20130903IPC to Snake River 1-22.pdf

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An IDACORP Companv
LISA D. NORDSTROM
Lead Counsel
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September 3,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 W estWashington Street
Boise, ldaho 83702
Re: Case No. !PC-E-13-16
Certificate for Public Convenience and Necessity for Jim Bridger Units 3 and
4 - ldaho Power Company's Responses to the First Discovery Requests of
Snake River Alliance
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Responses to the First Discovery Requests of Snake River Alliance to
ldaho Power Company.
Also enclosed are four (4) copies of a confidential disk containing information
responsive to Snake RiverAlliance's requests. Please handle the confidentia! information
in accordance with the Protective Agreement executed in this matter.
Sincerely,
1221 W. ldaho St. (83702)
PO. 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 (!SB No. 7432)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ idahopower. com
irei n hardt@ id a hopower. co m
Attorneys for ldaho Power Company
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER )
coMPANY',S APPLTCATTON FOR A ) CASE NO. IPC-E-13-16
CERTTFTCATE OF PUBLTC CONVENTENCE )
AND NECESSTTY FOR THE INVESTMENT ) TDAHO POWER COMpANy',S
lN SELECTTVE CATALYTTC REDUCTTON ) RESPONSES TO THE FTRST
CoNTROLS ON JrM BRTDGER UN|TS 3 ) D|SCOVERY REQUESTS OF
AND 4.) SNAKE RIVER ALLIANCE TO
) rDAHO POWER COMPANY
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Discovery Requests of Snake River Alliance to ldaho Power
Company dated August 20,2013, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY. 1
REQUEST NO. 1: Does ldaho Power intend to apply to the IPUC for another
CPCN for Bridger Units 1 and 2, and also for either of the North Valmy units? lf so,
please describe what that application would entail and when such applications would be
reasonably expected to be filed.
RESPONSE TO REQUEST NO. 1: At this time, ldaho Power has not
determined whether or not it would file another Certificate for Public Convenience and
Necessity ("CPCN") filing for Jim Bridger Units 1 and 2. While the magnitude of the
estimated retrofit costs are similar to those for Units 3 and 4, the installation of Selective
Catalytic Reduction ("SCR') technology for Units 1 and 2 is not required until2022 and
2021, respectively.
The estimated costs for compliance with the Mercury and Air Toxics Standard
("MATS') for North Valmy are significantly less than that of Jim Bridger Units 3 and 4
and, at this time, the Company anticipates it would seek to recover those costs as part
of the incremental capital investment and operations and maintenance expense
determination in a general rate case proceeding.
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please explain the basis for the Company's decision to limit
this Application to the two SCR additions at Jim Bridger.
RESPONSE TO REQUEST NO. 2: As stated in the Direct Testimony of Lisa A.
Grow, p. 15, while the Company does not believe it is required to request a CPCN by
ldaho Code S 61-526, with the magnitude of the investment and the changing climate
for investments in coal-fired generation, the Company voluntarily requested a CPCN.
ldaho Power limited the CPCN request to the estimated costs of the SCRs which need
to be installed at Jim Bridger Units 3 and 4 by the end of 2015 and 2016, respectively, in
order to successfully comply with the federa! and state emissions regulations because
the SCR retrofits for Jim Bridger Units 1 and 2 are not required until 2022 and 2021,
respectively, and because the emission controls for the North Valmy units are not of the
same magnitude of investment as those at Jim Bridger Units 3 and 4.
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: ldaho Power's Coa! Unit Environmental lnvestment Analysis
for the Jim Bridger and North Valmy Coal-Fired Power Plants ("Coal Study," Page 4)l
states that "ldaho Power assumed that it could negotiate with state and federa! entities
a five-year period where no additiona! environmental controls are installed in exchange
for shutting the unit down at the end of the five-year period. These compliance timing
alternative cases are strictly hypothetica!. ldaho Power may not have any basis under
current regulations to negotiate this delay and the relevant regulatory authorities have
not offered any such delay." Please provide all communications between ldaho Power
and the Environmental Protection Agency, PacifiCorp, or the state of Wyoming
regarding such negotiations.
RESPONSE TO REQUEST NO. 3: The above reference to the "Coa! Study,
Page 4" points to the description of the Compliance Timing Alternatives that were
analyzed in the Coal Study. These alternatives were strictly hypothetical and requested
by the Public Utility Commission of Oregon Staff. As such, there were no
communications between ldaho Power and the Environmental Protection Agency
('EPA"), PacifiCorp, or the state of Wyoming regarding the delay of installation of
environmental controls on any unit in exchange for shutting that unit down.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
' ln these discovery Requests, "Coal Study" refers to the 30 page un-redacted document filed as
part of the Company's IRP update in Case No. IPC-E-11-11, not to confidential Exhibit No 5
accompanying the testimony of Witness Harvey.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 4
REQUEST NO. 4: Page 4 of the Coal Study indicates that all four Jim Bridger
units will require emission controls for mercury under the MATS rule. Please explain
the basis for the decision not to include such controls in this CPCN Application or, in the
alternative, how the proposed SCR additions in this application will satisfy MATS
compliance.
RESPONSE TO REQUEST NO. 4: The SCR additions will not satisfy the
requirements of the MATS rule. The costs for mercury controls are not of the same
dollar magnitude as that of the SCR additions. Idaho Power determined it will seek to
recover these costs as part of the norma! incremental capital investment and operations
and maintenance expense determination in a general rate case proceeding.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 5
REQUEST NO. 5: The Oregon Public Utilities [src/ Commission (OPUC), in its
acknowledgment order in Case 12-177 (ldaho Power's 2011 IRP), states that, "We
acknowledge Staff's proposed Action ltem 11, but not another IRP provision relating to
new investments in coal plants until ldaho Power completes a study of its coal
investment compliance costs and other parties have had the opportunity to comment on
the study. That order also required that ldaho Power's coal plant evaluation "will
investigate whether there is flexibility in the emerging environmental regulatons [sic/that
would allow the company to avoide [sic] early compliance costs by offereing [sic] to shut
down individual units prior to the end of their useful lives." Please explain how ldaho
Power fulfilled this order's requirement regarding a thorough analysis of its coal
investment compliance costs, such as specific costs of compliance with MATS, National
Ambient Air Quality Standards (NAAQS), New Source Performance Standards (NSPS)
or other rules, how such information was provided to ldaho Power customers and
regulators, and how ldaho Power provided other parties an opportunity to comment on
the study.
RESPONSE TO REQUEST NO. 5: To determine the economic viability of
installing the Jim Bridger plant SCRs, ldaho Power prepared the Coal Unit
Environmental lnvestment Analysis ("Coal Study"), which is included in two parts as
confidential Exhibit No. 5 (SAIC's static forecast unit generation analysis) and Exhibit
No. 6 (ldaho Power's dynamic total portfolio analysis) to the Direct Testimony of Tom
Harvey in this case. The Coal Study thoroughly analyzed ldaho Power's coal
investment compliance costs for all four units at the Jim Bridger plant and the two units
at the North Valmy plant, such as specific costs of compliance with MATS, NAAQS,
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 6
NSPS, or other rules. ldaho Power's Coal Study was filed with both the OPUC and the
ldaho Public Utilities Commission ("IPUC") on February 14, 2013, as an attachment to
the 2011 Integrated Resource Plan ("lRP') Update. While part of ldaho Power's Coal
Study is confidentia!, the public portion of the document is available to regulators and
customers through the ldaho Power, IPUC, and OPUG websites.
The 2011 IRP Update and the Coal Study were filed at the request of the OPUC
and were part of an informational filing for the IPUC; no public comment period was
established. The Coal Study was also filed as part of Case No. IPC-E-13-16.
lntervenors and the IPUC Staff will have the opportunity for discovery requests and the
opportunity to submit testimony as part of Case No. IPC-E-13-16.
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 7
REQUEST NO. 6: Please provide all communications between ldaho Power and
any state or federal regulatory agencies that support ldaho Power's assertion that
"ldaho Power analyzed avoiding the installation of required or reasonably anticipated
emission controls by delaying the compliance requirement by five years in exchange for
shutting the unit down at the end of the five year period".
RESPONSE TO REQUEST NO. 6: The Jim Bridger power plant is a reliable,
low-cost coal resource and has the lowest dispatch cost of ldaho Power's entire thermal
generation fleet. Based on the importance of the Jim Bridger power plant to the
resource portfolio of PacifiCorp and ldaho Power, ldaho Power analyzed, but did not
discuss with any state or federal agencies, the possibility of avoiding the installation of
required emission controls at Jim Bridger by delaying the compliance requirements in
exchange for shutting down the units.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY. S
REQUEST NO. 7: Please explain when ldaho Power decided to seek a CPCN
from the IPUC and provide all internal communications regarding the decision to seek a
CPCN.
RESPONSE TO REQUEST NO. 7: An exact date of when the Company
decided to seek a CPCN for the investment in SCR equipment at Jim Bridger Unit 3 and
Unit 4 is unknown; however, as stated in the Direct Testimony of Lisa A. Grow, pp. 15-
19, it was based upon a number of issues and events in recent years, including the
magnitude of the investment, the uncertainty surrounding coal-fired generation in
today's political and social environment, and the amount of interest expressed by
stakeholders. Through internal discussions and meetings with senior managers and
officers of the Company in the first half of May 2013, it was determined that the
appropriate regulatory strategy would be to request a CPCN, which would initiate a
public process to provide the Company, IPUC, and interested parties a regulatory forum
to fully vet these contested issues. ldaho Powe/s Chief Executive Office, LaMont
Keen, announced the Company's intent to voluntarily file for regulatory approval of the
investments at IDACORP's annual meeting on May 16,2013. As the decision to seek a
CPCN was based on oral discussions, no documented communications exist.
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY.9
REQUEST NO. 8: ls it ldaho Powe/s opinion that ldaho Power will be required
to comply with the federal Mercury and Air Toxics Standards (MATS) in 2015 at the
Bridger units? lf so, please state the basis of said opinion.
RESPONSE TO REQUEST NO. 8: Yes, al! four units at the Jim Bridger power
plant are required to comply with the MATS rule. The EPA final MATS rule took effect
on April 12, 2012. MATS set both national emission standards for hazardous air
pollutants from coal- and oil-fired electric utility steam generating units and standards of
performance for fossil-fuel fired electric utility steam generating units. The MATS rule
also established a three-year compliance period to meet the standards set by the EPA.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 1O
REQUEST NO. 9: In ldaho Powe/s opinion, what is the estimated cost of MATS
compliance at the Bridger units? Please state the basis of said opinion.
RESPONSE TO REQUEST NO. 9: For the estimated costs of MATS
compliance at the Jim Bridger power plant, please refer to the Company's response to
Snake River Alliance's Request No. 13.
The capital estimates used in the Coal Study provided in the Company's
Response to Snake River Alliance's Request No. 13 were based in part upon a high-
level estimate from Sargent & Lundy with the assumption that the plant was going to
use activated carbon, calcium bromide ("CaB/'), and potentially a scrubber re-emission
chemical. After testing was completed in 2011, the estimates were refined to include
the assumption that the plant would only use CaBr and the scrubber re-emission
chemical. These refined numbers were derived in large part from budgetary quotes
from chemical suppliers as well as PacifiCorp corporate engineering's estimate for
project management.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 11
REQUEST NO. 10: Please provide all internal documents which analyze or
discuss how potential future carbon dioxide control regulations would impact ldaho
Power's ownership of any of the Jim Bridger coal units.
RESPONSE TO REQUEST NO. 10: ldaho Power objects to this Request as
being overly broad and unduly burdensome because it seeks to obtain "all" interna!
documents without limit as to time which analyze or discuss potential future carbon
dioxide control regulations. Subject to and without waiving the foregoing objection, the
Company's analysis and discussion regarding how potentia! future carbon dioxide
control regulations would impact ldaho Power's ownership of any of the Jim Bridger
units is contained within the confidential SAIC report (Harvey, Dl Testimony, Exhibit No.
5), the Coal Study (Harvey, Dl Testimony, Exhibit No. 6), and the 2013 IRP (Application,
Attachment 4). With regard to the impact on the ownership of any of the Jim Bridger
units, the 2013 lRP, the Company's resource plan forthe 20-year planning period 2013
through 2032 states on page 8:
The preferred resource portfolio includes continued
operations at the Jim Bridger and North Valmy coal facilities.
ldaho Power intends to operate its facilities, including the
coal-fired generation plants, in full compliance with
environmental regulations.
The response to this Request is sponsored by Michae! J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 12
REQUEST NO. 11: Please provide a copy of the Limited Notice to Proceed
referenced at Pages 14 and 15 of Witness Harvey's direct testimony.
RESPONSE TO REQUEST NO. 11: ldaho Power will make available a copy of
the confidential and commercially sensitive Limited Notice to Proceed ("LNTP')
referenced at pages 14 and 15 of the Direct Testimony of Tom Harvey at its corporate
headquarters in Boise, ldaho, to those parties that have signed the Protective
Agreement in this matter. Please contact Doug Jones at 388-2615 or Camilla Victoria
at 388-5821 to view the materials.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 13
REQUEST NO. 12: Please provide all internal documents, including
communications with PacifiCorp, that led to the decision to enter into the LNTP,
including any analysis of potential ratepayer exposure due to the costs resulting from
the LNTP.
RESPONSE TO REQUEST NO. 12: ldaho Power will make available a file
containing confidential internal documents, including communications with PacifiCorp,
that led to the decision to enter into the LNTP at its corporate headquarters in Boise,
ldaho, to those parties that have signed the Protective Agreement in this matter. Please
contact Doug Jones at 388-2615 or Camilla Victoria at 388-5821 to view the materials.
As stated on page 16, lines 3-15 of the Direct Testimony of Michae! J.
Youngblood, the Company estimated the revenue impact of the proposed additions to
the Company's rate base by performing a high-level jurisdictional revenue requirement
analysis. ln addition, please see ldaho Powe/s Response to Staffs Production
Request No. 11.
The response to this Request is sponsored by Michae! J. Youngblood, Manager
of Regulatory Projects, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REOUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 14
REQUEST NO. 13: Witness Harvey's direct testimony at Page 24 states:
"Based on the Company's evaluation of the emerging regulations, the Company's Jim
Bridger Plant will require additional investment in environmental control technology to
comply with the Mercury and Air Toxic Standards (MATS) regulations with a projected
completion date of 2015. The anticipated investments related to the MATS regulations
were included in the coal study and were determined to be cost effective. However,
those specific investments are not within the scope of this CPCN request." Explain the
basis for the Company's decision not to include these specific investments within the
scope of Case No. !PC-E-13-16. Please provide the Company's best estimate of the
anticipated cost of those investments.
RESPONSE TO REQUEST NO. 13: The costs for the additional investment in
environmental control technology to comply with the MATS regulations are not of the
same dollar magnitude as that of the SCR additions. ldaho Power determined it will
likely seek to recover these costs as part of the normal incremental capital investment
and operations and maintenance expense determination in a genera! rate case
proceeding. The projected capita! costs of these mercury control systems for each of
the Jim Bridger Units 1,2,3, and 4 are contained on pages 18 and 19 of confidential
Exhibit No. 5, SAIC report, to the Direct Testimony of Tom Harvey.
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 15
REQUEST NO. 14: According to Witness Grow's testimony at Page 9, "The Jim
Bridger Plant is also the Company's lowest cost thermal resource from an installed cost
of nameplate capacity perspective." Based on actual 2012 financial information, the
total cost of nameplate capacity [excluding fuel and per-unit energy taxes] for the Jim
Bridger Plant was $8.24lkilowatt month. For comparison purposes, the average 2012
installed costs of nameplate capacity for the remalning baseload thermal fleet was
$13.3 I kW month. Please state the basis for these assertions of fact.
RESPONSE TO REQUEST NO. 14: The confidential schedule provided on the
confidential CD contains the factual basis for Ms. Grow's assertion that in 2012 the Jim
Bridger power plant was the Company's lowest cost thermal resource from an installed
nameplate capacity perspective. The confidential CD will be provided to those parties
that have signed the Protective Agreement in this matter.
The response to this Request is sponsored by Lisa Grow, Senior Vice President
of Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 16
REQUEST NO. 15: Please refer to Witness Grow testimony, Page 7, lines 7-8.
Please state the basis of this assertion of fact or opinion.
RESPONSE TO REQUEST NO. 15: The statement "ldaho Power's resource
portfolio is among the most diverse and therefore secure in the nation" was made based
upon Ms. Grow's extensive utility experience and knowledge of the industry. The
importance of fuel diversity cannot be overstated given its implications for assuring
economic and energy security. Too great a reliance upon any one energy source
(especially those with a history of price volatility) creates a significant risk of exposure to
electricity price spikes and supply disruptions.
The response to this Request is sponsored by Lisa Grow, Senior Vice President
of Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY. 17
REQUEST NO. 16: Please refer to Witness Grow testimony, Page 8, lines 8-10.
Please state the basis of this assertion of fact or opinion.
RESPONSE TO REQUEST NO. 16: This statement comes from the fact that the
Jim Bridger plant provides ldaho Powe/s customers with low-cost energy not only when
the system is peaking but low-cost energy throughout the year as a baseload resource.
!n fact, over the recent 12-month period from August 2012 through July 2013, economic
dispatch practices resulted in power production at the Jim Bridger power plant that
totaled 4,994,841 million megawatt-hours, or 570 average megawatts of energy.
The response to this Request is sponsored by Lisa Grow, Senior Vice President
of Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY. 18
REQUEST NO. 17: Please refer to Witness Grow testimony and the answer
beginning on line 17.
a.) Please identify by name and title the ldaho Power Company
representative primarily responsible for discussions with PacificCorp [sic/ regarding
implementation of Regional Haze Rules.
b.) Please identify by name and title the PacifiCorp representative primarily
responsible for discussions with ldaho Power Company regarding implementation of
Regional Haze Rules.
c.) Please describe the process by which decisions or understandings
resulting from discussions between ldaho Power Company regarding implementation of
Regional Haze Rules are memorialized or reduced to writing.
d.) Please identify by name and job title the ldaho Power Company official
having custody or control of any documents described in your answer to the preceding
sub-part.
e.) Please identify by name and job title the persons referenced at Page 13,
line 21.
f.) Please state the date of the meeting referenced at Page 13, Line 21.
RESPONSE TO REQUEST NO. 17:
a. The ldaho Power representative responsible for discussions with
PacifiCorp regarding Regional Haze Rules is Tom Harvey, Joint Projects Manager.
b. The main PacifiCorp contact for information on the SCR project has been
Chad Teply, Vice President of Resource Development and Construction for PacifiCorp
Energy.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 19
c. ldaho Power does
understandings resulting from
memorialized or reduced to writing.
not have a written policy or guideline by which
discussions of the Regiona! Haze Rules are
d. Please see the Company's Response to subpart c above.
e. The meeting referenced on page 13, line 21 of Ms. Grow's testimony that
took place at the Jim Bridger power plant was attended by Darrel Anderson (President,
ldaho Power), Lisa Grow (Senior Vice President of Power Supply, ldaho Power), Tom
Harvey (Joint Projects Manager, ldaho Power), John Carstensen (Engineering Project
Leader, ldaho Power), Mike Dunn (President, PacifiCorp Energy), Dana Ralston (Vice
President of Thermal Generation, PacifiCorp Energy), and Chad Teply (Vice President
of Resource Development and Construction, PacifiCorp Energy).
f. The meeting referenced on page 13, line 21 of Ms. Grow's testimony was
held on April 15,2013.
The response to this Request is sponsored by Lisa Grow, Senior Vice President
of Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 20
REQUEST NO. 18: According [src/ Attachments 2 and 3 to the Application,
PacifiCorp filed its applications for approval of SCR investments with the Wyoming and
Utah regulatory commissions on August 7, 2012 and August 10, 2012, respectively.
Please explain the basis of the Company's decision not to file its Application with the
IPUC until June 28,2013.
RESPONSE TO REQUEST NO. 18: The Company voluntarily filed its
Application with the IPUC in this case, Case No. IPC-E-13-16, concurrently with the
Company filing its 2013lRP, Case No. IPC-E-13-15. The Company filed its Application
for a CPCN on the same day (June 28,2013) as the 2013 IRP because the IRP was a
critical document filed as an exhibit in support of the CPCN.
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 21
REQUEST NO. 19: Please identify by name, job title, address, phone number
and email address the employee of SIAC [src] who would be able to answer detailed
questions regarding Exhibit No. 5.
RESPONSE TO REQUEST NO. 19: The person able to answer detailed
questions regarding Exhibit No. 5 is SAIC's attorney, John S. Gardner, 9400 North
Broadway, Suite 300, Oklahoma City, Oklahoma 73114. Mr. Gardne/s e-mai! is
[e-mail] and his telephone number is [phone].
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 22
REQUEST NO. 20: Did ldaho Power enter into an engagement letter, or similar
document with SIAC [src] with respect to the preparation of Exhibit No. 5? lf so, please
provide a copy.
RESPONSE TO REQUEST NO. 20: Yes, Idaho Power entered into a
Professional Services Agreement and two Statements of Work with SAIC. These
documents are confidential and are included on the confidential CD. The confidential
CD wi!! be provided to those parties that have executed the Protective Agreement in this
matter.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 23
REQUEST NO. 21: Prior to February 8, 2013 did SIAC [src] submit to ldaho
Power any draft versions of Exhibit No. 5? !f so, please provide copies.
RESPONSE TO REQUEST NO. 21: SAIC did submit drafts of its report for
ldaho Powe/s review. The confidential files on the CD represent drafts of the SAIC
report provided to ldaho Power for review. The confidentia! CD will be provided to those
parties that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 24
REQUEST NO. 22: lf SIAC [stc] did submit draft versions of Exhibit No. 5, did
ldaho Power make any comment to SIAC [src] regarding draft versions?
a. lf comments to SIAC [src] were in writing, please provide copies;
b. lf comments to SIAC [src] were oral, please state:
1. The name and job title of the ldaho Power employee(s) providing
such comment;
2. The name and job title of the SIAC [sic] employee(s) receiving such
comment;
3. The date(s) of oral comments;
4. The substance of oral comments;
RESPONSE TO REQUEST NO. 22: ldaho Power personnel provided feedback
to SAIC on the drafts provided by SAIC to ldaho Power.
a. Comments were primarily oral. Written comments consisted of e-mails
sent to SAIC with suggestions or questions regarding the draft report. The confidential
e-mails are contained on the confidentia! CD. The confidential CD will be provided to
those parties that have signed the Protective Agreement in this matter.
b. The dates of the oral comments occurred during the period beginning in
August of 2012 and ending in February of 2013 via phone conversations between ldaho
Power and SAIC personnel. The primary point of contact for ldaho Power is Rick
Haener, Fuels Management Coordinator, and for SAIC Charles Janecek, Senior
Consultant. The discussions were primarily concerned with layout and wording. No
logs or formal documentation exists of these discussions.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 25
The response to this Request is sponsored by Tom Harvey, Joint Projects
Manager, ldaho Power Company.
DATED at Boise, tdaho, this 3d day of September 2013.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 26
Attomey for Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3'd day of September 20131 served a true and
conect copy of IDAHO POWER COMPANY'S RESPONSES TO THE FIRST
DISCOVERY REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Gommission Staff
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Email [e-mail]
lndustrial Customers of ldaho Power Hand Delivered
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 Gonseruation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Snake River Alliance
Dean J. Miller
Chas. F. McDevitt
Celeste K. Miller
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, ldaho 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
[e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
chas@mcdevitt-m i ller. com
ck@ mcdevitt-m i I ler. co m
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REQUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 27
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Christa Bearry, Legal
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST DISCOVERY
REOUESTS OF SNAKE RIVER ALLIANCE TO IDAHO POWER COMPANY - 28