20130802IPC to ICIP 1-4.pdf

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An IDACORP Company-Gd,1:_; '
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LISAD.NORDSTROM :r;, i:,.";
Lead Counse! r .. t' 'l :" .: '":,
[e-mail] i I 'r I
August 1,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
!daho 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 Response to the First Production Request of
the l'ndustrial Customers of ldaho Power
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the First Production Request of the lndustrial Customers of
ldaho Power to ldaho Power Company.
Also, enclosed in a separate envelope are four (4) copies of the confidential disk
containing information responsive to the lndustrial Customers of ldaho Power's Request for
Production No. 4.B. Please handle the confidential information in accordance with the
Protective Agreement executed in this matter.
Sincerely,
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
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Lisa D. Nordstrom
LDN:csb
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
JENNIFER M. REINHARDT-TESSMER (lSB No. 7432)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@ idahopowe r. com
i rei n ha rdt@ id a hopower. com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC
!N THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERT!FICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE INVESTMENT
IN SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JIM BRIDGER UNITS 3
AND 4.
UTILITIES COMMISSION
CASE NO. IPC-E-13-16
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO
POWER COMPANY
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COMES NOW, Idaho Power Company ("!daho Power" or "Company"), and in
response to the First Production Request of the lndustria! Customers of ldaho Power
("lClP") to ldaho Power Company dated July 1 1, 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 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 al! discussions between NV Energy and
ldaho 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see ldaho
Power's objection to this Request filed on July 25, 2013.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, ldaho 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 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 Power'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 coal-fired
generation" why the Company did not include emission control investments for the
Valmy units as part of its CPCN request to the ldaho Commission
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see Idaho
Power's objection to this Request filed on July 25, 2013.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, ldaho 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 FOR PRODUCTION NO. 3: ldaho Power's application at page 8
At the Company's current authorized rate of return, the
additional annual revenue requirement for SCR investments
in Jim Bridger Unit 3 and Jim Bridger Unit 4 would be
approximately $9.1 million and 9.7 million, respectively.
A. lf the full amounts were granted to the Company by the Commission what
would be the estimated percentage increase in overall rates?
B. 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. lf the full amount were granted to the Company by the Commission along
with the Valmy emission control costs, how does ldaho Power propose to include the
expenditures in rates? (e.9. 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
A. To be clear, in the Company's Application for a Certificate of Public
Convenience and Necessity ("CPCN"), the Company did not request cost recovery of
any investment in Selective Catalytic Reduction ("SCR') equipment at the Jim Bridger
plant at this time. However, if the ldaho Public Utilities Commission was to grant
recovery beginning today, the full amount of the additional annual revenue requirement
for SCR investments in Jim Bridger Unit 3 and Jim Bridger Unit 4 would be
approximately $9.1 million and $9.7 million, respectively. Based upon the current ldaho
jurisdictional base revenue of $886,884,888 used in the Company's most recent Power
Cost Adjustment ('PCA") filing (Case No. IPC-E-13-10), the overall estimated
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY - 4
percentage increase in rates would be 1.03 percent and 1.09 percent, respectively, or
2.12 percent combined.
B. ldaho Power objects to lClP's Production Request No. 3.B on the grounds
that it is not likely to lead to the discovery of admissible evidence and calls for
speculation. Notwithstanding the foregoing objection, as noted in Exhibit No. 5 to the
Direct Testimony of Tom Harvey, the Valmy Dry Sorbent lnjection ("DSl") emission
controls for compliance with the acid gases section of the Mercury and Air Toxics
(MATS) Rule requires an initial capita! expenditure of approximately $8.0 million in
2015. Using the same assumptions used in estimating the additional annual revenue
requirement for SCR investments in Jim Bridger Unit 3 and Jim Bridger Unit 4 of
approximately $9.1 million and $9.7 million, respectively, a high level estimate of the
additiona! revenue requirement for the Valmy DS! investment would be approximately
$1.2 million. Based upon the current ldaho jurisdictional base revenue of $886,884,888
used in the Company's most recent PCA filing, the estimated additional overall
percentage increase in rates today would be approximately 0.14 percent.
C. The Company has not determined the approach by which future cost
recovery will be requested.
The response to this Request was prepared by Michael J. Youngblood, Manager
of Regulatory Projects, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho 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 FOR PRODUCTION NO. 4: Lisa Grow's prefiled testimony at page 9
states:
The Jim Bridger Plant has the lowest dispatch cost of ldaho
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.
C. Please provide the expected dispatch of each unit in the Company's
thermal fleet for the period of June 2013 through May 2014.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
A. The May 2013 Operating Plan is highly confidential and contains
proprietary information that can be viewed on site at ldaho Power's corporate
headquarters. Please contact Doug Jones at 388-2615 or Camilla Victoria at 388-5821
to view the materials.
B. Please see the confidential Excel file provided on the confidential CD for
expected thermal dispatch cost information. The confidential CD will be provided to
those parties that have signed the Protective Agreement in this matter.
C. The expected dispatch of ldaho Power's thermal units is highly
confidentia! and contains proprietary information that can be viewed on site at ldaho
Power's corporate headquarters. Please contact Doug Jones at 388-2615 or Camilla
Victoria at 388-5821 to view the materials.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY - 6
The response to this Request was prepared by
Manager, ldaho Power Company, in consultation with
Counsel, Idaho Power Company.
DATED at Boise, ldaho, this 1" dry of August 2013.
Tom Harvey, Joint Projects
Lisa D. Nordstrom, Lead
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1't day of August 2013 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO 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 Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Industrial 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 Conservation 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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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY - 8