20140425ICIP 16-18 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON & O'LEARY PLLC
515 N. 27ft Street
Boise,Idaho 83702
Telephone : [phone]
Fax: [phone]
Peter@richardsonandolear,. com
sre g@richardsonandoleary. com
Attorneys for the Industrial Customers of Idatro Power
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
IMPLEMENT POWER COST
ADJUSTMENT (*PCA") RATES FOR
ELECTRIC SERVICE FROM JUNE 1,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
) cAsE NO. rPC-E-14-0s
)) THIRD PRODUCTION REQUEST OF
) THE INDUSTRIAL CUSTOMERS OF
) IDAHO POWER
)
2OI4 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 ldaho Power ("IC[P") by and through their
attorney of record, Peter J. Richardson, hereby requests that ldatro 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, Idatro 83703, Tel:
(208) 3 42- 1700; Fax : [phone] ; [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 wifiress 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. 16
Exhibit 2 to Mr. Tatum's prefiled direct testimony states, "While surplus sales for the two
months were impacted by the lower than forecast production from Langley Gulch, the impact on
overall PCA was minimal because of a corresponding decrease in Langley Gulch fuel expense."
Please quantifu the revenue impact on the overall PCA for the lower than forecast production
from Langley Gulch for the month of October 2013.
REOUEST FOR PRODUCTION NO. 17
Exhibit No. 5, page 1, on line 5 to Mr. Wright's prefiled direct testimony shows actual
MWh tdafio Jurisdictional Sales for the 2013-2014 PCA year. As indicated in the footnote to that
line, April and May 2013 are normalized MWh sales. In OrderNo. 32821 at page I I the Idatro
Public Utilities Commission ruled that,
Based on our review of the record, we find it reasonable for the Company to apply actual
Idaho jurisdictional energy sales to the forecast rate in the calculation of the true-up
component of the PCA mechanism. We direct the Company to implement this change
with the new PCA rates on June 1, 2013.
What were the actual Idaho jurisdictional MWh sales for April and May 2013?
REOUEST FOR PRODUCTION NO. 18
Does the Company believe that the true up component of the 2013 -2014 PCA rates is based on
actual sales data? Even though a literal reading of the Commission's Order seems to only direct
a change from normalized to actual sales beginning in the month of June 2013 (rather than
THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-14-05
PAGE 2
April), does the Company believe it would be consistent with the intent of the Commission's
Order to use actual data for all true up calculations? Please explain.
DATED this 25m day of April2}l4:
CERTIFICATE OF SERVICE
I hereby certify that on 25ft day of April z}l4,copies of the foregoing Third Production
Request of the Industrial Customers of Idatro Power in Docket IPC-E-14-05 were hand delivered
to:
Jean Jewel
LisaNordstrom Timothy E. Tatum Secretary
Idaho Power Company ldaho Power Company Idaho Public Utilities Com'n
1221 West Idatro 1221 West ldatro 472West ldaho
Boise,Idatro 83702 Boise,Idaho 83702 Boise, tdatro 83702
and sent via electronic mail to:
Ben Otto
Idaho Conservation League
botto @ idahoconservation. org
Eric Olsen
IIPA
[e-mail]
Tony Yankel
IIPA
[e-mail]
THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-14-0s
PAGE 3
Industrial Customers of Idatro Power