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Home My WebLink About20120503IPC to ICIP 1-4.pdfHO PNER® R ECEfVED An IDACORP Company 2012 MAY -3 PM 4: 28 JULIA A. HILTON LJAHO FtJ Corporate Counsel UTt LIT! :S COMM S jhiltonidahopower.com May 3, 2012 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-12-17 2012-2013 PCA Rates - Response to First Production Request of the Industrial Customers of Idaho Power Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Response to the First Production Request of the Industrial Customers of Idaho Power ("ICIP") in the above matter. Also enclosed are four (4) copies of a non-confidential disk containing information responsive to ICIP's First Production Request. Very truly yours, ulia A. Hilton JAH:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 JULIA A. HILTON (ISB No. 7740) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-6117 Facsimile: (208) 388-6936 ihiItoncidahopower.com lnordstromidahopower.com RECEIVED 2012 MAY -3 PM 14:28 DAHO PL; ;LK UT1UTES COMMISSION Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO IMPLEMENT POWER COST ADJUSTMENT (PCA) RATES FOR ELECTRIC SERVICE FROM JUNE 1, 2012 THROUGH MAY 31, 2013 CASE NO. IPC-E-12-17 IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Industrial Customers of Idaho Power dated April 16, 2012, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -1 REQUEST FOR PRODUCTION NO. 1: Please provide a working electronic copy of Exhibit No. I to Scott Wright's testimony. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the attached Excel file. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Julia A. Hilton, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -2 REQUEST FOR PRODUCTION NO. 2: At page 13 of his prefiled testimony Mr. Wright identifies several factors causing a reduction in FERC Account 501 (Coal) in the current forecast PCA filing from the base amount. Among those factors include better than normal hydro. At the top of page 15 Mr. Wright notes that the base PCA case assumed 6.7 MAF streamfiow for Brownlee and the current PCA filing has a twenty percent reduction in hydo [sic] at 5.6 MAF. Can you please reconcile how a forecast reduction in hydro causes reduced forecast thermal generation need as between the base PCA and the current forecast PCA filing? RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Page 14, line 24 of Mr. Wright's Direct Testimony states that "Normal is defined as median, which is 4.9 million acre feet ['MAF']." This year's April-July streamflow forecast for Brownlee reservoir is 5.6 MAF. Wright Direct Testimony, page 15, line 2. Last year's April-July streamflow forecast for Brownlee reservoir was 6.7 MAF. Wright Direct Testimony, page 15, line 3. At the top of page 15, Mr. Wright's Direct Testimony compares forecast hydro conditions to base level hydro, not last year's forecast to this year's forecast. With this in mind, the forecast of above "normal" hydro conditions for this year's Power Cost Adjustment would suggest a lesser need for thermal generation as compared to base level assumptions. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Julia A. Hilton, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -3 REQUEST FOR PRODUCTION NO. 3: Mr. Wright identified the following three additional factors as contributing to the reduced coal costs in FERC Account 501; (1) lower market prices, (2) inclusion of Langley Gulch, and (3) additional PURPA power on the system. Please quantify the contribution of each factor to the reduced coal costs in FERC Account 501. Please provide copies of all computations, workpapers and other documents relied upon, created or used in preparing your response. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: As stated on page 3, starting on line I of Mr. Wright's Direct Testimony, "While there may be many factors that contribute to the net difference between the PCA base and forecast accounts, I will discuss the factors that I believe had variation worth noting." This statement was based upon the notable differences between the base power supply expense accounts starting on page 5 and the forecast of power supply expense accounts starting on page 7. Wright Direct Testimony. By examining the deviations between the base and forecast accounts, observations are made based upon the interplay of the base and forecast accounts. For example, the reduced coal generation forecast can be attributed to the following variables: (1) hydro generation that is above normal, as stated on page 15, line 2; (2) Langley Gulch power plant generation that is expected to come on-line in July 2012, as stated on page 8, line 3; and (3) additional Public Utility Regulatory Policies Act of 1978 power that increased by $66.7 million, as stated on page 10, line 10. Id. The statement on page 13, line 10 referring to lower market prices playing a factor in reduced coal generation was premised on the fact that current electric market conditions are in fact down from previous years, which can have a dramatic effect on the Company making additional surplus sales. Id. Other than the factors that were IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -4 described above, an analysis was not created beyond the observations of deviations between the base level power supply expenses and the forecast amounts described on pages 5 and 7 of Mr. Wright's Direct Testimony. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Julia A. Hilton, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -5 REQUEST FOR PRODUCTION NO. 4: On page 14 of his direct testimony Mr. Wright addresses the reduction in FERC Account No. 555, Purchased Power, non- PURPA. He explained that there are two reasons the reduced need for purchased non- PURPA power thusly: "The decrease can be attributed to the addition of Langley Gulch and PURPA energy, which both contribute to a reduced need for purchased power." Please quantify the contribution of each factor to the reduced need for purchased power. Please provide copies of all computations, workpapers and other documents relied upon, created or used in preparing your response. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the Company's response to the Industrial Customers of Idaho Power's Request for Production No. 3. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Julia A. Hilton, Corporate Counsel, Idaho Power Company. DATED at Boise, Idaho, this 3rd day of May 2012. jiAIAA.HILTON Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 3rd day of May 2012 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the following named parties by the method indicated below, and addressed to the following: Hand Delivered U.S. Mail Overnight Mail FAX X Email don.howellcpuc.idaho.pov Hand Delivered X U.S. Mail Overnight Mail FAX X Email Pete r(richardsonandoleary.com Qreq(ärichardsonandolearv.com Hand Delivered U.S. Mail Overnight Mail FAX X Email dread ingmindsprini.com CJAi1cci Commission Staff Donald L. Howell, II Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hill Road Boise, Idaho 83703 co Christa Bearry, Legal Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -7