20140107ICIP 1-6 to IPC.pdf

Peter J. Richardson ISB # 3195 ,'1, '
RICHARDSON ADAMS, PLLC
515 N. 27tr Street ?:!! : l:1: -l t,i lii, t3
Boise,Idatro 83702
Telephone: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of ldaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE ) CASE NO. rpC-E-13-20
APPLICATTON OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) FIRST PRODUCTION REQUEST OF
ESTABLISH A NEW BASE LEVEL OF ) THE INDUSTIAL CUSTOMERS OF
NET POWER SUPPLY EXPENSE ) IDAHO POWER
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that ldaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the 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 one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at:6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: (208) 3 84- I 5 1 1 ; [e-mail]
l -FTRST PRODUCTTON REQUEST OF INDUSTRTAL CUSTOMERS OF rDAHO POWER- IPC-E-13-20
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REOUEST FOR PRODUCTION NO. 1:
The prefiled direct testimony (page 18) of Timothy Tatum states:
The Company proposes to use the same energy allocation basis that would exist under the
PCA to apportion the approximately $99.3 million base rate increase to each customer
class; that is, in proportion to each class's annual energy consumption. By using the
same energy allocation basis applied in next year's PCA frling, each customer class will
contribute exactly the same amount of revenue to offset NPSE that would exist under the
PCA collection.
A. Would the results be the same, e.g. identical contribution of revenue that would exist
under the PCA, if the $99.3 million were allocated under a full cost-of-service allocation?
B. If the answer to A is no, please indicate what portion of the $99.3 million each customer
class would be responsible for and the total percentage change for each class if the $99.3 were
allocated on a cost of service basis.
C. Please provide the full cost of service run, in electronic format, with the proposed S99.3
included.
REOUEST FOR PRODUCTION NO. 2:
The prefiled direct testimony (page 3) of Scott Wright states:
The Company and Commission have historically used the term "variable power supply
expenses" as the sum of fuel expenses . . . and purchased power expenses . . . not
including purchases from qualifring facilities . . ., minus surplus sales revenues . . . The
AURORA model is used to quantiff these components which cumulatively are referred
to as NPSE.
A. Please provide a list of all company resources that are included in the AURORA model
run used in this docket to find NPSE that are not included in the last Commission approved cost-
of-service model in Case No. IPC-E-11-08.
2 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER- IPC-E-13-20
B. Please provide the dollar amount of the rate base resource listed in A, above, that were
used in the AURORA runs in this docket to find NSPE.
C. For each resource listed in A and B above, please provide the original in service cost and
the amount of depreciation associated with each discreet resource.
REOUEST FOR PRODUCTION NO. 3:
The prefiled direct testimony (pages 6 -7) of Scott Wright states:
For the 2013 Base Level NPSE, the Company segmented PURPA generation into two
categories, "PURPA Wind" and all other PURPA. PURPA Wind was modeled by
applying the2012 hourly actual historical PURPA Wind generation to shape to the
monthly forecasted generation amounts.
A. For the AURORA model runs used in this docket, how did the Company model the
Elkhorn Wind Project's hourly generation?
B. If the Elkhorn Wind Project's generation was modeled differently from "PURPA Wind"
please explain fully why and provide the basis for its different model.
REQUEST FOR PRODUCTION NO. 4:
The prefiled direct testimony Gage 9) of Scott Wright states:
For the 2010 Base Level NPSE, natural gas prices were assumed to be $5.79 per MMBtu
for Henry Hub and $5.50 per MMBtu for natural gas delivered to the Company's plants.
For the 2013 Base Level NPSE, they are forecasted to be $3.62 per MMBtu for Henry
Hub and $3.68 per MMBtu for natural gas delivered to the Company's plants.
A. Please explain why the 2010 natural gas price delivered to the Company's plants is less
expensive than the natural gas priced at the Henry Hub and why 2013 natural gas price delivered
to the Company's plants is more expensive than natural gas priced at the Henry Hub.
B. Please provide all workpapers used to derive the $3.62 per MMBtu Henry Hub price and
for the 53.68 price for gas delivered to the Company's plants along with an explanation of the
logic used in finding these NPSE Base Level prices.
3 -FIRST PRODUCTION REQUEST OF TNDUSTRIAL CUSTOMERS OF rDAHO POWER- IPC-E-13-20
REOUEST FOR PRODUCTION NO. 5:
The prefiled direct testimony Gage 9) of Scott Wright states:
The total coal expenses quantified in the 2010 Base Level NPSE were $167.2 million.
For the 2013 Base Level NPSE, total coal expenses are forecasted to be $108.5 million or
a decrease of $58.7 million.
Please provide a list of all of the thermal resources included in the 2010 and the 2013 Base Level
NPSE. For each listed resource provide the MWh produced and associated costs included in the
NPSE.
REOUEST FOR PRODUCTION NO. 6:
The prefiled direct testimony (page 12) of Scott Wright states:
Because actual20l3 conditions were reflective of an atypicalyear, the Company used
2012 acttal water lease expense to reflect a more realistic expectation for a normalized
level of FERC Account 536, Water for Power expense.
A. What metric does the Company use to measure typical and atypical water years?
B. Using the response in A, above, please indicate the level of the metric for2012 and 2013
along with the amount of the water lease expense for each year.
C. Pease describe what the Company considers average and median water conditions.
DATED this 7th day of January,2llL.
RICHARDSON ADAMS, PLLC
,, fdc,
Peter J. Richardson, ISB #3195
Attomeys THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
4 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER- IPC-E-13-20