20160524IPC to ICIP 10.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
May 23,2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-16-08
2016-2017 Power Cost Adjustment - ldaho Power Company's Response to
the Second Production Request of the lndustrial Customers of ldaho Power
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the Second Production Request of the lndustrial
Customers of ldaho Power.
Very truly yours,
Xr- 924,"^tl,r",^'
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho 5t. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (tSB No.5733) j:l:ilf IVED
ldaho Power company '- :,:.',; ::3 pl{ rr: 5 j1221West ldaho Street (83702) r
P.O. Box 70 , ,,,_ ,l_lC
Boise, Idaho 83707 - :j( ,ri"iiiSi0l'j
Telephone: [phone]
Facsimile: [phone]
I n ord strom @ id a h opower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE APPLICATION )
oF rDAHO POWER COMPANY FOR ) CASE NO. !PC-E-16-08
AUTHORTTY TO TMPLEMENT POWER )cosr ADJUSTMENT (PCA) RATES FOR ) IDAHO POWER COMPANY',S
ELECTRTC SERVICE FROM JUNE 1,2016 ) RESPONSE TO THE SECOND
THROUGH MAY 31,2017 ) PRODUCTTON REQUEST OF
) THE INDUSTRTAL CUSTOMERS
) oF IDAHO POWER
)
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the lndustrial Customers of ldaho Power
dated May 18, 2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 10: On page 10 of the Direct Testimony of
ldaho Power witness Matthew Larkin he states this year's PCA forecast anticipates an
increase of 257,857 MWh of PURPA generation over last year's forecast. This increase
is largely due to the expected 320 MW of solar projects. The Pocatello Airport on May
16, 2016 announced the solar project planned on their property has been withdrawn.
Please fully answer the following;
a) Was the Pocatello Airport solar project included in this year's PCA
forecast?
b) lf so what was the size of the solar project at the Pocatello Airport?
c) lf so what should be the reduction in the projection of MWh from this
year's PCA forecast?
d) lf so what should be the dollar reduction in the Account 555, PURPA that
is included in this year's PCA request by the Company?
e) Does the Company intend to update its Application in this matter to reflect
this change? Why or why not?
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
a & b) The requested information was provided in the Company's response to
the ldaho Public Utilities Commission Staffs Production Request No. 3, which was then
provided to the lndustrial Customers of Idaho Power in response to its Request for
Production No. 1.
c & d) There should be no reduction in the filed Power Cost Adjustment ('PCA')
forecast for either megawatt-hours or expected expenses with respect to the Pocatello
Airport solar project.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
e) Please see the following excerpt from pages 2 through 4 of the
Company's Reply Comments filed in this case on May 23,2016:
With respect to ICIP's recommendation, the Company
maintains that the March 31,2016, Operating Plan ("March
Op Plan") is the appropriate basis for the 2016-2017 PCA
forecast, and should not be modified to remove the Pocatello
Solar project. While ldaho Power can confirm the media
reports are accurate and the Pocatello Solar project officially
terminated as of early May, for reasons stated below, the
Company does not believe it is necessary to incorporate any
change to the filed PCA forecast.
The March Op Plan reflects the most current forecast
information available at the time the PCA is filed, beginning
with the first month in the April through March PCA forecast
year. Given the forecast time period and the annual mid-
April filing date, the March Op Plan serves as the most
current information available for the PCA forecast included in
the Company's annual PCA filings.
The True-Up is the appropriate component of the
PCA to track differences between actua! and forecast net
power supply expenses ('NPSE"). Throughout the PCA
forecast year of April through March, when actual NPSE
deviate from the forecast contained in the March Op Plan,
the deviations are tracked through the True-Up component
of the PCA and passed through to customers in the following
year's PCA rate. To the extent that expenses resulting from
Public Utility Regulatory Policies Act of 1978 ('PURPA')
contracts deviate from actuals, 100 percent of the variance is
passed through to customers in the next year's PCA rate.
On page 6 of its Comments, Staff acknowledges thatthe Company's forecasted PURPA expenses are
appropriate, and that any deviations between forecast and
actuals wil! be trued-up in the following PCA. ldaho Power
concurs with Staffs conclusion.
Lastly, the modification suggested by lClP represents
the singling out of one known variable that has changed
since the completion of the March Op Plan, ignoring all other
changes that have occurred since that time. lt is important
to note that if the PCA forecast was to be updated following
the initial filing date, it would be appropriate to update for all
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
known changes since the development of the March Op
Plan. The result of this comprehensive update could be a
rate increase or decrease relative to the filed request,
depending on the entirety of changes that occurred since the
filed PCA forecast was developed.
The response to this Request is sponsored by Matt Larkin,
Requirement Manager, ldaho Power Company.
DATED at Boise, ldaho, this 23'd day of May 2016.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
Revenue
. NORDS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23d day of May 2016 I served a true and correct
copy of IDAHO POWER COMPANY'S 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
Brandon Karpen
Deputy Attorney Genera!
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5