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LISA D. NORDSTROM
Lead Counsel
lnordstrom@idahopower.com
May 13,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-05
2014-2015 Power Cost Adjustment - ldaho Power Company's Response to
the Second Production Request of the lndustrial Customers of ldaho Power
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Redacted Response to the Second Production Request of the lndustrial
Customers of ldaho Power ('lclP').
Also, enclosed in a separate envelope are an original and three (3) copies of ldaho
Power Company's Gonfidential Response to the Second Production Request of the
lndustrial Customers of ldaho Power and four (4) copies of a confidential disk containing
information responsive to lClP's Request for Production Nos. 13 and 15. Please handle
the confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
5K*-P@
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388-6936
I no rd strom@ ida hopower. co m
Attomey for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
COST ADJUSTMENT ('PCA") 3,q1Eg
FOR ELECTRIC SERVICE FROM JUNE 1,
2014, THROUGH MAY 31,2015, AND TO
UPDATE BASE RATES IN COMPLIANCE
WITH ORDER NO. 33OOO.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. |PC-E-14-05
IDAHO POWER COMPANY'S
REDACTED RESPONSE TO THE
SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compof,y"), and in
response to the Second Production Request of the lndustrial Customers of ldaho Power
dated April24,2014, herewith submits the following information:
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 7: On page 1 is a table entitled "Surplus
Sales." Please provide a table listing the MWh figures that form the basis of the graph.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The table below shows
the megawatt-hour ('MWh') figures that form the basis of the graph on page 1 entitled
"Surplus Sales."
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
Surplus Sales
MWh
2013 2013 2013 2013 2013 2013 2013 2013 2013 2014 2014 2014
Apr May Jun Jul Auo Sep Oct Nov Dec Jan Feb Mar Total
Forecast 237 322 11 26 33 294 376 368 229 276 391 552 3.115
Actual 65 73 61 55 51 200 194 267 215 241 315 261 1.998
REQUEST FOR PRODUCTION NO. 8: For each month represented on the
graph please identify the forecasted and actual monthly generation for the Langley
Gulch generating station.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The forecasted and
actual monthly generation for the Langley Gulch generating station is shown in the
confidential table below.
Langley Gulch
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 9: What was the forecast and actual
variable cost of operating Langley Gulch during each month represented on the graph.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The forecasted and
actual variable costs of operating Langley Gulch for each month of the 2013-2014 PCA
year are shown in the confidential table below.
Langley Gulch
Variable Cost
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDAGTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 10: The table on page 2 shows that actual
hydro generation was Iess 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: While ldaho Power
recorded higher actual surplus sales than forecasted by 96,569 MWh for the months of
June, July, and August, total actual surplus sales for the PCA year were significantly
below forecast by 1,116,990 MWh. This reduction in actual surplus sales was primarily
the result of lower than anticipated hydro generation. Please refer to ldaho Poweds
response to lndustrial Customers of Idaho Power's Request for Production No. 7 to see
the monthly MWh data.
!t is also important to note that hydro generation is only one component. The
table below is a summation (000s MWh) of system components for June, July, and
August.
June -August June -August June -AugustForecast Actua! Variance
Load
Hydro
Thermal
CSPP
Purchased Power
Total Resources
1,725
2,083
574
417
(316)
381
(4e)
363
282
379
4,728
4,798
70
5,010
1,408
2,464
525
780
5,177
167Surplus Sales
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
97
During this three-month period, loads were higher than forecast. ln fact, ldaho
Power recorded all-time system peaks on July 1 and again on July 2, 2013. ln order to
meet ldaho Poweds system load under lower than forecasted hydro conditions, ldaho
Power increased production at its thermal plants, specifically Langley Gulch, and
purchased power from the grid. The higher than forecast surplus sales resulted from
the increased thermal production and increased purchased power.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST FOR PRODUCTION NO. 11: Reference the table on page 2 labeled
"Brownlee Inflow." Were the forecast values the values that would be forecast based
upon present conditions and nonnal future precipitation, i.e., 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The Brownlee inflow
forecast values for the April 2013 through March 2014 PCA forecast year were based
on Snake River basin conditions at the time of the March 2013 forecast, norma! future
temperatures, and normal precipitation for the entire PCA year. The Snake River basin
conditions considered at the time of the March 2013 forecast included snow pack
conditions, as well as other basin conditions such as upstream reservoir storage.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 12: On page 2 it states that Langley Gulch
"was not dispatched in October 201 3 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. lf the maintenance was planned, please explain why
the forecast included the plant's "full dispatch" of production in the month of October.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Yes. The October
2013 maintenance outage was the first major planned maintenance event for Langley
Gulch. Maintenance of the gas turbine is triggered after 12,500 hours of operation.
This maintenance also addressed balance of plant systems and steam turbine work that
arose during the summer. ldaho Power extended the maintenance outage to include
some remaining warranty work since any work requires the plant to cool for several
days prior to work being performed. Maintenance work included:
o Removal, repair, and reinstallation of a steam control valve
. Removal, repair, and reinstallation of hot reheat bypass valve
. Repair of leaks in the boiler feed water system
lnstallation of PDA couplers
Testing of the emergency diesel generator at the river pump house
Modification of the heat plant bypass level control valve
Repair of the HRSG inlet duct liner
The October 2013 maintenance outage had not been scheduled at the time of
the March 2013 forecast. Instead, the plan expected the plant to be fully dispatched.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
Each month, ldaho Power prepares an 18-month system-wide forecast and
maintenance schedules are updated as part of that process. Once the maintenance
schedule became known, the availability of the unit was reduced from 245 average
megawatt-hours ("aMW") lo 27 aMW, reflecting four days of operation at the beginning
of the month and four days of operation at the end of the month. ln actuality, the plant
was available for operations October 1 and October 28 - 31 and operated a total of
9,890 MWh forthe month, or 13 aMW.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 13: Does ldaho Power prepare a new 12-
month hydro generation each month, or on any other regular periodic basis? Please
provide a copy of al! of the 12-month hydro forecasts (monthly or otherwise) that were
prepared from March 2013 through the most recent forecast available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: ldaho Power prepares
an 18-month forecast each month. Please see the confidential Excel file provided on
the confidential CD. The attachment provided in response to this request is confidential
and will be provided to those parties that have executed the Protective Agreement in
this matter.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1O
REQUEST FOR PRODUCTION NO. 14: Please provide all documents and
spreadsheets (in workable electronic format) used in the forecast of the Net 95%
accounts based on the Company's March 27,2014 Operation Plan as shown on pages
4 and 5 of Scott Wright's direct testimony. Please explain the difference in those values
and those values in Table 1, page 9 of Tim Tatum's direct testimony. Please describe
all assumptions used in the forecast and provide a copy of the Operation Plan used for
the forecast.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: The Operating Plan
used for the PCA forecast is part of the Energy Risk Management Committee minutes
and is confidential. lt is available for onsite review. Please contact Doug Jones at (208)
388-2615 or Camilla Victoria at (208) 388-5821 to schedule a time to review the
documents.
The values on Table 1 of Tim Tatum's testimony refer to the base Net Power
Supply Expense ("NPSE") amounts approved in Order No. 33000 in Case No. IPC-E-
13-20. The base NPSE amounts are quantified using the AURORA model and based
off of a normalized test period. The values shown on pages 5 and 6 of Scott Wright's
testimony are the PCA forecast amounts for the April 2014 through March 2015 test
period, which are not normalized and use a different test period.
Assumptions used in the forecast include:
Fonryard market prices - a forward price curve is developed using quotes from
the lnterContinenta! Exchange (.lCE") and broker quotes for Mid-Columbia ("Mid-C')
and Palo Verde hubs. Border prices, representing the edge of ldaho Powe/s system,
IDAHO POWER COMPANY'S REDAGTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11
are developed using Mid-C prices and adjusting for seasonality and transmission
expenses.
Water flows - Water flows are forecast based on many factors including river
base flows, future precipitation and temperature, the amount and timing of water leases,
upstream reservoir levels and operations, current and future snow pack conditions, the
rate and timing of snow melt, basin soil conditions, system irrigation demand, and the
health of the aquifer.
Loads - Loads are developed based on historical data, seasonal variations, and
information from large industrial and special contract customer.
Maintenance - Maintenance assumptions are developed by plant operations
personnel to estimate the timing and duration of maintenance events.
CSPP and PPA - Generation forecasts for Public Utility Regulatory Policies Act
of 1978 contracts and power purchase agreements are developed by the project
management.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
REQUEST FOR PRODUCTION NO. 15: According to the testimony of Scott
Wright, page 10, the proceeds of the sale of REC's and SO2 are included in the
Company's deferral expense account. PIease provide a list of the number of RECs
sold, who they were sold to and at what price. Also please provide the amount of SO2
sold, who it was sold to and at what price.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Please see the
confidential Excel filed provided on the confidentia! CD. The attachments provided in
response to this request are confidential and will be provided to those parties that have
executed the Protective Agreement in this matter.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
ldaho Power Company.
DATED at Boise, ldaho, this 13h day of May 2014.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13
Attomey for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of May 20141 served a true and correct
copy of IDAHO POWER COMPANY'S REDAGTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
upon the following named parties by the method indicated below, and addressed to the
following:
Commission Staff Hand Delivered
Karl T. Klein
Deputy Attomey General
ldaho Public Utilities Commission
472 W esl Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-OOT 4
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
U.S. Mail
X Email karl.klein@puc.idaho.sov
X Email peter@richardsonadams.com
X Email dreadinq@mindsprinq.com
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1 391
Overnight Mail
FAX
Hand DeliveredX U.S. Mail
Overnight Mail
FAX
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email botto@idahoconservation.orq
_FAXX Email elo@racinelaw.net
ldaho lrrigation Pumpers Association _Hand Delivered
Eric L. Olsen U.S. Mai!
RACINE, OLSON, NYE, BUDGE, & _Overnight Mail
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 14
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
_Hand Delivered
U.S. Mail
Ovemight Mail
FAXX Email tonv@vankel.net
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 15