20170210ICL & Sierra Club 2-1 to 2-10 to IPC Redacted.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
COSTS VALMY PLANT
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CASE NO. IPC-E-16-24 SECOND SET OF DATA
REQUESTS OF SIERRA CLUB
AND IDAHO CONSERVATION
LEAGUE TO IDAHO POWER COMPANY [REDACTED]

Sierra Club and Idaho Conservation League (“ICL”) hereby serve their redacted second 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 of
21 days, which is March 2, 2017.

INSTRUCTIONS
1. Please provide copies of responses to the following contacts:
Sierra Club Law Program 2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]
Sierra Club Law Program 2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]
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.
10. 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.

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 REDACTED Second Set of Data Requests to Idaho Power Company February 9, 2017

DATA REQUESTS

SC/ICL 2-1. Provide all workpapers underlying Exhibit 6 of Mr. Harvey’s Direct Testimony,
including any Excel workpapers, in “as-utilized” form, unlocked and with formulae and
links intact, and model run input and output files as per the format of SC-ICL 9a.

SC/ICL 2-2. Refer to the Direct Testimony of Mr. Harvey, page 16 at 20-21.
a. Provide the “most recent load forecast, natural gas forecast, and Valmy coal
price forecast,” as used in this assessment.
b. Provide the source of the natural gas price forecast.
c. Provide Idaho Power Company’s most recent (i.e. as of today) natural gas price
forecast.
d. To the extent that Idaho Power Company has run Aurora with a more recent
natural gas price forecast than used in this filing, provide this Aurora run as per
the format in SC-ICL 9a.

SC/ICL 2-3. Please refer to response to SC-ICL 1-7, describing that the process used by Idaho Power
Company to assess the economic value of North Valmy is “very similar to the assessment
of various portfolios within the IRP.”
a. Has Idaho Power formally assessed the economic value of retiring either unit of
North Valmy in any year prior to 2025 at any time since the submission of the 2015 Integrated Resource Plan? A formal assessment here is defined as an
analysis resulting in an internal memorandum, presentation, white paper, or
draft filing. If not, why not?
b. Has Idaho Power informally assessed the economic value of retiring either unit of North Valmy in any year prior to 2025 at any time since the submission of the 2015 Integrated Resource Plan? An informal assessment would be a draft
calculation or analysis resulting in an internal communication of any form. If
not, why not?
c. Provide any analyses conducted by Idaho Power with respect to the economic value of maintaining or retiring either unit of North Valmy in any year prior to 2025 since the submission of the 2015 Integrated Resource Plan.
d. Provide the workpapers supporting such analysis if conducted.
e. Did Idaho Power review the testimony or exhibits of NV Energy in its 2017-
2036 Triennial Integrated Resource Plan with respect to the treatment of North
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 REDACTED Second Set of Data Requests to Idaho Power Company February 9, 2017

Valmy? If so, who at IPC reviewed the NV Energy filing, and which materials
were reviewed?
f. Is Idaho Power Company in agreement with NV Energy’s assessment (as per that filing’s public Exhibit ECON-3, IRP Volume 12 pages 92-122) that North
Valmy is likely to operate at or below a 5.5% capacity factor in every year
between now and 2025? If not, why not?

SC/ICL 2-4. Please refer to SC-ICL 5 Attach 1 Conf., email from Gaurav Shil (NVE) to Tom Harvey
on June 26, 2014, subject FW: FW: Valmy Update.
a. Did NV Energy provide a Valmy , draft or otherwise, of any
form, including workbooks, presentation, whitepaper, or draft filing, at any date
after June 26, 2014?
b. Provide any workbooks, presentations, whitepapers, or draft filings shared by NV
Energy with Idaho Power Company with respect to a Valmy
on or after June 26, 2014, up through the present day.
c. Aside from the 2015 IRP, has Idaho Power Company shared any form of
with respect to North Valmy after June 26, 2014?
d. Provide any workbooks, presentations, whitepapers, or draft filings shared by
Idaho Power Company with Nevada Power Company with respect to a
on or after June 26, 2014, up through the present day.

SC/ICL 2-5. Please refer to SC-ICL 5 Attach 1 Conf., email from Gaurav Shil (NVE) to Tom Harvey
on July 14, 2014, subject RE: RE: Valmy Update with
attachment “Valmy assumptions v3.xlsx”
a. Did Idaho Power Company make any changes or recommendations to change this
workbook? If not, did Idaho Power Company approve of the assumptions made in
this workbook?
b. Provide any correspondence or feedback from Idaho Power Company back to NV
Energy with respect to assumptions after July 14, 2014, or document the
nature of phone calls with respect to the conducted at this time between
Mr. Harvey and Mr. Shil, or their representatives.
c. Refer to the attachment, tab “Infra,” line 25 with respect to
Does Idaho Power Company agree that owned water rights and supplies
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 REDACTED Second Set of Data Requests to Idaho Power Company February 9, 2017

are not sustainable at North Valmy? If so, what exactly does this mean to IPC? If
not, why not? Provide supporting evidence.
d. Refer to the attachment, tab “Infra,” lines 27 and 28 with respect to
. Does Idaho Power Company agree are not sustainable at
North Valmy? If so, what exactly does this mean to IPC? If not, why not? Provide
supporting evidence.
e. Refer to the attachment, tab “Infra,” line 34 with respect to
Does Idaho Power Company agree that Valmy is
If not, why not? Provide supporting
evidence and any studies conducted by IPC demonstrating that such
by Valmy.

SC/ICL 2-6. Please refer to SC-ICL 5 Attach 1 Conf., email from Tom Harvey to Tessia Park and Lisa
Grow on May 2, 2016, subject FW:FW: April 19 Conf. Call. Refer specifically to the
email in this chain from Kevin Geraghy on April 15 at 9:52 AM with respect to a
by NV Energy.
a. Please provide all correspondence between Idaho Power Company and NV
Energy with respect to this
. Provide correspondence at any level of management, executive or
otherwise.
b. Please provide all internal correspondence at Idaho Power Company with respect
to this .

SC/ICL 2-7. Please refer to SC-ICL 5 Attach 1 Conf., email from Tom Harvey to Tessia Park and Lisa
Grow on May 2, 2016, subject FW:FW: April 19 Conf. Call.
a. Please refer to the first email in this chain from Mr. Harvey on April 15 at 8:44
AM. What is the referred to in this email? Provide a copy of the with
Mr. Harvey’s redlines, and a final copy of the
b. Refer to the email in this chain from Kevin Geraghy on April 15 at 9:52 AM. Did
Idaho Power ever receive a formal or informal from NV Energy?
Please describe the nature of the initial referred to here.
c. Refer to the email in this chain from Mr. Harvey on May 2 at 6:48 AM. Please
describe the nature of the “” discussed here, and include any
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 REDACTED Second Set of Data Requests to Idaho Power Company February 9, 2017

supporting documentation or workpapers as used or considered by the Company
at such time.
d. Refer to the email in this chain from Mr. Geraghty on May 2 at 10:46 AM. Did
IPC consider ? If not, why not?
e. Refer to the top email in this chain from Mr. Harvey on May 2 at 12:59 PM.
Please describe the nature and outcome of the discussion or input provided in
response to this email. Provide any notes or memoranda documenting or
memorializing such discussion.

SC/ICL 2-8. Please refer to SC-ICL 5 Attach 1 Conf., email from Rick Haender to Tom Harvey on
January 5, 2016, subject RE: RE: Valmy Life Assessment Analysis.
a. Did the Company have discussions internally with respect to
as a result or following this email? If so, describe the nature of those
discussions and provide any notes or memoranda memorializing such discussions.
b. Did the Company have discussions with NVE with respect to
as a result or following this email? If so, describe the nature of those
discussions and provide any notes or memoranda memorializing such discussions.

SC/ICL 2-9. Refer to the Direct Testimony of Mr. Tom Harvey, page 12 at 3 through 9, with respect to
the Company’s changing use of Valmy (i.e. capacity rather than off-system sales).
a. Has Idaho Power or NV Energy at any time since January 2014 sought to change
the nature of the labor agreement(s) with North Valmy employees as a function of
the Company’s changing use of the power plant?
b. Has Idaho Power of NV Energy at any time since January 2014 sought to change
the nature of the labor agreement(s) with North Valmy employees for any other
reason aside from the changing use of the power plant?
c. If the answer to either (a) or (b) above is affirmative, please describe what the
Company has sought to change, and the reason why the Company has sought such
change, including dates of negotiations or new contracts.
d. If the answer to either (a) or (b) above is affirmative, provide the contract prior to
any negotiation or appeal, and the contract resulting from such negotiation or
appeal, if available.
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 REDACTED Second Set of Data Requests to Idaho Power Company February 9, 2017

e. Provide the annual number of full time workers employed at the North Valmy site
by either the Company or NV Energy from 2008 through 2016.
f. Provide the projected annual number of full time workers expected to be
employed at the North Valmy site by either the Company or NV Energy from
2017 to 2025.

SC/ICL 2-10. Please refer to the response to IPL-SC DR 1-3 (Operating Agreement).
a. Has Nevada Energy, at any time, alleged default or the potential of default to
IPC?
b. Has IPC, at any time, alleged default or the potential of default to Nevada
Energy?
c. If either of the above is affirmative, provide the notice of the alleged default and
the response from the allegedly defaulting party.

CERTIFICATE OF SERVICE
I hereby certify that on this 9th day of February 2017, I delivered true and correct copies of the foregoing SECOND SET OF DATA REQUESTS OF SIERRA CLUB AND IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY [REDACTED] to the following
persons via electronic mail:

Commission Secretary
Idaho Public Utilities Commission
[e-mail] [e-mail]
Idaho Power Lisa D. Nordstrom
Matt Larkin
Idaho Power Company [e-mail] [e-mail]
[e-mail]
IIPA Eric L. Olsen
ECHOHA WK & OLSEN, PLLC
[e-mail]

Anthony Yankel [e-mail]

Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Brian T. Hansen
Holland & Hart, LLP [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail] [e-mail]
[e-mail]

MICRON Pete Bennett
Micron Technology, Inc.

DOE Steven Porter
United States Department of Energy

/s/ Alexa Zimbalist
Alexa Zimbalist Legal Assistant
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]