20140519IPC to Staff 1-3.pdf

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DONOVAN E. WALKER
Lead Counse!
[e-mail]
May 19,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
!daho Public Utilities Commission
47 2 W est Wash i ngton Street
Boise, Idaho 83702
Case No. IPC-E-14-08
J. R. Simplot Accounting Order - ldaho Power Company's Response to the
First Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff to ldaho Power Company.
Also enclosed are four (4) copies of a confidential disk containing information
responsive to the Staff's First Production Request. Please handle the confidential
information in accordance with the Protective Agreement executed in this matter.
Veryf\uly yours,
J)Zdr--
Donovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise. lD 83707
DONOVAN E. WALKER (lSB No. 5e21 ) RECf; lVffi il
JULTA A' HILT9N (lsB No' 7740)
?0rrr HAy t9 pr{ rrr rrgldaho Power Company
1221West Idaho Street (83702) TDAHO F,ii[i.t(,
P.O. Box 70 UTILITIES C0fi#,41$iit0i\
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
ih i lton @ ida hopower.com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF THE APPLTCATTON )
oF |DAHO POWER COMPANY FOR AN ) CASE NO. !PC-E-14-08
ACCOUNTING ORDER.)) TDAHO POWER COMPANY'S
) RESPONSE TO THE F|RST
) PRODUCTTON REQUEST OF
) THE COMMTSSTON STAFF TO
) TDAHO POWER COMPANY
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compohy"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated May 12,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide electronic executable copies of all
spreadsheets and analysis used to derive the $1,884,406.85 amount of the
overpayment to Simplot. Please show the monthly estimated generation, the monthly
actual generation, and the alternative prices that were applied. Please also include
copies of any other supporting work papers used to derive the amount.
RESPONSE TO REQUEST NO. 1: Please see the confidential Excel file
provided on the confidentia! CD. The confidential CD will be provided to those parties
that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please explain how it was determined that Simplot would pay
$1,564,503.76 and ldaho Power would pay the remaining $319,903.09 of the
$1,884,406.85 total amount of the overpayment.
RESPONSE TO REQUEST NO. 2: Idaho Power has proposed to refund
$319,903.09 to ldaho Power customers as this is the difference between the calculated
overpayment amount and the amount J. R. Simplot Company ("Simplot") has agreed to
reimburse to ldaho Power customers for this overpayment.
Through the course of discussions, each party's responsibilities, legal concerns,
numerous dollar values, etc., were discussed. As a result of these conversations,
Simplot proposed the $1,564,503.76 payment based upon an internal calculation it
performed. Simplot did not provide written detail of its interna! calculation but explained
that it was based on various internally generated energy values-most importantly, a
value it could agree to. ldaho Power evaluated this value in comparison to its
calculated values, taking into consideration legal concerns, litigation options, and other
issues, including the statute of limitations, and determined it was a reasonable
compromise of the overpayment amount.
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Coordinator Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: Please explain whether Simplot's monthly generation
estimates assumed planned maintenance in May and June of every year.
RESPONSE TO REQUEST NO. 3: Idaho Power does not have information
confirming that Simplot specifically provided monthly generation estimates for the
months of May and June that included planned maintenance. However, historically and
a review of many years of generation data confirms that Simplot has routinely reduced
energy deliveries to ldaho Power during the months of May and June for apparent
annual planned major maintenance of the generation facility and it is a common
occurrence that planned maintenance schedules require unplanned deviations.
As indicated in the confidential Excel file provided in the Company's response to
Staff's Production Request No. 1, the overpayment of $1,884,406.85 is the
overpayment amount based upon the actual energy estimates compared to the actual
performance with adjustment for the months of May and June of each year. The May
and June values were adjusted due to the confusion in the energy sales contract
between the actual notification of maintenance schedules and notifications requesting
adjustment to the monthly kilowatt-hour ("kWh") estimates. ln the discussions with
Simplot, it was suggested that Simplot had routinely provided updated information on its
planned maintenance schedule and also information regarding unplanned changes in
these maintenance schedules. The energy sales agreement allowed for adjustments in
the monthly estimated kWh estimates on a real-time basis if the reason for these
changes was due to a forced outage that was not caused by force majeure, neglect,
disrepair, or lack of preventative maintenance. It was suggested that the real-time
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
notifications of changes in the planned maintenance schedules should have been
accounted for in the Company's overpayment calculations.
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Coordinator Leader, ldaho Power Company.
DATED at Boise, ldaho, this 19th day of May 2014.
&,f,,*-DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
CERTIFICATE OF SERVICE
t HEREBY CERTIFY that on the 19fr day of May 2014 I served a true and conect
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Donald L. Howel!, !!
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Wash i ngton (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Gompany
Don Sturtevant, P.E.
J. R. Simplot Company
One Capital Center
999 Main Street
P.O. Box 27
Boise, ldaho 83707 -0027
X Hand Delivered
_U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand DeliveredX U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
Christa Bearry, Leg
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6