20130725IPC Objections to ICIP.pdf

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An IDACORP Company
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LISA D. NORDSTROi'
Lead Counse!
I [e-mail]
July 25, 2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-16
Certificate for Public Convenience and NecessityforJim Bridger Units 3 and
4 - ldaho Power Company's Obiections to Request for Production Nos. 1
and 2 of the First Production Request of the lndustrial Customers of ldaho
Power
Dear Ms. Jewell:
Enclosed for filing in the above matter are an origina! and three (3) copies of ldaho
Power Company's Objections to Request for Production Nos. 1 and 2 of the First
Production Requestof the IndustrialCustomersof ldaho Powerto ldaho PowerCompany.
Sincerely,
;Kr-04,*t"*
Lisa D. Nordstrom
LDN:csb
Enclosures
:.j.-i '-
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
JENNIFER M. REINHARDT-TESSMER (lSB No. 7432)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@ idahopower. co m
irein ha rdt@ idaho power. co m
Attorneys for ldaho Power Company
!N THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE INVESTMENT
IN SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JIM BRIDGER UNITS 3
AND 4.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. |PC-E-13-16
IDAHO POWER COMPANY'S
OBJECTIONS TO REQUEST FOR
PRODUCTION NOS. 1 AND 2 OF
THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
TO IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("!daho Powe/' or "Compony"), and
objects to Request for Production Nos. 1 and 2 of the First Production Request of the
lndustrial Customers of Idaho Power to ldaho Power Company dated July 1 1, 2013, as
follows:
IDAHO POWER COMPANY'S OBJECTIONS TO REQUEST FOR PRODUCTION NOS. 1 AND 2 OF
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO
IDAHO POWER COMPANY - 1
REQUEST FOR PRODUCTION NO. 1: ldaho Powe/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:
ln April 2013, NV Energy announced a schedule to retire the
North Valmy Coal Plant. ldaho Power is a one-half owner of
the North Valmy coal plant, and NV Energy is the operating
partner. ldaho 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.
OBJECTION TO REQUEST FOR PRODUCTION NO. 1: ldaho Powerobjects to
this Request for Production No. 1 (A-C) on the grounds that the requested information is
not reasonably calculated to lead to the discovery of admissible evidence and/or is not
relevant to the subject matter of this case. Idaho Power has filed a request for a
Certificate of Public Convenience and Necessity for pollution control investments at the
Jim Bridger power plant. Consequently, this case does not impact nor relate to the
North Valmy power plant.
The objection to this Request was prepared by Jennifer M. Reinhardt-Tessmer,
Corporate Counsel, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S OBJECTIONS TO REQUEST FOR PRODUCTION NOS. 1 AND 2 OF
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO
IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 2: Lisa Grow's prefiled testimony, at page
19, states:
O. Are emission control investments at Valmy part of the
Company's current CCPCN [sic/ request?
A. No. While the Valmy plant is not a part of the
Company's request for a CPCN for the SCR
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 ldaho Powe/s understanding of Nevada's legislation as it
relates to the retirement of the North Valmy Units 1 and 2.
B. Please explain, given the "changing climate with regard to coa!-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
OBJECTION TO REQUEST FOR PRODUCTION NO. 2: ldaho Power objects to
this Request for Production No. 2 (A-B) on the grounds that the requested information is
not reasonably calculated to lead to the discovery of admissible evidence and/or is not
relevant to the subject matter of this case. ldaho Power has filed a request for a
Certificate of Public Convenience and Necessity for pollution control investments at the
Jim Bridger power plant. Consequently, this case does not impact nor relate to the
North Valmy power plant. Moreover, the request improperly calls for a statement of
opinion or policy that has not been previously written or published pursuant to Rule of
Procedure 225.O1(a).
IDAHO POWER COMPANY'S OBJECTIONS TO REQUEST FOR PRODUCTION NOS. 1 AND 2 OF
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO
IDAHO POWER COMPANY.3
The objection to this Request was prepared by Jennifer M. Reinhardt-Tessmer,
Corporate Counsel, ldaho Power Company, and Lisa D. Nordstrom, Lead Counsel,
ldaho Power Company.
DATED at Boise, ldaho, this 25th day of July 2013.
IDAHO POWER COMPANY'S OBJECTIONS TO REQUEST FOR PRODUCTION NOS. 1 AND 2 OF
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO
IDAHO POWER COMPANY - 4
D. NORDS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 25th day of July 2013 I served a true and correct
copy of IDAHO POWER COMPANY'S OBJECTIONS TO REQUEST FOR
PRODUCTION NOS. 1 AND 2 OF THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL 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
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Snake River Alliance
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
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Christa Bearry, Legal Assistant
IDAHO POWER COMPANY'S OBJECTIONS TO REQUEST FOR PRODUCTION NOS. 1 AN
THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO
IDAHO POWER COMPANY - 5