20140424ICIP 7-15 to IPC.pdf

Peter J. Richardson ISB # 3195 ,
Gregory M. Adams ISB # 7454
RICHARDSON & O'LEARY PLLC :':t'::r' ,i.j? 'ir, i.';i I': Ig
515 N. 27ft Street
Boise,Idatro 83702 .l
Telephone: [phone] :
Fax: [phone]
Deter@richardson*dol.*. "o*gre g@richardsonando le ar.v. com
Attomeys for the Industrial Customers of Idatro Power
BEX'ORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) cAsE NO. IPC-E-14-05
APPLICATTON OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) SECOND PRODUCTION REQUEST
IMPLEMENT POWER COST ) OF THE TNDUSTRIAL CUSTOMERS
ADruSTMENT (*pCA") RATES FOR ) OF IDAHO POWER
ELECTRIC SERVICE FROM JIINE I, )
2014 THROUGH MAY 3I,2OI5
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idatro Power ("[ClP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho 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: [phone] I 1 ; [e-mail]
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.
Requests Nos. 7 - 12 reference Exhibit No. 2 contained in Mr. Tatum's direct prefiled
testimony.
REOUEST FOR PRODUCTION NO. 7
On page I is a table entitled "Surplus Sales." Please provide a table listing the MWh
figures that form the basis of the graph.
REOUEST FOR PRODUCTION NO. 8
For each month represented on the graph please identifu the forecasted and actual
monthly generation for the Langley Gulch generating station.
REOUEST FOR PRODUCTION NO. 9
What was the forecast and actual variable cost of operating Langley Gulch during each
month represented on the graph.
REOUEST FOR PRODUCTION NO. IO
The table on page 2 shows that actual hydro generation was less than forecast in the
months of June, July and August. The graph on page 1 shows that actual surplus sales were
higher than forecast in June, July and August. Since, according to the exhibit, "surplus sales
were impacted primarily by lower hydro generation", please explain why actual surplus sales
were higher than forecast during June, July and August when the actual hydro generation was
lower than forecast.
REOUEST FOR PRODUCTION NO. I I
Reference the table on page 2 labeled "Brownlee Inflow." Were the forecast values the
values that would be forecast based upon present conditions and normal future precipitation, i.e.,
SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF TDAHO
POWER
rPC-E-14-05
PAGE 2
was the April 2013 value primarily based upon March 2013 snow pack conditions, while the
December 2013 value was based more upon normal precipitation for that timeframe as opposed
to March 2013. Please explain.
REOUEST FOR PRODUCTION NO. 12
On page 2 it states that Langley Gulcho.was not dispatched in October 2013 due to
required maintenance." 'Was this planned maintenance? What is the number of operating hours
necessary to trigger a planned maintenance shut down? Please describe the nature of the
maintenance and why it took an entire month to complete. If the maintenance was planned,
please explain why the forecast included the plant's "full dispatch" of production in the month of
October.
REOUEST FOR PRODUCTION NO. 13
Does lda]ro Power prepare a new l2-month hydro generation each month, or on any other regular
periodic basis? Please provide a copy of all of the l2-month hydro forecasts (monthly or
otherwise) that were prepared from March 2013 through the most recent forecast available.
REOUEST FOR PRODUCTION NO. 14
Please provide all documents and spreadsheets (in workable electronic formats) used in
the forecast of the $111,145,245 for the PCA 2013-2014 as shown in Table l, page 6 of Tim
Tatum's testimony. Please describe all assumptions use in the forecast and provide a copy of the
Operation Plan used for the forecast.
REOUEST FOR PRODUCTION NO. 15
According to the testimony of Scott Wright, page 10, the proceeds of the sale of REC's
and SOz are included in the Company's deferral expense account. Please provide a list of the
SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-14-05
PAGE 3
number of RECs sold, who they were sold to and at what price. Also please provide the amount
of SOu sold. who it was sold to and at what price.
DATED this 24m day of April2}l4:
Peter J. Richardson
Industrial Customers of Idatro Power
CERTIFICATE OF SERVICE
I hereby certify that on 24h day of April z}l4,copies of the foregoing Second Production
Request of the Industrial Customers of ldatro Power in Docket IPC-E-14-05 were hand delivered
to:
LisaNordstrom
Idaho Power Company
l22l West ldaho
Boise,Idaho 83702
Jean Jewel
Timothy E. Tatum Secretary
Idaho Power Company ldaho Public Utilities Com'n
1221 West ldatro 472West ldatro
Boise,Idatro 83702 Boise,Idaho 83702
SECOND PRODUCTTON REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-14-05
PAGE 4