20161209ICL & Sierra Club 1-16 to IPC.pdf

RECEIVED
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION 20 lei DEC -9 PH I : 17
)
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RA TES )
FOR ELECTRIC SERVICE TO RECOVER )
COSTS ASSOCIATED WITH THE NORTH )
V ALMY PLANT )
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CASE NO. IPC-E-16-24
FIRST SET OF DA TA REQUESTS
OF SIERRA CLUB AND IDAHO
CONSERVATION LEAGUE TO
IDAHO POWER COMPANY
. 1-U .:LiC
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Sierra Club and Idaho Conservation League ("ICL") hereby serve their first set of data requests
regarding the above-mentioned docket. Sierra Club and ICL request that Idaho Power Company
provide responses as expeditiously as possible, but not later than the deadline of21 days, which
is December 30, 2016.
INSTRUCTIONS
1. Please provide copies of responses to the following contacts:
Travis Ritchie Alexa Zimbalist
Sierra Club Law Program Sierra Club Law Program
2101 Webster Street, Suite 1300 2101 Webster Street, Suite 1300
Oakland, CA 94612 Oakland, CA 94612
[e-mail] [e-mail]
Ben Otto
Idaho Conservation League
710 N 6th St.
Boise, ID 83701
[e-mail]
2. Whenever possible, Sierra Club and ICL prefer to receive electronic copies of data
responses either by email or on CD.
3. Responses to any and all of Sierra Club and ICL 's data requests should be supplied to
Sierra Club and ICL as soon as they become available to Idaho Power.
4. The requests herein shall be deemed to be continuing in nature and Idaho Power is
requested to supplement its responses as necessary and as additional information
becomes available.
5. In responding to each data request, please consult every document source which is in
your possession, custody, or control, including all documents in the possession of experts
or consultants.
6. For each response, identify the person who prepared the answer to the data request as
well as his or her position with Idaho Power or any Idaho Power affiliate or parent.
7. Please reproduce the data request being responded to before the response.
8. If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
9. If the responses include spreadsheet files, please provide those spreadsheet files in
useable electronic Excel readable format.
I 0. In responses providing computer files, list the file names with cross-reference to the data
request, and if necessary to the understanding of the data, provide a record layout of the
computer files. Computer files provided with a response must be in or compatible with
the current version, or the immediately prior version, of Microsoft Office.
11. For each dollar amount provided in response to a discovery request please state if the
amount is in nominal or constant dollars and what years dollars.
~-
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In The Matter of the Application of Idaho Power Company for Authority to Increase Its
Rates for Electric Service to Recover Costs Associated with the North Valmy Plant
Case No. IPC-E-16-24
Sierra Club and Idaho Conservation League's First Set of Data Requests to
Idaho Power Company
December 9, 2016
DATA REQUESTS
SC/ICL 1-1. Provide all data requests and responses received from or sent to other parties in this
proceeding. This is an ongoing request.
SC/ICL 1-2. Provide copies of all confidential testimony and workpapers relied on in the application.
SC/ICL 1-3. Provide the North Valmy operating agreement currently in force, as well as any
amendments currently in force.
SC/ICL 1-4. Provide any other partnership or ownership agreements currently in force at the North
Valmy station between Idaho Power Company and Nevada Energy (or its affiliates).
SC/I CL 1-5. Provide any correspondence between Idaho Power Company and Nevada Energy ( or its
affiliates) with respect to the useful life ofNorth Valmy station between 2013 and the
present day. Please interpret "useful life" broadly in this case to encompass service life,
depreciable life, and economic life.
SC/ICL 1-6. Provide all correspondence and communications between Idaho power Company and
Nevada Energy (or its affiliates) that discusses North Valmy station between 2013 and
the present day, including but not limited to all correspondence related to the expected
life and/or economic value of North Valmy station. To the extent such communications
do not have a written record, provide the approximate dates, frequency and topics of such
communications.
SC/ICL 1-7. Describe the process used by Idaho Power Company to assess the economic value of
Idaho Power Company, if such processes have been employed. If not employed, why
not?
SC/ICL 1-8. Please refer to Idaho Power Company's 2015 Integrated Resource Plan, Table 9.4.
a. Please confirm that Portfolio 9 ("P9") assesses a future in which one unit at
Valmy is retired in 2019, and a second unit is retired in 2025.
b. Please confirm that in all sensitivities reported in this table, P9 is the least
cost portfolio. If not, explain why not.
c. Please explain in detail why the Company did not select P9 as the preferred
portfolio from the 2015 IRP.
In The Matter of the Application of Idaho Power Company for Authority to Increase Its
Rates for Electric Service to Recover Costs Associated with the North Valmy Plant
Case No. IPC-E-16-24
Sierra Club and Idaho Conservation League's First Set of Data Requests to
Idaho Power Company
December 9, 2016
d. Explain, in detail, what is meant by "baseline costs too high" P4, PS, and
PIS.
SC/ICL 1-9. Please refer to Idaho Power Company's 2015 Integrated Resource Plan.
a. Provide the Aurora model outputs for the Company's preferred portfolio and
P9. Provide, at a minimum annual capacity (MW), generation (GWh),
capacity factor(%), heat rate (MMBtu/MWh or equivalent), fixed cost
('000$, including capital and fixed O&M), fuel cost ('000$), variable O&M
cost ('000$), and emissions (tons) of CO2 by unit.
b. Provide any post-processing workbooks used by the Company in the
evaluation or assessment of the annual and total financial cost of these
portfolios.
SC/ICL 1-10. Please refer to Idaho Power Company's 2015 Integrated Resource Plan, page 9, where
the Company writes that "the optimization of coal unit shutdown alternatives using
computer modeling tools will not be possible until the proposed CAA Section 111 (d)
regulation is finalized sometime in the second half of 2015."
SC/ICL 1-11.
a. Please confirm that CAA Section 11 l(d) regulation was, in fact, finalized.
b. Did Idaho Power Company seek to optimize coal unit shutdown alternatives
using computer modeling tools after the finalization of that regulation? If not,
why not?
c. Did Idaho Power Company seek to optimize coal unit shutdown alternatives
using computer modeling tools in preparation for this depreciation case? If
not, why not?
With respect to studies examining transmission implications for the retirement of one or
both units of North Valmy station:
a. Identify any studies conducted by or on behalf of Idaho Power Company
between 2013 and the present day;
b. Identify any studies in the possession of Idaho Power Company produced
between 2013 and the present day;
c. Provide any studies identified in (a) and (b ), above.
d. What is Idaho Power Company's current estimated cost of transmission
mitigation for a 2019 retirement of one unit at Val my? Provide the basis for
this response and any supporting studies.
'\
,
In The Matter of the Application ofldaho Power Company for Authority to Increase Its
Rates for Electric Service to Recover Costs Associated with the North Valmy Plant
Case No. IPC-E-16-24
Sierra Club and Idaho Conservation League's First Set of Data Requests to
Idaho Power Company
December 9, 2016
e. What is Idaho Power Company's current estimated cost of transmission
mitigation for a 2019 retirement of both units at Val my? Provide the basis for
this response and any supporting studies.
SC/ICL 1-12. Regarding studies, conducted between 2013 and the present day, of the economic value
to Idaho Power's ratepayers for the continued operations at North Valmy beyond
December 2016:
a. Identify any such studies conducted by or on behalf of the Company;
b. Provide papers, reports, memoranda or presentations provided to or
generated by the Company from such studies;
c. Provide workpapers supporting such studies as available to the Company, in
original condition, unlocked, with formulae and links intact.
SC/ICL 1-13. Provide any correspondence, presentations, memoranda, white papers or the like
presented or provided to lenders, banks, rating agencies, bondholders, shareholders or the
like between 2013 and the present day with respect to the economic value, useful life, or
depreciation date of North Valmy.
SC/ICL 1-14. Provide any strategic planning documents for North Valmy produced by or on behalf of
Idaho Power Company or Nevada Energy (or its affiliates) between 2013 and the present
day.
SC/ICL 1-15. Regard contracts for fuel at North Yalmy Station with terms longer than one year:
a. Identify contracts signed between 2005 and the present day;
b. Identify the source, minimum annual take, fixed price, and term length of
each contract.
SC/ICL 1-16. Provide any currently active contracts for the procurement and/or transportation of coal at
North Valmy station.
CERTIFICATE OF SERVICE
I hereby certify that on this 9th day of December 2016, I delivered true and correct copies of the
foregoing FIRST SET OF DAT A REQUESTS OF SIERRA CLUB AND IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY to the following persons via
electronic mail:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
[e-mail]
[e-mail]
IIPA
Eric L. Olsen
ECHOHA WK & OLSEN, PLLC
[e-mail]
Anthony Yanke!
[e-mail]
MICRON
Pete Bennett
Micron Technology, Inc.
cbennet@ micron.com
Idaho Power
Lisa D. Nordstrom
Matt Larkin
Idaho Power Company
[e-mail]
[e-mail]
[e-mail]
MICRON
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Brian T. Hansen
Holland & Hart, LLP
[e-mail]
[e-mail]
[e-mail]
bhansen@ho l landhart.com
[e-mail]
[e-mail]
[e-mail]
DOE
Steven Porter
United States Department of Energy
[e-mail]
Isl Alexa Zimbalist
Alexa Zimbalist
Legal Assistant
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]