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Home My WebLink About20131016IPC 1-10 to ICL.pdf3Iffi*. An IDACORP ComDanv JENNIFER M. REINHARDT.TESSMER Gorporate Counsel irei n hardt@idahopower.com October 16,2013 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 Firct Production Request to the ldaho Conservation League Dear Ms. Jewell: Enclosed for filing in the above matter are an original and three (3) copies of ldaho Power Company's First Production Request to the ldaho Conservation League. JMR:cb Enclosures 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) :i:.1:I : . [.] i,: !.1, Idaho Power Company ':'1221Wesl ldaho Street (83702) P.O. Box 70 Boise, ldaho 837OT Telephone: (208) 388-5825 Facsimile: (208) 388-6936 I nordstrom@ ida hopower. com i rei n ha rdt@ id a ho powe r. co m Attorneys for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION !N THE MATTER OF |DAHO POWER )coMpANy's AppLtcATloN FoR A ) CASE NO. !pC-E-13-16 CERTTFTCATE OF PUBLTC CONVENTENCE ) AND NECESSTTY FOR THE INVESTMENT ) TDAHO POWER COMPANY'S rN SELECT|VE CATALYTIC REDUCTION ) FIRST PRODUCTTON REQUEST CoNTROLS ON JtM BRTDGER UNITS 3 ) TO IDAHO CONSERVATTON AND 4.) LEAGUE ) COMES NOW, Idaho Power Company ("ldaho Powe/' or "Compony"), by and through its attorneys, and hereby requests that ldaho Conservation League ("lCL") answer the following request and provide the following information and documents in accordance with the Idaho Public Utilities Commission's ("Commission") Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. To allow the Company to utilize these responses in preparing its rebuttal testimony, it is necessary that the responses to these requests be provided by October 30,2013. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO IDAHO CONSERVATION LEAGUE - 1 These requests are to be deemed continuing in nature and ICL is requested to provide, through supplementation, additional documents or information that is responsive to these requests that it, or any person acting on its behalf, may later come into possession or become aware of. REQUEST NO. 1: Does lCL base its position or any opinions expressed in this case on a study of energy efficiency potential within ldaho Powe/s service territory? lf so, please provide a copy of the study and any supporting workpapers. REQUEST NO. 2: Does ICL base its position or any opinions expressed in this case on a study that evaluates dispatchable, baseload alternatives to Jim Bridger generation? If so, please provide a copy and any supporting workpapers. REQUEST NO. 3: Please review Courtney White's direct testimony p. 4, Il. 1-3. Describe and quantify the resource options currently available that minimize costs and risks of meeting current and future customer needs. REQUEST NO. 4: PIease review Courtney White's direct testimony p. 7, ll. 6-11 and p. 9, l. 14. Describe and quantify the risks and costs of alternative generation resources to replace Jim Bridger units 3 and 4 by 2016. REQUEST NO. 5: Please review Courtney White's direct testimony p. 8, !!. 3-5. Describe how ldaho Powe/s current system is sub-optimized and the method ldaho Power should use to optimize it. REQUEST NO. 6: Please review Courtney White's direct testimony p. 4, ll. 6-13, p. 10, ll. 11-14. Describe and quantify a future ldaho Power electrical system without coal and with future disruptive forces. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO IDAHO CONSERVATION LEAGUE - 2 REQUEST NO. 7: Does lCL base its position or any opinions expressed in this case on a study or analysis of resource alternatives to the Jim Bridger plant that accounts for carbon? If so, please provide a copy and any supporting workpapers. REQUEST NO. 8: ln the absence of a carbon regulatory regime, what carbon assumptions should be used to compare the Jim Bridger plant to other generation resources? REQUEST NO. 9: On page 7, ll. 18-20 of Ms. White's testimony, she indicates that "incorporating a carbon adder into the quantitative analysis does not adequately characterize the nature and range of pollution contro! costs to which the ratepayer is exposed." Please identify and describe the nature and range of pollution control costs that ldaho Powefs carbon adder does not address. REQUEST NO. 10: Please provide Ms. White's experience in resource planning specific to utilities. DATED at Boise, ldaho, this 16th day of Octobe r 2013. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO IDAHO CONSERVATION LEAGUE - 3 HARDT.TESSMER CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 16th day of October 2013 I served a true and correct copy of IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO IDAHO CONSERVATION LEAGUE 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 47 2 W esl Washington (83702 ) P.O. Box 83720 Boise, ldaho 83720-007 4 lndustrial Gustomers 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 Idaho Conservation League 710 North Sixth Street Boise, ldaho 83702 Snake River Alliance Dean J. Miller McDEVITT & MILLER LLP 420 West Bannock Street (83702) P.O. Box 2564 Boise, ldaho 83701 IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO IDAHO CONSERVATION LEAGUE - 4 Hand Delivered U.S. Mail Overnight Mail FAXX Email kris.sasser@puc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAXX Email peter@richardsonadams.com qreq@richardsonadams.com Hand Delivered U.S. Mai! Overnight Mail FAX Emall dreading@mindsprinq.com Hand Delivered U.S. Mail Overnight Mai! FAX Email botto@idahoconservation.org Hand Delivered U.S. Mai! Overnight Mail FAXX Email ioe@mcd evitt-miller. com Ken Miller, Clean Eneey Program Director Snake RiverAlliance P.O. Box 1731 Boise, ldaho 83701 _Hand Delivered _U.S. Mail Ovemight Mail _FAXX Email kmiller@snakeriveralliance.oru IDAHO POWER COMPANYS FIRST PRODUCTION REQUEST TO IDAHO CONSERVATION LEAGUE. S