20150811ICIP 1-7 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Greg Adams (ISB 7454)
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone]
Fa:r: [phone]
Peter@richardsonarrdolt*..orn
Attomeys for the Industrial Customers of Idatro Power
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TTM APPLICATION )
OF IDAHO POWER COMPANY FOR AN )
ORDER AUTHORIZING TTIE APPROVALJ
OFALONGTERMPROGRAM )
CONTRACT WITH SIEMENS ENERGY, )
[NC., AND DEFERRAL OF ASSOCIATED ICOSTS. )
))
CASE NO. IPC.E-15-17
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the ldatro Public Utilities Commission
(the "Commission'o), The Industrial Customers of Idatro Power ("ICIP") by and through their
attomey 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 aI 6070 Hill Road, Boise, Idatro 83703, Tel:
ICIP First Production Request- trC-E-I5-17
,t
a
(208) 3 42-1700; Fax: (208) 3 84- I 5 I I ; [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.
lf some of the following requests include disclosures deemed by Idaho Power to be
confidential, the ICIP has already entered into lda]ro Power's standard confidentiality agreement.
REOUEST FOR PRODUCTION NO. 1
Please provide all discovery responses along with the workpapers and attachments
provided to all other parties.
REOUEST FOR PRODUCTION NO. 2
Mr. Mahlum, at page 6 of his direct testimony has the following Question and Answer:
Q. Did the Company issue a request for proposal for the services provided for
under the LTP Contract?
A. No. However, Idaho Power did contract with a professional knowledgeable in
long-term program contacts who contacted multiple third-party providers of gas
plant maintenance as part of a formal request for information process. Those
third-party proposals were analyzed by both the Company and the contracted
professional and it was determined that there are currently no other third-party
maintenance providers that could provide services equivalent to those provided
under the LTP Contract with Siemens.
Please provide the names and positions of all those "professional knowledgeable in long-term
program contracts" that were contacted by the Company. Please also provide all the "third-party
providers of gas plant maintenance" that were contacted by the knowledgeable professionals.
Please provide all correspondence between the knowledgeable professionals (emails, notes,
documents, etc.) and ldaho Power. Please document all inputs used to "determine ... that there
are currently no other third-party maintenance providers..."
REOUEST FOR PRODUCTION NO.3
In Idaho Public Utilities Commission case IPC-E-09-03, in which ldaho Power asked for
ICIP Fint Production Request - IPC-E-15-17
i"I
a CPCN for Langley Gulch Company, witness Mr. Porter stated;
a. Will Idaho Power have personnel capable of operating a base load resource of this
type?A. Yes. Idaho Power will be able to operate and maintain this combined cycle power
plant. Idatro Power has been operating natural gas combustion turbines since Evander
Andrews Unit Nos. 2 and 3 were constructed in 2001. The Company added Bennett
Mountain in 2005, and Evander Andrews Unit No. 1 in 2008. Idatro Power's operations
and maintenance staffis familiar with gas operations and has developed extensive
expertise with Siemens F-Class gas turbines. [n addition, the combined cycle power plant
will be controlled by the Siemen's T-3000 system, which is the control system currently
used to operate the Company's existing gas turbines.
The combined cycle plant staff will consist of 18 personnel, including l0
operators to provide 24by 7 coverage, two maintenance mechanics, two technicians, an
engineer, a chemist, clerk/materials coordinator, and an operations and maintenance
supervisor. These individuals will be hired at various stages in the construction process so
that they will be familiar, as needed, with the design and construction of the Plant and
will receive training prior to commercial operation.
The existing combustion turbine staff and the new combined cycle staff will be
combined to form a gas group, reporting to one manager. This will facilitate the sharing
of knowledge and expertise among the plants as well as allowthe Company to shift
manpower as needed for maintenance.
Prior to commencing with Plant operations, personnpl will receive operating and
maintenance training as part of the contracts with Siemens and Kiewit/TIC.
Operating and maintenance procedures will be developed and implemented with
Siemens and Kiewit/TIC prior to commercial operation of the Plant. [Vemon Porter,
Idaho Power Direct Testimony, IPC-E-09-03, p. 23 -25.)
lf the Commission approves the proposal for the Long Term Program (LTP) with Siemens, what
cost savings does the Company expect in personnel and other costs that will no longer be
provided by ldatro Power for each of the gas plants; Danskin, Bennett Mountain, and Langley
Gulch? How many personnel will remain in the 'gas group?' What function (mechanic,
technician, etc) will each of the remaining personnel perform?
REOUEST FOR PRODUCTION NO.4
Ms. Waites, in Exhibit 1 of her direct testimony uses a 7 .860/o 'Proposed Rate of Return'
as the discount rate to find the NPV of Revenue Impact for 5, 10, and 20 years. Please give
explanation of the source of the 7.86% discount rate, and explain rationale of why it was
ICIP First Production Request - IPC-E- I 5- 17
selected.
REOUEST FOR PRODUCTION NO. 5
Mr. Mahlum, at page 13 of his direct testimony states, "The pricing structure under the
LTP Contract involves per-unit initiationfezs, . . . ". Please fully define the meaning of "per-
unit". Please describe how the amount of the initialization fee was derived along with all
workpapers and documents supporting the calculation.
REOUEST FOR PRODUCTION NO. 6
Ms. Waites at page 3, beginning on line 20 of her direct testimony, states that "the
contract price reflects a discount based on ldatro Power's net book value of the initial spare
parts." Please quantify and document the genesis and calculation of the "discount." What is the
fair market value of the spare parts? What is the replacement cost of the spare parts? Please
provide a copy of the Company's pricing policy with respect to the sale of spare (surplus) parts.
Please provide copies of all PUC orders/letter advices or other documentation approving said
policy. Does this policy apply equally to vendors and/or ratepayers of the company? [f not,
please explain the rational for the different treatment.
REOUEST ['OR PRODUCTION NO. 7
On page 6 beginning on line 7 of Ms. Waites direct testimony she states:
a. Do you believe the transfer of ownership in the initial spare parts to
Siemens complies with Idaho Code $ 6l-328?
A. Yes. The transfer and sale of the initial spare parts to Siemens is
consistent with the public interest, will result in lower overall costs to Idatro Power and
its customers, and Siemens has the bona fide intent and financial ability to operate and
maintain the initial spare parts in the public service.
ICIP First Production Request- IPC-E-15-17
Please explain how the "spare parts" in question (reference Idaho Code $ 61-328(1)) are
currently being'oused in the generation, transmission, distribution or supply of electric supply
and energy..."
Please define the phrase "public service" as used by Ms. Waites on line 15 page 6 of her
direct testimony. Please explain, in detail how Siemens will be "operate[ing] and maintain[ing]
the initial spare parts in the public service."
Please provide copies of all material referred to by Ms. Waites in responding to this
question.
DATED this I lth day of August 2015.
Richardson Adams, PLLC
Peter J. Richardson
Industrial Customers of Idaho Power
ICIP Fint Production Request- IPC-E-15-17
CERTIF'ICATE O[' SERVICE
I HEREBY CERTIFY that on the 9th day of February,2}l5, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER, in Docket No. IPC-E-15-03 was
served as indicated below to:
Ms. Jean Jewell X- Hand Delivery
Commission Secretary _ U.S. Mail, postage pre-paid
Idatro Public Utilities Commission _ Facsimile
P O Box 83720 Electronic Mail
Boise ID 83720-0074
Lisa D. Nordstrom X Hand Delivery
Idatro Power Company _ U.S. Mail, postage pre-paid
1221 West ldaho Street _ Facsimile
P.O. Box 70 Electronic Mail
Boise,Idaho 83707
lnordstrom@ idahopower. com
dockets@ idahopower. com
Tim Tatum _ Hand Deliver
Idaho Power.Company X-U.S. Mail, postage pre-paid
1221 West ldatro Street _Facsimile
P.O. Box 70 X Electronic Mail
Boise,Idatro 83707
ttatum@idahopower. com
,^. \W
Nina Curtis
Administrative Assistant
ICIP First Production Request- IPC-E-I5-17