20170301ICL and Sierra Club Redacted 3-1 to 3-2 to IPC.pdf

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

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CASE NO. IPC-E-16-24

THIRD 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 third 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 22, 2017.

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

Alexa Zimbalist
Sierra Club Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[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.
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 Third Set of Data Requests to
Idaho Power Company
March 1, 2017

DATA REQUESTS

SC/ICL 3-1. Reference the Company’s Response to Sierra Club-ICL’s Request No. 6, Confidential
Attachment. With regard to the meeting agenda dated February 26, 2016:

a. Identify all of the individual meeting participants, including from Idaho Power
Company and from . Please include titles and employers for each
individual.
b. Please describe in detail the discussion on item 1 listed in the agenda, the

i. What was the proposal? (ie. Dates, costs, etc.)
ii. Who made the initial proposal
iii. What was Idaho Power Company’s position with regard to this issue?
iv. What was stated position in the meeting with regard to this
issue?
v. What resolution, if any, did the parties reach?
vi. If no resolution was reached, what were the next steps identified and/or what
barriers prevented resolution?
c. Since the February 26, 2016 meeting, have any further discussions or developments
taken place with respect to a proposed unit closure at North Valmy? If so, please
describe and provide any documentation of such developments.

SC/ICL 3-2. Reference the Company’s Response to Sierra Club-ICL’s Request No. 6, Confidential
Attachment. With regard to the meeting agenda for a call dated October 18, 2016:

a. Identify all of the individual meeting participants, including from Idaho Power
Company and from . Please include titles and employers for each
individual.
b. Did the parties at this meeting discuss the appropriate retirement date for North
Valmy? If yes, what specific dates were discussed?
c. To the best of Idaho Power’s recollection, please describe the details of the

d. To the best of Idaho Power’s recollection, please describe
e. To the best of Idaho Power’s recollection, please describe
f. What alignment and next steps were reached?
g. Since the October 18, 2016 meeting, have any further discussions or developments
taken place with respect to any of the topics discussed at that meeting? If so, please
describe and provide any documentation of such developments.

CERTIFICATE OF SERVICE
I hereby certify that on this 1st day of March 2017, I delivered true and correct copies of the foregoing
THIRD SET OF DATA REQUESTS OF SIERRA CLUB AND IDAHO CONSERVATION
LEAGUE TO IDAHO POWER COMPANY [REDACTED] to the following persons via electronic
mail. A true and correct copy of the confidential version has been served via FedEx or U.S. Mail to
those persons who have signed the protective agreement.

Diane Hanian (C)
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
[e-mail]
Idaho Power
Lisa D. Nordstrom (C)
Matt Larkin (C)
Idaho Power Company
1221 W. Idaho St.
Boise, ID 83702
[e-mail]
[e-mail]
[e-mail]

Idaho Public Utilities Commission
Camille Christen (C)
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
[e-mail]

DOE
Steven Porter (C)
United States Department of Energy
Office of the General Counsel ( GC-76)
1000 Independence Ave., SW, Room 6D-
033 Washington, D.C. 20585
[e-mail]

IIPA
Eric L. Olsen
ECHOHA WK & OLSEN, PLLC
[e-mail]

Anthony Yankel (C)
12700 Lake Ave. Unit 2505
Lakewood, OH 44107
[e-mail]

MICRON
Thorvald A. Nelson (C)
Frederick J. Schmidt (C)
Emanuel T. Cocian (C)
Brian T. Hansen (C)
Holland & Hart, LLP
6380 S. Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

MICRON
Pete Bennett (C)
Micron Technology, Inc.
8000 S. Federal Way
Boise, ID 83707
[e-mail]

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