HomeMy WebLinkAbout20130827Staff 45-48 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:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF rDAHO POWER )
coMPANy'S APPLICATION FOR A ) CASE NO. IPC-E-13-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR INVESTMENT IN ) FOURTH PRODUCTION
SELECTIVE CATALYTIC REDUCTION ) REQUEST OF THE
CONTROLS ON JIM BRTDGER UNrrS 3 AND 4. ) COMMTSSTON 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 (Idaho Power;
Company) provide the following documents and information on or before TUESDAY,
SEPTEMBER 10, 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
FOURTH PRODUCTION REQUEST OF
THE COMMISSION STAFF AUGUST 27,2013
record holder and, if different, the witness who can sponsor the answer at hearing. Reference
IDAPA 31.01 .01.228.
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. 45: Please explain why Sulfur Dioxide (SO2) emission levels for Jim
Bridger Unit 4 are almost 300 times lower than the levels for Jim Bridger Unit 3 as shown in
Table A-l in Tom Harvey's Exhibit No. 5.
REQUEST NO. 46: In Tom Harvey's Exhibit No. 5 (page 3-8), it says "the study
approach examined costs and benefits of each unit's upgrade or retirement decision separately,"
and that "...the effects of the given unit's scenario was isolated and considered no interaction with
any other units on the IPC system." Because each analysis was isolated from the system, it
would seem that if a generation unit does not require natural gas as fuel for a given scenario, that
the price of natural gas would have no effect on the analysis results. Please explain why the
Total Cost results for the Emission Upgrade Scenario for Jim Bridger Unit 3 (page 4-6) and Unit
4 (page 4-8) show increasing Total Net Present Value (NPV) costs with increasing natural gas
prices for a given carbon price (i.e. carbon prices are held constant).
REQUEST NO. 47: In Tom Harvey's Exhibit No. 5 (page 3-9), the Company and SAIC
assumed that a price of carbon from burning natural gas would be 50 percent of the $/MWh price
for coal. In the Natural Gas Conversion scenarios for Jim Bridger Units 3 and 4 in the low and
planning gas cases, the Total NPV cost results for the high carbon cases are lower than the no
carbon and planning carbon cases for a given natural gas price. Please explain why the high
carbon cases reflect a higher total cost than the no carbon or planning carbon cases.
REQUEST NO. 48: In response to Staffs Production Request No. 5, the Company
states "there are no large future transmission investments between Jim Bridger and the Treasure
Valley that can be avoided if Jim Bridger Units 3 and 4 were to be shut down." Per the original
request, Staff requests whether or not transmission investments can possibly be avoided or
FOURTH PRODUCTION REQUEST OF
THE COMMISSION STAFF AUGUST 27,2013
Dated at Boise, Idaho, tfri, O,7traay of August 2013.
Technical Staff: Mike Louisl45 - 48
"delayed." Please answer the question as it pertains to
specifically whether or not investment in the Gateway
or delayed.
"delaying" potential investment and
West transmission line could be avoided
i:umisc:prodreq/ipcel3. I 6ksml prod req 4
FOURTH PRODUCTION REQUEST OF
THE COMMISSION STAFF
Deputy Attorney General
AUGUST 27,2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF AUGUST 2013,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-13-16, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
JENNIFER REINHARDT-TES SMER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : lnordstrom@idahopower.com
j reinhardt@idahopower. com
dockets@ idahopower. com
C Bearry@idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS
515 N 27TH ST
BOISE ID 83616
E-MAIL: peter@richardsonadams.com
sres@.richardsonadams.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: botto@idahoconservation.ore
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmiller@snakeriveralliance.ors
DR DON READINU
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadine@mindspring.com
DEAN J MILLER
CHAS F McDEVITT
CELESTE K MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOISE TD 83702
E-MAIL: joe@mcdevitt-miller.com
chase@mcdevitt-mil ler. com
ck@mcdevitt-miller. com
CERTIFICATE OF SERVICE