20131101Staff to Snake River 1-6.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BARNO.6618
Street Address for Express Mail:
472W WASHINGTON
BOISE ID 83702-5918
Attorney for the Commission Staff
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 JIM BRIDGER UNITS 3
AND 4.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E.I3.16
COMMISSION STAFF'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
SNAKE RIVER ALLIANCE
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, responds as follows to Snake River Alliance's First
Production Request to Commission Staff.
REQUEST NO. l: Please refer to testimony of Witness Louis, Pg. 9, L. 5.
Please state with specificity each of the potential environmental and future environmental
compliance costs evaluated by Staff and Staff s estimate of the present dollar cost of each
compliance measure.
STAFF RESPONSE NO. 1: See Idaho Power's Application Exhibit No. 5, pp. l8-21
for compliance costs evaluated by Staff. Staff did not develop its own estimates.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF SNAKE RIVER
ALLIANCE 1 NOVEMBER 1,2013
REQUEST NO 2: Please refer to testimony of Witness Louis, Pg. 16, L. 6.
Please state with specificity each regulation about which there is considerable uncertainty.
STAFF RESPONSE NO.2: Future existing-source greenhouse gas regulations have
considerable uncertainty because proposed rules are not expected until June I ,2014 and final
rules are not expected until June l, 2015.
REQUEST NO 3: Please refer to testimony of Witness Louis, Pg. 10, L.22.
Please identiff all efforts of which you are aware whereby either PacifiCorp or Idaho Power
attempted to negotiate a delay in RegionalHaze compliance.
STAFF RESPONSE NO.3: I am not aware of any negotiations by Idaho Power. I am
aware of negotiations between PacifiCorp and the Wyoming Department of Environmental
Quality through discussion contained in Surrebuttal Testimony of Cathy S. Woollums and
Supplemental Exhibits (Utah Docket No. 12-035-92; RMP_(CSW-5SR); RMP_(CSW-4SR).
REOUEST NO 4: Please refer to testimony of Witness Louis, Pg. 11, L. 16.
Please identifu the specific provisions of contractual obligations between the companies that
make it very difficult for Idaho Power to pursue a different approach.
STAFF RESPONSE NO. 4: Please see Idaho Power's response to Staff Production
Request No. 9.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF SNAKE RIVER
ALLIANCE NOVEMBER 1,2013
REQUEST NO 5: Please refer to testimony of Witness Louis, Pg. 12,L. 4.
Please:
a. Provide a definition of 'ostranded assets" as used therein.
b. Provide Staff s assessment of the degree of certainty that IPCo would face
financial loss associated with "stranded assets" as you have defined it.
STAFF RESPONSE NO. 5:
a. Stranded assets are those investments which have already been made but which, at
some time prior to the end of their economic life (as assumed at the investment
decision point), are no longer able to earn an economic return, as a result of changes
in the market and regulatory environment. (Staffs definition is derived from the
lnternational Energy Agency's definition of stranded assets.)
b. Staff has not assessed the degree of certainty that losses would be incurred.
REQUEST NO 6: Please refer to testimony of Witness Louis to Pg. 18 L. l.
Please:
a. Provide a copy of the "tipping point" analysis provided by the Company.
b. Assume that instead of attempting to assign a dollar cost to CO2 emissions,
future federal regulations impose limitations on the level of GHG emissions
from existing coal-fired plants. Please state whether Staff has analyzedthe
cost of such form of regulation, either generically or in connection with Jim
Bridger specifically, and if so the results of such analysis.
STAFF RESPONSE NO. 6:
a. Please see Idaho Power's response to Staff Production Request No. 43.
b. Staff has not speculated on the cost or performed the suggested analysis of such form
of regulation.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF SNAKE RIVERALLIANCE 3 NOVEMBER I,2OI3
DATED at Boise,Idaho, this P day of October 2013.
Technical Staff: Mike Louis
i:utrisclipccl3. 16 Staff lr Rcsponsc to Snake Rivcr Allirncc.doo
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF SNAKE RTVER
ALLIANCE
Deputy Attorney General
NOVEMBER I,2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IST DAY oF NoVEMBER 2013,
SERVED THE FOREGOING RESPONSE OF THE COMMISSION STAFF TO THE
FIRST PRODUCTION REQUEST OF THE SNAKE RIVER ALLIANCE, N CASE NO.
IPC-E-I3-16, 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
BOrSE ID 83707-0070
E-MAIL: [e-mail]
i reinhardt@.idahopower. com
dockets@idahopower. com
C Bearry@,idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS
5I5 N 27TH ST
BOISE ID 836I6
E-MAIL: [e-mail]
gre [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 8370I
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : dreadin [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK
BOTSE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE