20130425ICIP 1-9 to Idaho Power.pdf

I
Peter J. Richardson ISB #3195
Gregory M. Adams ISB # 7454
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
gregrichardsonandoleary.com
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Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
IMPLEMENT POWER COST
ADJUSTMENT MECHANISM (PCA)
RATES FROM JUNE 1, 2013 THROUGH
MAY 31. 2014
) CASE NO. IPC-E-13-10
)
) FIRST PRODUCTION REQUEST OF
) THE INDUSTRIAL CUSTOMERS OF
) IDAHO POWER
)
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. 3 to Scott Wright's testimony.
REQUEST FOR PRODUCTION NO. 2
Please provide a working electronic copy of Exhibit No. 4 to Scott Wright's testimony.
REQUEST FOR PRODUCTION NO. 3
Please provide a working electronic copy of Exhibit No. 1 to Kelly Noe's testimony.
REQUEST FOR PRODUCTION NO. 4
Please provide a working electronic copy of Exhibit No. 2 to Kelly Noe's testimony.
REQUEST FOR PRODUCTION NO. 5
Exhibit 5 of Tim Tatum's testimony is a memo from Phillip DeVol to Tim Tatum, dated
April 9, 2013. The following requests relate to that memo.
A.Please provide a working electronic copy of the data use to produce the graph at
the top of page 5 labeled "Surplus Sales (MWh)".
B.Please provide a working electronic copy of the data use to produce the graph at
the top of page 6 labeled "Market and Thermal Dispatch Prices".
C.Please provide a working electronic copy of the data use to produce the graph on
page 6 labeled "Thermal Dispatch (MWh)".
D.Please provide a working electronic copy of the data use to produce the graph at
the top of page 6 labeled "Native Load (MWh)".
REQUEST FOR PRODUCTION NO. 6
On pages 12 and 13 of his direct testimony Tim Tatum presents Table 2. The following
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E- 12-17
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requests reference Table 2.
A.Please provide all documents and spreadsheets (in workable electronic formats)
used in the forecast of coal resources for both the 2012-2013 and 2013-2014
forecasts. Please include an explanation of the method and assumptions used in
the forecast to lead to the dollar amounts listed in Table 2 for coal. Please also
include each coal unit that was assumed to be on-line and the level of output for
each unit split between that needed to meet firm load and that assumed to be for
surplus sales.
B.Please provide all documents and spreadsheets (in workable electronic formats)
used in the forecast of gas resources for both the 2012-2013 and 2013-2014
forecasts. Please include an explanation of the method and assumptions used in
the forecast that lead to the dollar amounts listed in Table 2 for gas. Please also
include each gas unit that was assumed to be on-line and the level of output for
each unit split between that needed to meet firm load and that assumed to be for
surplus sales.
C.Please provide an explanation of the assumed market energy prices, by month, for
the 2012-2013 PCA forecast period,
D.Please provide assumptions and methods used in the forecast of $11.7 million
lower forecast of surplus sales for the 2013-2014 PCA period relative to the
surplus sales forecast for the 2012-2013 PCA period.
E.Please provide a list of the PURPA projects included in the forecasts for 2012-
2013 and for 2013-2014 PCA periods. Please provide (in workable electronic
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-12-17
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format) the power output of each PURPA project along with the dollar costs of
each project.
F. Please provide the estimates of incentive payments for each of the three demand
response programs for both the 2012-2013 and for 2013-2014 PCA periods. Did
the Company assume in its forecast of incentive payments for the FlexPeak
program for the 2013-2014 PCA period that the Commission will approve its
proposed modification as filed in IPC-E-13-04?
REQUEST FOR PRODUCTION NO. 7
On pages 14 and 15 of his direct testimony Tim Tatum states since the Company's base
rates changed on July 1, 2013 the incremental revenue requirements associated with the
Langley Gulch plant decreased by approximately $9.2 million. Please provide an
explanation of how the $9.2 million was derived, along with all documents and
spreadsheets (in workable electronic formats) used in the calculation. Please indicate the
definition of "incremental revenue requirement" (ref. page 14 at line 15) and specify if it
includes the $58.1 million the Commission authorized to be included in base rates for the
Langley Gulch project in Order 32585. Also please include the assumed capacity factor
for Langley Gulch used in the predication.
REQUEST FOR PRODUCTION NO. 8
For the following request please reference Exhibit 3 of Scott Wright's testimony. Line 38
is titled "Renewable Energy Credit Sales" and includes both negative and positive values.
A. Please explain the small but positive values for October of 2012, and December
2012 through March 2013.
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
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B.Please provide a list, per month, each party the REC's were sold to, the number of
RECs, and the price of each REC.
C.Please provide a list, per month, of the source and number of RECs sold by the
Company during the April 2012 to March 2013 period.
REQUEST FOR PRODUCTION NO. 9
Please provide all documents and spreadsheets (in workable electronic formats) used in
the forecast of the $111,145,245 for the PCA 2013 —2014 as shown in Table 1, page 6 of Tim
Tatum's testimony. Please describe all assumptions used in the forecast and a copy of the
Operation Plan used for the forecast.
DATED this 25TH day of April 2013
Richardson & 'Leary, PLLC
ByO
Peter J. J. Richardson
Industrial Customers of Idaho Power
CERTIFICATE OF SERVICE
I hereby certify that on 25th day of April 2013, copies of the foregoing First Production
Request of the Industrial Customers of Idaho Power were hand delivered to:
Julia Hilton
Lisa Nordstrom
Idaho Power Company
1221 West Idaho
Boise, Idaho 83702
Scott Wright
Gregory Said
Idaho Power Company
1221 West Idaho
Boise, Idaho 83702
Jean Jewel
Secretary
Idaho Public Utilities Com'n
472 West Idaho
Boise, Idaho 83702
CkA~.,'
Nina Curtis
Administrative Assistant
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
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