20130711ICIP 1-4 to IPC.pdf

Peter J.Richardson ISB #3195
RiCHARDSON ADAMS,PLLC
515 N.27th Street
Boise,Idaho 83702
Telephone:[phone]
fax:(20$)938-7904
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
2ni:JUL Ii PH 3:21+
U I ,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
A CERTIFICATE Of PUBLIC CONVENIENCE
AND NECESSITY FOR THE INVESTMENT
IN CATALYTIC REDUCTION CONTROLS
ON JIM BRIDGER UNITS 3 AND 4.
)CASE NO.IPC-E-13-16
)FIRST PRODUCTION
)REQUEST Of THE
)INDUSTRIAL CUSTOMERS
)Of IDAHO POWER TO
)IDAHO POWER COMPANY
)
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 (“Idaho
Power”)provide the following documents.
This production request is to be considered as continuing,and Idaho Power 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 copy of your answer to Mr.Richardson at the address noted above and
one copy to Dr.Reading at 6070 Hill Road,Boise,Idaho 83703.Please provide Dr.Reading’s
copy at dreading(mindsprin.net in electronic format,if available.
-FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER-IPC-E-13-16
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:
Idaho Power’s 2013 IRP (Attachment 4 to the Application at page 95)discusses NV
Energy’s announcement about retiring North Valmy Unit 1 in 2020 and North Valmy Unit 2 in
2025 stating:
In April 2013,NV Energy announced a schedule to retire the North Valmy Coal Plant.
Idaho Power is a one-half owner of the North Valmy coal plant,and NV Energy is the
operating partner.Idaho Power has not agreed to the North Valmy plant retirement
schedule announced by NV Energy.
A.Please provide a narrative of all discussions between NV Energy and Idaho Power related
to the retirement of North Valmy units 1 and 2.
B.Please provide all documents relating to the retirement of North Valmy Units 1 and 2.
C.Please provide copies of the contracts for the operation,ownership and maintenance of
the North Valmy Units 1 and 2.
REQUEST FOR PRODUCTION NO.2
Lisa Grow’s prefiled testimony,at page 19,states:
Q.Are emission control investments at Valmy part of the Company’s current CCPCN
request?
A.No.While the Valmy plant is not a part of the Company’s request for a CPCN for the
5CR investments at Jim Bridger Units 3 and 4,the Nevada legislation associated with NV
Energy’s announcement is yet another indication of the changing climate with regard to coal
fired generation.
A.Please explain Idaho Power’s understanding of Nevada’s legislation as it relates to the
retirement of the North Valmy Units 1 and 2.
2 -FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER-IPC-E-13-16
B.Please explain,given the “changing climate with regard to coal-fired generation”why the
Company did not include emission control investments for the Valmy units as part of its CPCN
request to the Idaho Commission
REQUEST FOR PRODUCTION NO.3.
Idaho Power’s application at page $states:
At the Company’s current authorized rate of return,the additional annual revenue
requirement for 5CR investments in Jim Bridger Unit 3 and Jim Bridger Unit 4 would be
approximately $9.1 million and 9.7 million,respectively.
A.If the full amounts were granted to the Company by the Commission what would be the
estimated percentage increase in overall rates?
3.Assuming the Valmy emission control costs were added to those for Bridger what would
be the dollar amount and overall percentage increase in rates?
C.If the full amount were granted to the Company by the Commission along with the Valmy
emission control costs,how does Idaho Power propose to include the expenditures in rates?(e.g.
as part of a general rate case,single issue rate case etc)What is the Company’s expected
timeline for filing to recover the costs associated with this CPCN application?
REQUEST FOR PRODUCTION NO.4
Lisa Grow’s prefiled testimony at page 9 states:
The Jim Bridger Plant has the lowest dispatch cost of Idaho Power’s entire thermal generation
fleet.Based on the Company’s May 2013 Operating Plan,the Jim Bridger Plant’s average
dispatch cost is expected to be
____/MWh
over the period of June 2013 through May 2014.For
comparison purposes,the average dispatch cost for the remaining baseload thermal fleet is
expected to be /MWh over the same period.
A.Please provide a copy of the referenced “Operating Plan”.
B.Please provide supporting documentation for the calculation of “the remaining baseload
thermal fleet[’s]”dispatch costs.
3 -FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER -IPC-E-13-16
C.Please provide the expected dispatch of each unit in the Company’s thermal fleet for the
period of June 2013 through May 2014.
DATED this 11th day of July 2013.
RICHARDSON ADAMS,PLLC
By:________
Peter J.Richardson,ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
4 -FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER-IPC-E-13-16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11th day of July,2013,a true and correct copy of the
foregoing FIRST PRODUCTION REQUEST Of THE iNDUSTRIAL CUSTOMERS OF
IDAHO POWER was served by hand delivery to:
Lisa Nordstrom
Jennifer Reinhardt-Tessmer
Idaho Power Company
1221 West Idaho Street
P0 Box 70
Boise,Idaho 83 707-0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Administrative Assistant
5 -FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER -IPC-E-13-16
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