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Home My WebLink About20130729Staff 11-24 to IPC.pdfKRISTINE A. SASSER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-03s7 BAR NO. 6618 Street Address for Express Mail: 472 W , WASHINGTON BOISE, IDAHO 83702-5918 Attomey for the Commission Staff IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR INYESTMENT IN SELECTIVE CATALYTIC REDUCTION CONTROLS ON JIM BRIDGER UNITS 3 AND 4. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-13-16 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company) provide the following documents and information on or before MONDAY, AUGUST 19, 2013. This Production Request is to be considered as continuing, and Idaho Power 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 answers to each question and any supporting workpapers that provide detail or are the source of information used in calculations. The Company is reminded that responses pursuant to Commission Rules and Procedure must include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder and, if different, the witness who can sponsor the answer at hearing. Reference rDAPA 31.0t.01.228. SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF JULY 29,2013 In addition to the written copies provided as response to the questions, please provide all Excel and electronic files on CD with formulas activated. REQUEST NO. 11: Please reference Direct Testimony of Michael J. Youngblood, p.16, lines 3-15. Please provide all analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that result in the calculation of the revenue requirement of approximately $9.1 million and $9.7 million for Jim Bridger Units 3 and 4, respectively. REQUEST NO. 12: If not provided in response to Request No. 11, please provide the analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that calculate the depreciation expense and accumulated depreciation used in the calculation of the revenue requirements referenced in Mr. Youngblood's testimony. Please include within your response the capital investment (commitment estimate) by electric plant in service account number and the associated depreciation rate for each plant account. REQUEST NO. 13: [f the depreciation rates in response to Request No. 12 do not match the most recently Commission-authorized rates, please provide all studies, life cycle analyses and other information used to derive the depreciable lives of the plant additions. Please provide this information for each electric plant in service account. REQUEST NO. 14: If not provided in response to Request No. 11, please provide the analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that identiff the jurisdictional allocation factors (reference Application, pag€ 8, item l7). Please include within your response a comparison of these allocations to those approved within the Company's last general rate case. If the allocations used in the revenue requirement analysis prepared for this case do not match those used in the last general rate case, please identify in detail the differences and the reasoning underlying each difference. SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF JULY 29,2013 REQUEST NO. 15: Please provide all analyses, assumptions, workpapers and worksheets (in electronic form with formulas intact) that result in the calculation of the almost $12 million of Allowance for Funds Used During Construction (AFUDC) included within Mr. Youngblood's testimony. Reference Direct Testimony of Michael J. Youngblood, p.15,line 9. REQUEST NO.If the response to Request No. 15 includes a cash flow and AFUDC rate (in percentage) calculation, please identify how the cash flows per month were identified and/or forecasted and provide all supporting documentation associated with those amounts if not already provided. Please include within your response the accounting extracts for amounts incurred to date and all electronic files with formulas intact. REQUEST NO. 17: Please provide the actual AFUDC monthly rate calculations for July 2010 through July 2013. Please include within your response the documentation supporting those calculations and any review and analyses performed on them. REQUEST NO. 18: Please describe how the project will be financed. Please include within your response a summary of the payment schedule that will be followed. Please also provide within your response copies of any financing agreements. REQUEST NO. 19: Please provide copies of the minutes of all Idaho Power Board of Directors' meetings (and committee and/or subcommittee meetings) at which the Project was discussed. Please provide within your response all analyses, presentations and any other materials that may have been provided to the Board of Directors and committee and/or subcommittees. REQUEST NO. 20: Has the Idaho Power Board of Directors authorized expenditure of funds for construction of the Project? If so, what amount has been authorized? Please include within your response the details of the amount authorized and, if it differs from the amount included within the Company's Application, why it differs. SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF JULY 29,2013 REQUEST NO. 21: If not already provided in response to Staff Production Request No. l, please provide copies of all contracts, leases, option agreements and memorandums of understanding signed to date for engineering, procurement, construction, major equipment, permits, and any other documents needed to complete the Project. REQUEST NO. 22: Please identify the amounts of non-refundable expense, investment and contractual obligations to date associated with the Project. REQUEST NO. 23: Please provide an unredacted copy of the Report and Order from the Public Service Commission of Utah, issued May 10,2013 for Docket No. 12-035-92. Reference the Company's Application, Attachment 2. REQUEST NO. 24: Please provide a detailed analysis of any differences between the project costs contained on pages 33 and 34 of the unredacted Report and Order from the Public Service Commission of Utah, issued May 10, 2013 for Docket No. 12-03 5 -92 and the total project costs contained in the Company's Application. Dated at Boise, Idaho, this day of July 2013. frr Kristine A. Sasser Deputy Attomey General Technical Staff: Patricia Harmsl Il -24 i:umisc:prodreq/ipcel3. l6ksph prod req 2 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF JULY 29,2073 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 29,, DAY oF JULY 2013, SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-8.13.I6, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: LISA D NORDSTROM JENNIFER REINHARDT IDAHO POWER COMPANY PO BOX 70 BOrSE ID 83707-0070 E-MAIL: lnordstrom@idahopower.com j reinhardt@idahopower. com dockets@idahopower.com CB earry@ idahopower. com PETER J zuCHARDSON GREGORY M ADAMS RICHARDSON ADAMS 515 N 27TH ST BOISE ID 83616 peter@richardsonadams. com greg@richardsonadams. com BENJAMIN J OTTO ID CONSERVATION LEAGUE 7IO N 6TH ST BOISE ID 83702 botto@idahoconservation. org KEN MILLER SNAKE RIVER ALLIANCE BOX 1731 BOISE ID 83701 kmiller@ snakeriveralliance. ors DR DON READING 6070 HILL ROAD BOISE ID 83703 dreading@mindspring. com SECRETARY CERTIFICATE OF SERVICE