20131016IPC 1-8 to Snake River.pdf

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JENNIFER ]tI. REINHARDT.TESSMER
Corporate Gounsel
[e-mail]
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 Necessity for Jim Bridger Units 3 and
4 - Idaho Power Company's Finst Production Request to the Snake River
AIIiance
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 Snake River Alliance.
JMR:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
JENNIFER M. REINHARDT-TESSMER (lSB No. 7432)
ldaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd stro m @ id a hopower. co m
irei n ha rdt@ idaho power. com
Attorneys for Idaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE INVESTMENT
IN SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JlM BRIDGER UNITS 3
AND 4.
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CASE NO. |PC-E-13-16
IDAHO POWER COMPANY'S
FIRST PRODUCTION REQUEST
TO THE SNAKE RIVER ALLIANCE
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compafly"), by and
through its attorneys, and hereby requests that the Snake River Alliance ("Snake River")
answer the following requests and provide the following information and documents in
accordance with the ldaho 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 THE SNAKE RIVER ALLIANCE - 1
These requests are to be deemed continuing in nature and Snake River 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 Snake River base its position or any opinions
expressed in this case on a study of energy efficiency potential within ldaho Power's
service tenitory? lf so, please provide a copy of the study and any supporting
workpapers.
REQUEST NO. 2: Does Snake River base its position or any opinions
expressed in this case on a study or analysis that evaluates dispatchable, baseload
alternatives to Jim Bridger power plant generation? lf so, please provide a copy of the
study or analysis and any supporting workpapers.
REQUEST NO. 3: Does Snake River base its position or any opinions
expressed in this case on a study or analysis of resource altematives to the Jim Bridger
power plant that accounts for carbon? lf so, please provide a copy of the study or
analysis and any supporting workpapers.
REQUEST NO. 4: In the absence of a carbon regulatory regime, what carbon
assumptions should be used to compare the Jim Bridger power plant to other
generation resources?
REQUEST NO. 5: On page 3 of his testimony, Mr. Miller indicates that he has
prepared multiple reports for the Snake River discussing coal. Please provide a copy of
each report.
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE SNAKE RIVER ALLIANCE - 2
REQUEST NO. 6: On page 14 of his testimony, Mr. Miller indicates that the cost
of compliance for additional environmental regulations would be far greater than the
$130 million in costs attributed to the selective catalytic reduction investment. Please
provide a mpy of the analysis that defines the regulations and associated costs that are
included in his estimate.
REQUEST NO. 7: On page 8, lines 16-18 of his testimony, Mr. Miller mentions
COz controls that should be considered in the not-too-distant future. Please describe
the COz controls that should be considered in the not-too-distant future.
REQUEST NO. 8: On page 15, lines 16-18 of his testimony, Mr. Miller states
that a new carbon regulatory regime would dramatically alter ldaho Power's resource
stack. Please provide the basis or analysis for this statement.
DATED at Boise, ldaho, this 16th day of Octobe r 2013.
: REINHARDT-TESSMER
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE SNAKE RIVER ALLIANCE - 3
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
THE SNAKE RIVER ALLIANCE 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
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial 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 A!!iance
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
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IDAHO POWER COMPANY'S FIRST PRODUCTION REOUEST TO THE SNAKE RIVER ALLIANCE.4
Ken Miller, Clean Energy Program Director
Snake RiverAlliance
P.O. Box 1731
Boise, ldaho 83701
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_FAXX Email [e-mail]
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE SNAKE RIVER ALLIANCE - 5