20120416ICIP 1-4 to IPC.pdf

RECEIVED
Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454 2012 APR 16 PM (4: 16
RICHARDSON & O'LEARY PLLC
L/ ,i t th
IDAH O hUu bLI1 515 N. 27 Street JTJLITES COMMSS1ON
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. IPC-E-12-17
APPLICATION OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) FIRST PRODUCTION REQUEST OF
IMPLEMENT POWER COST ) THE INDUSTRIAL CUSTOMERS OF
ADJUSTMENT MECHANISM (PCA) ) IDAHO POWER
RATES FROM JUNE 1, 2012 THROUGH )
MAY 31, 2013
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; dreadingmindspring.com
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REQUEST FOR PRODUCTION NO 1
Please provide a working electronic copy of Exhibit No 1 to Scott Wright's testimony.
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 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?
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.
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
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E- 12-17
PAGE 2
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.
DATED this 16th day of April 2012
Richardson &O'Leary, PL ~C
By_ 146,~
Peter J. Richardson
Industrial Customers of Idaho Power
CERTIFICATE OF SERVICE
I hereby certify that on April 16, 2012, copies of the foregoing First Production Request
of the Industrial Customers of Idaho Power were hand delivered to:
Julia Hilton Scott Wright Jean Jewel
Lisa Nordstrom Gregory Said Secretary
Idaho Power Company Idaho Power Company Idaho Public Utilities Com'n
1221 West Idaho 1221 West Idaho 472 West Idaho
Boise, Idaho 83702 Boise, Idaho 83702 Boise, Idaho 83702
cL t\Luc
Nina Curtis
Administrative Assistant
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E- 12-17
PAGE 3