20161130IIPA 1-15 to IPC.pdf

Eric L. Olsen (ISB# 4811)
ECHO HA WK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
RECE IVED
Z 16 ,iOV 30 PM 2: 25
1,. •• ,' J:JL.IC
I . ;'.J;,UISSION
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMP ANY FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE NORTH
VALMYPLANT
CASE NO. IPC-E-16-24
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST DATA
REQUESTS TO IDAHO POWER
COMPANY
Idaho Irrigation Pumpers, Inc., by and tlu·ough counsel, hereby submits its first Data
Requests to Idaho Power Company, pursuant to Commission Rule 225, as follows:
1. On page 10 of Mr. Harvey's testimony, it is stated: "The preferred portfolio selected for the
2015-2034 planning horizon contained both actions in the year 2025, with completion of the
B2H transmission line preceding the end-of-year coal plant retirement." Please answer the
following:
a. When was the B2H transmission line first publically proposed and when was its
anticipated completion date at the time?
b. What was the B2H transmission line's anticipated completion date at the time in the 2009
IRP?
c. What was the B2H transmission line's anticipated completion date at the time in the 2011
IRP?
d. What was the B2H transmission line's anticipated completion date at the time in the 2013
IRP?
e. What was the B2H transmission line's anticipated completion date at the time in the 2015
IRP7
f. Given the B2H transmission line's anticipated completion date in the 2015 IRP, what
milestones were planned/expected to be met by year-end 2015 and year-end 20167
g. Given the B2H transmission line's anticipated completion date in the 2015 IRP, what
expected milestones were not met by year-end 2015 and year-end 20167
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO IDAHO POWER COMPANY -Page 1
h. Please provide a copy of all communications during 2016 that address the possibility of
delay of the anticipated completion date of B2H past the summer of 2025.
2. On page 11 of Mr. Harvey's testimony, it is stated: "The 2015-2018 action plan recognized
in the 2015 IRP included ongoing permitting, planning studies, and regulatory filings
associated with the B2H transmission line during all four years ... ". Please answer the
following:
a. Where in the 2015 IRP are these action plans addressed?
b. Please supply more specifics regarding the ongoing permitting, planning studies, and
regulatory filings that were in the action plan and what were the dates of each item.
c. What specific ongoing permitting, planning studies and regulatory filings in the action
plan are presently behind schedule and by how much?
3. On page 11 of Mr. Harvey's testimony, it states with respect to Valmy that "the dispatch cost
is now typically higher than the market price." What is the dispatch cost or range of dispatch
costs of Valmy?
4. In supp01i of the table on page 12 of Mr. Harvey's testimony please provide in electronic
format, on an hourly basis, for the period January 1, 2008 through the most recent month
available the following data:
a. Total system input;
b. System input from Company owned generation (stating hydro, coal, natural gas, and
other generation separately);
c. System input from fum purchases, grouped by type of purchase (LF, IF, SF, etc.)
d. The cost of each group of firm purchase listed in "c" above;
e. Total system input from non-firm and/or economy purchases;
f. The cost of non-firm and/or economy purchase listed in "e" above;
g. System input from exchanges into the system;
h. System input from Unit purchases;
i. Other system inputs than those listed above;
J. Jurisdictional (Idaho and Oregon) sales;
k. System losses;
1. Requirements Wholesale sales (RQ);
m. Long-term finn Wholesale sales (LF);
n. Intermediate-te1m fom Wholesale sales (IF);
o. Sh01i-term Wholesale sales (SF);
p. The revenue collected Short-term Wholesale sales (SF) listed in "o" above
q. Unit sales, Wholesale (LU) or otherwise;
r. Non-film and/or economy sales (OS);
s. The revenue collected each hour from non-fum and/or economy sales listed in "r" above.
t. Exchanges out of the system;
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO IDAHO POWER COMPANY -Page 2
u. Other system outputs;
v. Inadvc1tent power flows into or out of the system;
w. The power available (at input level) to supply retail load once Wholesale, Exchange,
Wheeling, and Inadvertent has been subtracted;
x. Losses assigned to each retail jurisdiction;
y. Losses assigned to Wholesale sales; and
z. Idaho Power's share of the Valmy output.
5. Regarding all of the scenarios listed in Table 7.5 of Exhibit No. 5, is the completion of the
B2H transmission assumed for the summer of2025?
6. On page 14 of Mr. Harvey's testimony, it states: "However, Idaho Power and NV Energy
continue discussions working towards a mutually agreed upon closure date." If at some time
in the future, Idaho Power and NV Energy agree upon a closure date, will this preclude the
changing of that date for non-forecasted events (B2H being delayed, wholesale prices
returning to historic levels, etc.)?
7. On page 14 of Mr. Harvey's testimony, it states: "However, Idaho Power and NV Energy
continue discussions working towards a mutually agreed upon closure date. Synchronized
depreciation dates for rate making purposes will help in establishing a date to cease coal-fired
operations." Can this statement be taken to mean that having a "synchronized depreciation
dates for rate making purposes" is not a prerequisite for "establishing a date to cease coal­
fired operations"? If not, why not?
8. Please explain the following with respect to the Appendix A found on page 2 of Exhibit 6:
a. With respect to the annual fixed costs listed for each scenario, please indicate what
specific components (Return, fixed O&M, taxes, etc.) of "fixed costs" are involved.
b. With respect to the specific components of "fixed costs" for each scenario listed in "a"
above, please list the dollar amounts that make up the figures for 2016 through 2025.
c. With respect to the categories of "fixed costs" for each scenario listed in "b" above, and
the dollar amounts that make up the figures for 2016 through 2025, what would the
figures for the 2025 retirement scenario be if the retirement date was moved to 2026?
Please provide an explanation of how/why these values changed.
d. With respect to the categories of "fixed costs" for each scenario listed in "b" above, and
the dollar amounts that make up the figures for 2016 through 2025, what would the
figures for the 2025 retirement scenario be if the retirement date was moved to 2027?
Please provide an explanation of how/why these values changed.
e. Mr. Larkin states that the Company is requesting an additional revenue of $28.5 million
per year. How is this amount reflected on page 2 of Exhibit 6?
f. What causes the fixed costs in 2016 under the early retirement scenario to be $8,365,000
higher than under the present retirement schedule?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO IDAHO POWER COMP ANY -Page 3
g. What causes the fixed costs in 2018 under the early retirement scenario to be $7,462,000
higher than under the present retirement schedule?
h. With respect to the Aurora costs for each scenario, please supply a copy in electronic
format of the outputs for years 2025 through 2034.
1. In 2026 the Aurora Model predicts that the 2025 retirement scenario will result in
$7,732,000 more than the model run for the present retirement scenario. In 2027 the
Aurora Model predicts a reduction in this difference to $6,733,000. For the next several
years the difference between the two model runs show an increasing cost differential.
What input mechanisms are at work to cause this variation in the difference between the
two scenarios to change in this manner from year to year?
J. For the year 2026, is the entire cost to the customers $477,970,000 ($51,461,000 plus
$426,509,000) under the present retirement schedule and $434,241,000 under the 2025
retirement scenario for an overall savings of $43,729,000 in 2026? If not, what other
costs/differentials are involved?
k. If the answer to ''j" above is positive, does this mean that by present customers paying
$28,500,000 extra annually, effective June 1, 2017, then in 2026 the customers will begin
to save $43,729,000 annually and by 2034 the annual savings will drop to $32,309,000?
9. What specific forecast changes or other parameter changes occmTed between the 2013 Coal
Study and the 2015 IRP that resulted in the 2025 retirement date being economical compared
to 2031 and 2035 retirement dates?
10. Were any economic evaluations (similar to that in Exhibit 6 in this case) conducted in the
2013 Coal Study or the 2013 JRP? If so, please provide.
11. For each of the tariff rates listed in Attachment 2 to the Application, please provide the
following:
a. Billing demands where applicable;
b. Revenue associated with customer charges;
c. Revenue associated with demand charges;
d. Revenue associated with energy charges;
e. Revenue associated with Schedule 55 (Power Cost Adjustment);
f. Other "Current Billed Revenue" that may be included in Attachment 2;
g. Indicate which of the above revenues was included in "all base rate components except
the service charge" as used to spread the increase among tariff rates in Attachment 2; and
h. If Schedule 55 revenues were not considered a part of "all base rate components except
the service charge", explain why not.
12. On page 6 of Mr. Larkin's testimony, it states: " ... Idaho Power's preferred po1tfolio from
the 2015 Integrated Resource Plan ("IRP") included the shutdown of Valmy Unit 1 and 2 in
2025 to coincide with the completion of the Boardman to Hemingway ("B2H") transmission
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO IDAHO POWER COMPANY -Page 4
line. In addition to the 2015 IRP analysis, in 2016, Idaho Power completed an assessment of
the operating future of Valmy with respect to economics of production and system
reliability." Explain how the 2015 IRP could have been based upon the shutdown of Valmy
in 2025 when, it was not until 2016 that "Idaho Power completed an assessment of the
operating future ofValmy with respect to economics of production and system reliability."
13 . On page 9 of Mr. Larkin's testimony, it states: "Without accelerating the depreciation
schedule to reflect the 2025 shutdown date, cost recovery from customers could extend
beyond the plant's operating life, resulting in cost recovery from future customers for a plant
that will no longer be providing service at that time." Please answer the following:
a. Would it be accurate to say that "the plant's operation life" is actually 50 years and that
the Company is proposing to close the plant early because it is no longer economical
and/or needed?
b. Would it be accurate to say that the Company's proposal is to charge existing customers
approximately $28.5 million more annually between June 1, 2017 and December 31,
2025. And further that, because of the increase in costs to the customers between 2017
and 2025, the customers between 2026 and 2035 get a much larger decrease?
14. According to Mr. Larkin's testimony at page 5: "The Company's current base rates do not
include any recovery of ARO (Asset Retirement Obligation) related to Valmy." If the
present base rates do not include any recovery of ARO, why should this cost be added to the
increase in costs that the Company is presently proposing for the June 1, 2017 through
December 31, 2025 timeframe?
15. With respect to Attachment A of Exhibit 6, what would the "Fixed Costs" values be for
2016-2034 ifValmy was shut down in 2025, but there was no change in the Valmy
depreciation schedule i.e., there was no accelerated depreciation and the present depreciation
rates were maintained through 2031 and 2035?
DATED this 30111 day of November, 2016.
£;!~
RIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FffiST DATA REQUESTS TO IDAHO POWER COMPANY -Page 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 301h day of November, 2016, I served a true, conect
and complete copy of the foregoing document, to each of the following, via the method so
indicated below:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
4 72 W. Washington Street
Boise, ID 83720-0074
i jewel [e-mail]. us
Lisa D. Nordstrom
Idaho Power Company
12221 West Idaho Street
P.O. Box 70
Boise, ID 83707
E:mail: lnordstrom(@idahopower.com
[e-mail]
Matt Larkin
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
E-mail: [e-mail]
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
D D
D
D ~
D D
D
D ~
FlRST DATA REQUESTS TO IDAHO POWER COMPANY -Page 6
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
lectronic Mail (Email)