20130513Idaho Power 1-9 to ICIP.pdf

IDAHO
An IDACORP company
L:110
LISA D. NORDSTROM
Lead Counsel
Inordstrom(äidahopower.com -
May 13, 2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-13-10
2013 PICA and Revenue Sharing - Idaho Power Company's Response to the
First Production Requests of the Industrial Customers of Idaho Power to
Idaho Power Company
Dear Ms. Jewell:
Enclosed for filing in the above matter are 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") to Idaho Power Company. Also, enclosed are four (4) copies of a
confidential disk containing data responsive to ICIP's Production Request Nos. 5,6.f, and
8 to Idaho Power Company.
In addition, enclosed are four (4) copies of a non-confidential disk containing data
responsive to ICIP's Production Request Nos. 1, 2, 3, 4, and 7.
Very truly yours,
Lisa D. Nordstrom
LDN:evp
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
JULIA A. HILTON (ISB No. 7740)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstromidahopower.com
ihiltonidahopower.com
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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,
2013 THROUGH MAY 31, 2014
CASE NO. IPC-E-13-10
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Industrial Customers of Idaho Power to
Idaho Power Company dated April 25, 2013, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -1
REQUEST NO. 1: Please provide a working electronic copy of Exhibit No. 3 to
Scott Wright's testimony.
RESPONSE TO REQUEST NO. 1: Please see the Excel file, provided on the
non-confidential CD, which contains a working electronic copy of Exhibit No. 3 to Scott
Wright's testimony.
The response to this Request was prepared by Scott Wright, Regulatory Analyst
II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -2
REQUEST NO. 2: Please provide a working electronic copy of Exhibit No. 4 to
Scott Wright's testimony.
RESPONSE TO REQUEST NO. 2: Please see the Excel file, provided on the
non-confidential CD, which contains a working electronic copy of Exhibit No. 4 to Scott
Wright's testimony.
The response to this Request was prepared by Scott Wright, Regulatory Analyst
II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -3
REQUEST NO. 3: Please provide a working electronic copy of Exhibit No. I to
Kelly [sic] Noe's testimony.
RESPONSE TO REQUEST NO. 3: Please see the Excel file, provided on the
non-confidential CD, which contains a working electronic copy of Exhibit No. I to Kelley
Noe's testimony.
The response to this Request was prepared by Kelley Noe, Regulatory Analyst,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -4
REQUEST NO. 4: Please provide a working electronic copy of Exhibit No. 2 to
Kelly [sic] Noe's testimony.
RESPONSE TO REQUEST NO. 4: Please see the Excel file, provided on the
non-confidential CD, which contains a working electronic copy of Exhibit No. 2 to Kelley
Noe's testimony.
The response to this Request was prepared by Kelley Noe, Regulatory Analyst,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -5
REQUEST 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)".
RESPONSE TO REQUEST NO. 5: Please see the confidential Excel file,
provided on the confidential CD, containing the requested documents for A, B, C and D.
The confidential CD will be provided to those parties that have executed the Protective
Agreement in this proceeding.
The response to this Request was prepared by Phillip DeVol, Resource Planning
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -6
REQUEST NO. 6: On pages 12 and 13 of his direct testimony Tim Tatum
presents Table 2. The following 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
format) the power output of each PURPA project along with the dollar costs of each
project.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -7
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-1 3-04?
RESPONSE TO REQUEST NO. 6:
A. The methods and assumptions used in the forecast of coal, gas,
hydroelectric generation, cogeneration and small power production ("CSPP"), power
purchase agreement ("PPA"), surplus sales and purchased power are listed below. The
same assumptions were used for both the 2012-2013 power cost adjustment ("PCA")
period and the 2013-2014 PCA period.
1.Hydroelectric resources are modeled based on the most recent
water forecast and consider system constraints such as generator
maintenance or required minimum flows for fish operations.
2.CSPP and PPA resources are based on the most recent forecasts
provided by the projects.
3.Hedge transactions resulting from prior Operating Plan forecasts
are reflected in the system balance.
4.Coal and gas plants are analyzed based on whether the plant can
be economically dispatched compared to a forward market price.
5.All resources are compared to forecasted load to determine
monthly surpluses or deficits. Pricing for surplus sales and
purchased power forecasts for the PCA periods consist of two
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -8
primary parts: (I) already-transacted hedge sales or purchases at
(known) transacted prices and (2) anticipated sales or purchases of
energy valued at forward market energy prices.
The confidential forecast of coal resources for both the 2012-2013 and 2013-2014
forecasts will be available for onsite review. Please contact Doug Jones at 388-2615 or
Camilla Victoria at 388-5821 to schedule a time to review the documents.
B.Please see Idaho Power's response to the Industrial Customers of Idaho
Power Production Request No. 6.A above for the explanation of the method and
assumptions used in the forecast. The confidential forecast of gas resources for both
the 2012-2013 and 2013-2014 forecasts will be available for onsite review. Please
contact Doug Jones at 388-2615 or Camilla Victoria at 388-5821 to schedule a time to
review the documents.
C.Market energy prices, by month, for the 2012-2013 PCA forecast period
are based on the forward price curve as of March 21, 2012, for Mid-Columbia and the
Idaho Power border. The confidential forward price curve will be available for onsite
review. Please contact Doug Jones at 388-2615 or Camilla Victoria at 388-5821 to
schedule a time to review the documents.
D.Please see Idaho Power's response to the Industrial Customers of Idaho
Power Production Request No. 6.A above for the explanation of the method and
assumptions used in the forecast. The primary change that occurred between the
2012-2013 PCA forecast and the 2013-2014 PCA forecast is a decline in hydroelectric
conditions. Poor hydro conditions led to an estimated reduction of 1.8 megawatt-hours
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -9
("MWh") of hydroelectric generation between the two forecast periods. This reduction in
hydroelectric generation negatively impacts the surplus sales forecast.
E.The confidential forecast of CSPP resources for both the 2012-2013 and
2013-2014 forecasts will be available for onsite review. Please contact Doug Jones at
388-2615 or Camilla Victoria at 388-5821 to schedule a time to review the documents.
F.Please see the confidential Excel file, provided on the confidential CD.
The Company did not adjust its forecast of incentive payments for the FlexPeak
program for the 2013-2014 PCA period to reflect its proposed modification as filed in
IPC-E-1 3-04. The confidential CD will be provided to those parties that have executed
the Protective Agreement in this proceeding.
The response to this Request was prepared by Philip DeVol, Resource Planning
Leader, Idaho Power Company, and Pete Pengilly, Customer Research and Analysis
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -10
REQUEST 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.
RESPONSE TO REQUEST NO. 7: On April 30, 2013, the Company filed
replacement pages 14 and 15 to Timothy E. Tatum's direct testimony. As stated in the
cover letter, the $9.2 million difference in base level net power supply expenses
("NPSE"), described on pages 14 and 15 of Mr. Tatum's direct testimony, incorrectly
approximated $1.5 million in approved market energy purchases for transmission
losses, which are recorded to Federal Energy Regulatory Commission ("FERC")
Account 555, Non-Public Utility Regulatory Policies Act of 1978 ("PURPA"). The
inclusion of the $1.5 million in market purchases for transmission losses results in a
difference in base level NPSE of $7.7 million on an Idaho jurisdictional basis.
The $9.2 million difference was not used in the PCA computations presented in
this case. Therefore, this correction does not have any impact on the Company's
request in Case No. IPC-E-13-10. The discussion of the difference in base level NPSE
resulting from the Langley Gulch power plant rate adjustment was for informational
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -11
purposes only. The Excel file, provided on the non-confidential CD, contains the
quantification of the $7.7 million difference in base level NPSE.
The incremental revenue requirement identified on page 14 at line 15 of Mr.
Tatum's direct testimony references the increase of $58,105,578 in the annual revenue
requirement associated with the addition of the Langley Gulch power plant as approved
in Order No. 32585. The incremental revenue requirement of $58.1 million includes the
change in NPSE associated with the addition of Langley Gulch.
The Company used the AURORA model to determine the dispatch for the
Langley Gulch power plant. Based on the AURORA dispatch logic, the overall capacity
factor for the test period approved in Order No. 32585, was 40 percent.
The response to this Request was prepared by Tim Tatum, Cost of Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -12
REQUEST 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.
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.
RESPONSE TO REQUEST NO. 8:
A.The positive values recorded in all months are for Western Renewable
Energy Generation Information System fees associated with the Renewable Energy
Credit ("REC") sales. These fees offset the sales revenue.
B.Please see the confidential Excel file provided on the confidential CD.
The counterparty name is in column E, number of RECs is in column A and price of
each REC is in column B. The months are highlighted in yellow in column A. The
confidential CD will be provided to those parties that have executed the Protective
Agreement in this proceeding.
C.Please see the confidential Excel file provided in Idaho Power's response
to the Industrial Customers of Idaho Power's Production Request No. 8.13. The source
of the RECs is in column F by month.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -13
The response to this Request was prepared under the direction of Scoff Wright,
Regulatory Analyst II, by Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -14
REQUEST 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.
RESPONSE TO REQUEST NO. 9: The $111,145,245 shown in Table I on page
6 of Tim Tatum's testimony is calculated by using the forecast components that are
calculated in Scott Wright's testimony. The $111,145,245 is calculated by multiplying
the PCA forecast rate of 0.8258 cents per kilowatt-hour ("kWh") by the Idaho
jurisdictional sales of 13,459,099.624 MWh (0.8258 multiplied by 10 multiplied by
13,459,099.624 equals $111,145,245). The references to those calculations in Mr.
Wright's testimony are shown below:
• Difference of net 95 percent accounts equals $57,214,521 shown on page 6, line
3.
• Difference of PURPA expense equals $68,880,072 shown on page 6, line 13.
• Difference of Demand Response Incentive payments equals -$6,583,305 shown
on page 7, line 7.
• Rate for net 95 percent accounts equals 0.3858 cents/kWh shown on page 8,
line 6.
• Rate for PURPA expense equals 0.4889 cents/kWh shown on page 8, line 9.
• Rate for Demand Response Incentive payments equals -0.0489 cents/kWh
shown on page 8 line 13.
• Total Forecast portion of the PCA rate equals 0.8258 cents/kWh.
• Idaho jurisdictional sales equals 13,459,100 MWh shown on page 8, line 13.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -15
The Company's Response to the Industrial Customers of Idaho Power
Production Request No. 6 includes the assumptions used in the forecast. The
confidential Operating Plan will be available for onsite review. Please contact Doug
Jones at 388-2615 or Camilla Victoria at 388-5821 to schedule a time to review the
documents.
The response to this Request was prepared by Scott Wright, Regulatory Analyst
II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
DATED at Boise, Idaho, this 13 th day of May 2013.
LISA D. NORD$5ROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13th day of May 2013 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INUDSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY upon the following named parties by the method indicated below,
and addressed to the following:
Commission Staff
Karl T. Klein
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
6070 Hill Road
Boise, Idaho 83703
X Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email karl. kIeinDuc.idaho.qov
Hand Delivered
X U.S. Mail
Overnight Mail
FAX
X Email Qeterrichardsonandoleary.com
qregrichardsonandoleary.com
Hand Delivered
X U.S. Mail
Overnight Mail
FAX
X Email dreadinq(mindsprinp.com
Elizabeth Paynter, Leg Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY -17