20161230IPC to ICL & Sierra Club 1-16 Redacted.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
December 30, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-16-24
-'l1S iC · :Cf'.IM:SS ION
An IDACORP Company
Recovery of Costs Associated with North Valmy Power Plant -Idaho Power
Company's Response to the First Set of Data Requests of the Sierra Club
and the Idaho Conservation League
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and three (3) copies of
Idaho Power Company's Response to the First Set of Data Requests of the Sierra Club
and the Idaho Conservation League.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to the Sierra Club and the Idaho Conservation League's
data requests. Please handle the confidential information in accordance with the
Protective Agreement executed in this matter.
LDN:csb
Enclosures
Very truly yours,
o<i,~ 12. '?(_ a,_,k,~
Lisa D. Nordstrom
1221 W Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST SET
OF DATA REQUESTS OF THE
SIERRA CLUB AND THE IDAHO
CONSERVATION LEAGUE
COME$ NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Set of Data Requests of the Sierra Club and the Idaho
Conservation League to Idaho Power Company dated December 9, 2016, herewith
submits the following information:
IDh\HO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -1
REQUEST NO. 1-1: Provide all data requests and responses received from or
sent to other parties in this proceeding. This is an ongoing request.
RESPONSE TO REQUEST NO. 1-1: To date, Idaho Power has received data
requests from the Idaho Irrigation Pumpers Association, Inc., and joint data requests
from the Sierra Club and the Idaho Conservation League ("ICL"). Copies of Idaho
Power Company's Redacted Responses to the Idaho Irrigation Pumpers Association ,
lnc.'s First Data Requests was served on the parties on December 21, 2016. As a
matter of course, copies of Idaho Power's responses to discovery requests in this case
will be provided to all intervening parties. Please note that the language of each
request precedes Idaho Power's response .
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 2
REQUEST NO. 1-2: Provide copies of all confidential testimony and workpapers
relied on in the application .
RESPONSE TO REQUEST NO. 1-2: Idaho Power does not have any
confidential testimony, exhibits, or workpapers for this filing.
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 3
REQUEST NO. 1-3: Provide the North Valmy operating agreement currently in
force, as well as any amendments currently in force.
RESPONSE TO REQUEST NO. 1-3: Please see the confidential attachment,
which contains all the agreements currently in force, as well as any amendments,
provided on the confidential CD. The confidential CD will be provided to those parties
that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -4
REQUEST NO. 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).
RESPONSE TO REQUEST NO. 1-4: Please see the confidential attachment
provided in the Company's response to Sierra Club and ICL's Request No. 1-3.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 5
REQUEST NO. 1-5: Provide any correspondence between Idaho Power
Company and Nevada Energy (or its affiliates) with respect to the useful life of North
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.
RESPONSE TO REQUEST NO. 1-5: Because the potential pool of
communications was voluminous and burdensome to produce, counsel for Idaho
Power, Sierra Club, and ICL agreed that this Request be revised to only include
"communications between Idaho Power and NV Energy executives and senior
managers." It was also agreed that if the communications refer to an analysis
preformed by lower level employees that substantively influences the higher level
decisions, a complete record of such analysis may be requested by Sierra Club and ICL
as a follow up to the original Request.
Please see the confidential correspondence broadly referencing the useful life,
service life, depreciable life, and/or economic life of North Valmy station between 2013
and the present day provided on the confidential CD. Due to the volume of files being
provided in response to this Request, the individual file names and the actual
documents have not been labeled with the word "confidential." However, the main file
folder has been labeled confidential; all files provided in response to this Request
should be treated as confidential and handled accordingly. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this matter. In
addition, please see the confidential file provided in the Company's response to Sierra
Club and ICL's Request No. 1-6.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -6
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 1-6: Because the potential pool of
communications was voluminous and burdensome to produce, counsel for Idaho
Power, Sierra Club, and ICL agreed that this Request be revised to only include
"communications between Idaho Power and NV Energy executives and senior
managers." It was also agreed that if the communications refer to an analysis
preformed by lower level employees that substantively influences the higher level
decisions, a complete record of such analysis may be requested by Sierra Club and ICL
as a follow up to the original Request.
Please see the confidential document listing discussions regarding the North
Valmy station between 2013 and the present day, including correspondence related to
the expected life and/or economic value of North Valmy station provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this matter. In addition, please see the
confidential correspondence provided in the Company's response to Sierra Club and
ICL's Request No. 1-5.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 7
REQUEST NO. 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?
RESPONSE TO REQUEST NO. 1-7: Per clarification from Travis Ritchie, Sierra
Club and ICL request information regarding the economic value of the North Valmy
plant.
Idaho Power assesses the economic value of North Valmy by forecasting the
fixed and variable costs for Idaho Power's generation portfolio over the latest Integrated
Resource Plan ("IRP") forecast period. The fixed costs are evaluated using an Excel
workbook and the total generation portfolio costs are assessed via the hourly market
model, Aurora. The total of the fixed and variable costs of each alternative future
scenario are then compared on a net present value basis. The process is very similar
to the assessment of various portfolios within the IRP.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -8
REQUEST NO. 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.
d. Explain, in detail, what is meant by "baseline costs too high" P4, P5, and
P15.
RESPONSE TO REQUEST NO. 1-8:
a. Yes . Resource portfolios PB, P9, and P16 shown in Table 9.4 on pages
119 and 120 of the Idaho Power 2015 IRP retire one North Valmy unit in 2019 and retire
the second North Valmy Unit in 2025.
b. As shown in Table 9.4 on pages 119 and 120 of the Idaho Power 2015
IRP, resource portfolio P9 has the lowest estimated cost in all cases reported in Table
9.4.
c. As detailed on pages 5-8 of the Company's Reply Comments filed in Case
No. IPC-E-15-19:
Resource portfolio P9 reflects the retirement of North Valmy
Unit 1 at the end of 2019, the addition of 60 megawatts
("MW") of demand response in 2021-2024 (above and
beyond the 390 MW of summer demand response included
as an existing resource in all portfolios), 54 MW of
reciprocating engines in 2024, the 82H transmission line in
2025, an additional 18 MW of reciprocating engines in 2031
and a 170 MW simple cycle combustion turbine in 2032. pg
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -9
also reflects the retirement of the North Valmy Unit 2 in
2025. In comparison, the preferred portfolio P6(b) identified
in the 2015 IRP anticipates retirement of both North Valmy
Units 1 and 2 in 2025, and the addition of 82H in 2025 (prior
to the retirement of the North Valmy units), includes 60 MW
of additional demand response and 20 MW of ice-based
thermal energy storage in 2030, and a 300 MW combined
cycle combustion turbine in 2031.
Many of the public comments suggested the perception that
the P9 portfolio was "superior" to the P6(b) portfolio based
on a relative cost difference of $74.6 million in the total net
present value ("NPV") portfolio cost over the 20-year study
period. However, the evaluation of cost alone is not enough.
It also is important to consider the near-term impact to
customer rates. The portfolio analysis between P9 and
P6(b) compares the coal-fired generation plant retirements
and the associated cost differences by retiring the North
Valmy Units 1 and 2 earlier than their fully depreciated lives
of 2031 and 2034, respectively. Accelerating the
depreciation of the existing North Valmy plant investment will
require an immediate increase in customer rates during the
shortened recovery period. Using a December 31, 2014, net
book value, accelerating the end of life to 2025 for North
Valmy Units 1 and 2 would increase annual depreciation
expense by nearly $9.0 million, while an end of life for Valmy
Unit 1 of 2019, as modeled in portfolio P9, would increase
annual depreciation expense by an additional $6 million,
totaling nearly $15 million of incremental expense.
Moreover, with either a 2019 or 2025 retirement of Valmy,
customer rates would need to be adjusted to include
incremental capital additions required to keep the plant
operational during its remaining life. This adjustment would
require even more acceleration if North Valmy's closure was
in 2019 rather than 2025.
While the NPV of the total fixed and variable costs over the
20-year planning period are approximately 1.6 percent lower
for P9 as compared to P6(b), those cost savings must also
be balanced along with the qualitative risks discussed in the
IRP. On pages 125-130, the IRP explains these qualitative
risks in qualifying the favorable economics for portfolios with
retirement of North Valmy Unit 1 as early as 2019. Among
the risks, the IRP notes the uncertainty related to the 320
MW (as of April 2015) of yet-to-be-constructed Public Utility
Regulatory Policies Act of 1978 ("PURPA") solar and the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -10
effect of possible further project cancellations on capacity
additions in the early 2020s. This uncertainty remains
relevant, even with the Commission's recent decision in
Case No. IPC-E-15-01 (Order No. 33357). As an illustration,
with the complete removal of the PURPA solar from the load
and resource balance, capacity deficits with an earlier 2019
retirement of North Valmy Unit 1 are projected to reach
approximately 140 MW in July 2020 and grow to nearly 300
MW by 2023. By comparison, delaying the retirement of
North Valmy Unit 1 to 2025, including the complete removal
of PURPA solar, results in more manageable and moderate
deficits (provided the availability of Valmy units exist) of
approximately 5 MW in 2020 and less than 160 MW through
2023.
In addition, the qualitative risk analysis also considers the
uncertainty related to retirement planning for a jointly-owned
power plant. 2015 IRP at 125-130, 141-143. A 2019 North
Valmy 1 shutdown date is not within the complete control of
Idaho Power. NV Energy, Idaho Power's co-owner and the
operating partner of the North Valmy plant, has not indicated
that 2019 is an acceptable date to discontinue operations of
North Valmy Unit 1. Once an agreed upon retirement date
between the parties is determined, other actions are needed
in order to facilitate the plant retirement, such as regulatory
approval of an accelerated depreciation life of an asset.
Idaho Power and NV Energy will continue to work toward
synchronized depreciation dates and formalizing a mutually
agreed-upon retirement date.
As stated in the 2015 IRP, the goal of the qualitative risk
analysis is to select a portfolio likely to withstand unforeseen
events. 2015 IRP at 125. In addition to the risks associated
with the earlier retirement of a coal-fired generation unit, the
qualitative analysis included considerations for risks
associated with long-term sustainability of the Snake River
Basin, the relicensing of the Hells Canyon Complex,
eventual ramifications of the final Clean Air Act Rule 111 (d)
ruling, regulatory risk of future resource additions and
removals and associated allowance for return on investment,
resource commitment risk of developing PURPA projects
and the permitting of transmission lines, resource adequacy
of regional power supply, implementation of demand-side
management ("DSM") programs, and the development of
new technologies. In performing that analysis, along with
the relative magnitude of the financial cost between
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -11
I
I
portfolios and the potential immediate impact on customer
rates associated with an earlier North Valmy retirement,
Idaho Power's 2015 IRP identified portfolio P6(b) as the
preferred portfolio; the Company considers it to be preferred
choice in balancing cost, risk, and environmental concerns.
2015 IRP at 130.
Given the uncertainty that exists with the assumptions
included in all of the resource portfolios analyzed as part of
this IRP, the Company does not believe it would be
reasonable or prudent to retire an existing resource with
known fixed costs resulting in an immediate need for
additional cost recovery from customers. The planned
retirement of both North Valmy units in 2025 is a lower risk
option than a planned retirement of the Valmy unit in 2019
that will contribute to near-term rate stability and represents
a reasonable glide path toward reduced coal generation on
Idaho Power's system.
Additionally, as reported on page 130 of the Idaho Power 2015 IRP:
On the basis of the 2015 IRP's quantitative and qualitative
analysis, the preferred portfolio selected by Idaho Power is
P6(b). P6(b) balances the cost, risk, and environmental
concerns identified in this IRP. The retirement of the North
Valmy plant and the completion of 82H in 2025 balances the
risks of CAA Section 111 (d), increases in unplanned
intermittent and variable generation, and is shown to be cost
competitive. P6(b) also includes the addition of 60 MW of
demand response and 20 MW of ice-based TES in 2030. In
2031 , P6(b) also adds a 300-MW CCCT. These resource
additions late in the planning period address projected needs
for resources providing peaking capability and system
flexibility. With expected long-term expansion of variable
energy resources , the need for dispatchable resources that
provide system flexibility will also increase.
d. As described in the Idaho Power 2015 IRP on page 116:
Among the sensitivities developed for the 2015 IRP, Idaho
Power selected a baseline sensitivity for the initial portfolio
cost analysis. The baseline CAA Section 111 (d) portfolio
cost analysis assumes state-by-state mass-based
compliance with Langley Gulch constrained at a 30 percent
annual capacity factor. The selection of these assumptions
for the baseline analysis is not a reflection of Idaho Power's
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -12
preference for CAA Section 111 (d), nor is it an indication of
the company's view of the most probable CAA Section
111 (d) outcome. Rather, it is selected to provide information
in comparing costs between portfolios. The baseline costs
identify portfolios for further analysis under other CAA
Section 111 (d) sensitivities and for the stochastic risk
analysis. The results of the baseline CAA Section 111 (d)
sensitivity analyses are provided in Table 9.3.
The resource portfolios with greater baseline costs were not selected for the
advanced Clean Power Act ("CAA") Section 111 (d) sensitivity analysis that is presented
in Table 9.4 of the Idaho Power 2015 IRP. The resource portfolios with the higher
baseline costs that were not selected for the advanced CAA Section 111 (d) sensitivity
analysis are identified with the phrase "Baseline Costs too High" in Table 9.4.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -13
REQUEST NO. 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 pg_ 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.
RESPONSE TO REQUEST NO. 1-9:
a. Please see the confidential Excel file provided on the confidential CD that
includes the Aurora model outputs in Excel format for portfolio P6(b) and pg
(Attachment 1 ). The confidential CD will be provided to those parties that have
executed the Protective Agreement in this matter.
b. Please see the Excel file provided on the non-confidential CD that
includes the Excel workbook for portfolio P6(b) and pg (Attachment 2).
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -14
REQUEST NO. 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."
a. Please confirm that CAA Section 111 (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?
RESPONSE TO REQUEST NO. 1-10:
a. The CAA Section 111 (d) regulation was finalized on August 3, 2015. On
February 9, 2016, the Supreme Court stayed implementation of the Clean Power Plan
("CPP") pending judicial review.
b. No. Idaho Power did not seek to optimize the coal unit shutdown
alternatives in light of the finalization of the CPP. Unit shutdowns are not required for
compliance with the CPP and compliance could be met with restricted generation from
the coal units. Idaho Power did analyze compliance scenarios based on restricted coal
and gas unit generation levels in the specific state the plants are located .
c. No. Idaho Power did not analyze coal unit shutdown alternatives for this
case in light of the CPP becoming final. Based on the final CPP and historical
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -15
generation, it appeared that the state of Nevada would be able to meet both the mass
and rate goals with North Valmy running until the end of 2025.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -16
REQUEST NO. 1-11: 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 Valmy? Provide the basis for this
response and any supporting studies.
e. What is Idaho Power Company's current estimated cost of transmission
mitigation for a 2019 retirement of both units at Valmy? Provide the basis for this
response and any supporting studies.
RESPONSE TO REQUEST NO. 1-11:
a. Several alternatives have been considered by Idaho Power regarding
Valmy and Jim Bridger unit retirements and the resource treatment of the transmission
associated with these coal units. However, no studies have been conducted by or on
behalf of the Company. These alternative resource treatments of existing transmission
will be studied in the 2017 IRP.
b. Please see the Company's response to Sierra Club and ICL's Request
No. 1-11 .a, above.
c. The Company has not prepared any studies.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -17
d. Idaho Power does not have an estimated cost of transmission mitigation
for a 2019 retirement of one unit at Valmy. The existing transmission is not expected to
be decommissioned and removed upon termination of coal-fired operations at Valmy.
e. Idaho Power does not have an estimated cost of transmission mitigation
for a 2019 retirement of both units at Valmy.
The response to this Request is sponsored by Tom Harvey, Planning Resource
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -18
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 1-12:
a. In the Company's response to the Idaho Irrigation Pumpers Association,
lnc.'s Request No. 10, the Company provided links to its 2013 IRP and 2013 Coal
Study. Additionally, the Company's 2015 IRP performed an economic analysis of
potential resource portfolios which included North Valmy.
b. Idaho Power's 2015 IRP and Appendices A, B, and C, along with the IRP
Advisory Council (IRPAC) presentations, are located on Idaho Power's website via the
following link:
https://www.idahopower.com/AboutUs/PlanningForFuture/irp/2015/default.cfm.
c. Please see the confidential files provided on the confidential CD that were
used by the Company to develop the 2013 and 2015 IRPs and the Company's 2013
Coal Study. Due to the volume of files being provided in response to this Request, the
individual file names and the actual documents have not been labeled with the word
"confidential." However, the main file folder has been labeled confidential; all files
provided in response to this Request should be treated as confidential and handled
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -19
accordingly. The confidential CD will be provided to those parties that have executed
the Protective Agreement in this matter.
The response to this Request is sponsored by Tom Harvey, Planning Resource
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -20
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 1-13: To the best of my knowledge and belief,
there has been no electronic correspondence to lenders, banks, rating agencies,
bondholders, shareholders, or the like with respect to the economic value, useful life, or
depreciation date of North Valmy between 2013 and the present day. IDACORP
Investor Relations has a retention policy to not retain correspondence to outside parties
beyond six months.
To the best of my knowledge and belief, there have been a few presentations
with respect to the economic life, useful life, or depreciation date of North Valmy
between 2013 and the present day. IDACORP Investor Relations has a retention policy
to not retain presentations beyond one year. The following presentations are provided
on the non-confidential CD, in date order, as follows:
a. IDACORP, lnc.'s annual shareholder meeting transcript, dated May
19, 2016 (Attachment 1).
b. IDACORP, lnc.'s third quarter 2016 earnings conference call and
transcript, dated October 27, 2016 (Attachments 2 and 3). The full presentation can be
found at:
http://www.idacorpinc.com/-/media/Files/l/lDACorp/conference-calls/erwc3qpp2016.pdf.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -21
c. IDACORP, lnc.'s Edison Electric Institute Financial Conference
presentation, dated November 6-9, 2016 (Attachment 4). The full presentation can be
found at:
http://www.idacorpinc.com/-/media/Files/l/lDACorp/events/eei-financial-conference­
phoen ix-az-nov-6-9-2016. pdf.
d. IDACORP, lnc.'s Investor Meetings presentation, dated December
6, 2016 (Attachment 5). The full presentation can be found at:
http://www. idacorpinc. com/-/med ia/Files/1/1 DACorp/events/i nvestor-meetings-nyc-dec-2016. pdf.
e. IDACORP, lnc.'s Wells Fargo Energy Symposium presentation,
dated December 7, 2016 (Attachment 6). The full presentation can be found at:
http://www.idacorpinc.com/-/media/Files/l/lDACorp/events/wells-fargo-energy-symposium­
nyc-dec-2016.pdf.
The response to this Request is sponsored by Justin S. Forsberg, Director of
Investor Relations, IDACORP, Inc., and Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -22
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 1-14: The IRP is the primary strategic planning
document for North Valmy produced by Idaho Power. Idaho Power prepares the IRP
every two years as its primary resource strategic planning document. The recently
completed 2015 IRP and the 2013 IRP update provided in the links below are the
resource strategic planning documents completed since 2013 which included North
Valmy. There were no other strategic planning documents for North Valmy provided by
a third party on behalf of Idaho Power. The Company is also not aware of any strategic
planning documents for North Valmy that may have been produced by or on behalf of
NV Energy.
https://www.idahopower.com/AboutUs/PlanningForFuture/irp/2013/default.cfm
https://www.idahopower.com/AboutUs/PlanningForFuture/irp/2015/default.cfm
The response to this Request is sponsored by Tom Harvey, Planning Resource
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -23
REQUEST NO. 1-15: Regard contracts for fuel at North Valmy 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.
RESPONSE TO REQUEST NO. 1-15: The confidential spreadsheet provided on
the confidential CD shows the coal contracts signed between 2005 and the present day,
showing the source, minimum annual take, fixed price, and term length of each contract.
The confidential CD will be provided to those parties that have executed the Protective
Agreement in this matter.
The response to this Request is sponsored by Tom Harvey, Planning Resource
and Operations Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -24
REQUEST NO. 1-16: Provide any currently active contracts for the procurement
and/or transportation of coal at North Valmy station.
RESPONSE TO REQUEST NO. 1-16: Please see the current confidential rail
contract for North Valmy with the Union Pacific Railroad (Attachment 1) and the
confidential contract rate adjustment notification (Attachment 2) provided on the
confidential CD. Idaho Power does not have any active contracts for procurement of
coal for the North Valmy station. The confidential CD will be provided to those parties
that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Tom Harvey, Planning Resource
and Operations Director, Idaho Power Company.
DATED at Boise, Idaho, this 30th day of December 2016.
ft!t+ll ~~ IBA . NORDST OM
Attorney for ldah:=rCompany
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -25
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 301h day of December 2016 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION
LEAGUE upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Camille Christen
Deputy Attorney General
Idaho Public Utilities Commission
4 72 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Micron Technology, Inc.
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Brian T. Hansen
HOLLAND & HART, LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, Colorado 80111
Pete Bennett
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
_lL Hand Delivered
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X Email camille [e-mail]
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_lL Email [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
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_lL Email [e-mail]
[e-mail]
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE-26
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
Sierra Club
Travis Ritchie
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
United States Department of Energy and
Federal Executive Agencies
Steven Porter
Office of the General Counsel (GC-76)
The United States Department of Energy
1000 Independence Avenue, SW (Room 6D-033)
Washington, D.C. 20585
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_x_ Email steven [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF DATA
REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE -27