20150423IPC to Staff 1-2.pdf

SEffi*.
An IDACoRP Company
LISA O. NORDSTROIIi
Lead Gounsel
I [e-mail]
Apri! 23, 2015
LDN:csb
Enclosures
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VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Wash i ngto n Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-13
J. R. Simplot Company (Caldwell Facility) Special Contract - ldaho Power
Company's Response to the First Production Request of the Commission
Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and three (3) copiesof ldaho Power Company's Response to the First Production Request of the
Commission Staff.
Also enclosed are four (4) copies of a non-confidentia! disk containing
information responsive to the Staff's production requests.
Very truly yours,
,2^6*L?,-e-r,^*-
Lisa D. Nordstror#
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom@ idahopower. com
Attorney for Idaho Power Company
2I:: il'i] 2; Fi'l 12:58
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER )
CoMPANY'S APPLTCATTON FOR ) CASE NO. IPC-E-15-13
APPROVAL OF SPECTAL CONTRACT )
AND TARIFF SCHEDULE 32 TO PROVTDE ) TDAHO POWER COMPANY',S
ELECTRTC SERVTCE TO J. R. SIMPLOT ) RESPONSE TO THE FIRST
coMPANy',S CALDWELL FACIL|TY. ) PRODUCTTON REQUEST OF) THE COMMTSSTON STAFF
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated April 14, 2015, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: !n Commission Order No. 33038, the Commission directed
the parties to use the Company's most recent cost-of-service study as the starting point
for determining an appropriate rate. Please provide workpapers and calculations
showing the figures extracted from the 2011 Cost of Service Study, and how they were
used in deriving the rates shown in the contract. Also, please provide workpapers
showing how any changes that have occurred since the 2011 Rate Case were
accounted for in deriving the contract rates presented in Schedule 32.
RESPONSE TO REQUEST NO. 1: ln compliance with Order No.33038, the
Company applied the most current cost-of-service information available to projected
electrical requirements provided by J. R. Simplot Company ("Simplot"). The foundation
for these calculations was the 2011 Cost of Service Study reviewed in ldaho Public
Utilities Commission ("Commission") Case No. IPC-E-11-08 ("2011 Rate Case"), which
reflected the final revenue requirement approved in the 2011 Rate Case. The 2011
Cost of Service Study was modified to reflect the removal of the three Simplot Schedule
19 locations that the new Caldwell facility will replace and the addition of the new
Caldwell facility as an individual rate class. Costs were then allocated to the new
Caldwell facility according to projected loads and the Company's methodology from the
2011 study. Please see the Excel files (Attachments 1 and 2) provided on the enclosed
CD for the numerical detail.
Once revenue requirement from the 2011 Rate Case had been appropriately
allocated to the Caldwell Special Contract, rates were adjusted to reflect changes that
have occurred since the conclusion of the 2011 Rate Case. Specifically, the Company
adjusted the special contract tariff to capture base rate changes resulting from
Commission orders related to the Open Access Transmission Tariff (OATT) defenal
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
adjustment, the depreciation study adjustment, the Boardman balancing account
adjustment, the Langley Gulch power plant adjustment, and, most recently, the update
to base net power supply expenses effective June 1,2014. To appropriately reflect the
outcomes of the aforementioned cases, ldaho Power adjusted the Caldwell Special
Contract rates in the same manner as the fina! approved rate changes from those
cases. Please see the Excelfile (Attachment 3) provided on the enclosed CD.
The response to this Request is sponsored by Mike Youngblood, Manager of
Regulatory Projects, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 2: How did the Company arrive at allocatlon factors used to
determine rates shown in the Schedule 32? ln particular, how did the Company
determine the 3CP/12CP and 12CP allocators used to allocate transmission and
production demand costs?
RESPONSE TO REQUEST NO. 2: The projected load profile (maximum
demand and energy) for the new Simplot facility in Caldwell was provided by Simplot.
The Company used that information to calculate the projected average monthly demand
and applied historical monthly system coincident demand ("SCD") factors to establish
the system coincident peak demands to be used as inputs into the 2011 Cost of Service
Study. The SCD factors that were applied to the projected average demand were the
combined 2012 monthly SCD factors from the three Simplot rate 19P locations that
have been or are planned to be closed due to the consolidation of activities at the new
Caldwell facility.
The following calculations were used to compute Simplot's coincident peak
demands used in the special contract pricing:
Projected Average Demand
Monthly Energy @ # of Hrs _ Avg. Monthly
Generation Level(kWh) in Month - Demand (kW)
System Coincident Demand factor
Historical Monthly+ System Coincident
Demand (kW)
Projected System Coincident Peak Demand
The response to this Request is sponsored
Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
Projected System
= Coincident Peak
Demand (kW)
by Mike Youngblood, Manager of
HistoricalAvg Monthly
Demand (kW)
_ System Coincident- Demand factor
System Coincident
Demand factor
Projected Avg.x Monthly Demand (kW)
DATED at Boise, ldaho, this 23d day of April 2015.
Attomey for ldaho Power Company
IDAHO POWER GOMPAI.IYS RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. S
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23d day of Apri! 2015 t served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
KarlT. Klein
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 8372O-OO7 4
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83701
Don E. Sturtevant
Director, Energy Purchasing
J. R. Simplot Company
P.O. Box 27
Boise, ldaho 83707 -0027
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6