20170302IPC to ICL & Sierra Club Redacted 2-1 to 2-10.pdf

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LISA D. NORDSTROM
Lead Counsel
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March 2,2017
VIA HAND DELIVERY
Diane Hanian, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-16-24
Recovery of Costs Associated with North Valmy Power Plant - ldaho Power
Company's Response to the Second Set of Data Requests of the Siena Club
and the ldaho Conservation League
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Redacted Response to the Second Set of Data Requests of the
Sierra Club and the ldaho Conservation League. Also enclosed for filing are an original
and three (3) copies of ldaho Power Company's Gonfidential Responses to the ldaho
Conservation League and the Sierra Club's Production Request Nos. 2-5, 2-6, 2-7, and
2-9.
ln addition, enclosed are four (4) copies of a confidential disk containing
information responsive to the Siena Club and the ldaho Conservation League's data
requests. Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.
truly yours,
LDN:kkt
Enclosures
P.O. Box 70 (83707)
1221 W. ldaho 5t.
Boise, lD 83702
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ ida hopower. co m
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Attomey for ldaho 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
GASE NO. IPC-E-16-24
IDAHO POWER GOMPANY'S
REDACTED RESPONSE TO THE
SECOND SET OF DATA
REQUESTS OF THE SIERRA
CLUB AND THE IDAHO
CONSERVATION LEAGUE
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the Second Set of Data Requests of the Siena Club and the Idaho
Conservation League to ldaho Power Company dated February 9, 2017, herewith
submits the following information:
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 1
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REQUEST NO. 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.
RESPONSE TO REQUEST NO. 2-1: Please see the Company's response to
Staffs Request No. 1 for the workpapers in Excel with formulae and links intact
underlying Exhibit 6.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 2
REQUEST NO. 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 ldaho Power Company's most recent (i.e. as of today) natural gas
price forecast.
d. To the extent that ldaho 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.
RESPONSE TO REQUEST NO. 2.2:
a. Please see the Company's response to Staffs Request No. 14.
b. The 2016 Henry Hub forecast from the EIA Annual Energy Outlook 2016
released September 2016.
c. The 2016 Henry Hub forecast referred to in b above is the most recent
long-term natural gas forecast. The long-term forecast was set with the annual EIA
publication and will not be updated until the next EIA publication in the fall of 2017.
d. ldaho Power has not prepared a new AURORA analysis for the purposes
of evaluating the Valmy Plant. However, a supplemental analysis as described in the
response to Staffs Request No. 2.i. wil! be filed and will include updated assumptions in
line with the 2017 lRP. The Company expects to provide the results of the
Supplemental Analysis as a supplemental response to Staffs Request no Iater than the
end of March 2017.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 3
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 4
REQUEST NO. 2-3: Please refer to response to SC-ICL 1-7, describing that the
process used by ldaho Power Company to assess the economic value of North Valmy
is "very similar to the assessment of various portfolios within the lRP."
a. Has ldaho 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 lntegrated Resource Plan? A formal assessment here is defined as an analysis
resulting in an internal memorandum, presentation, white paper, or draft filing. lf not,
why not?
b. Has ldaho 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
20lS lntegrated Resource Plan? An informa! assessment would be a draft calculation or
analysis resulting in an intemal communication of any form. lf not, why not?
c. Provide any analyses conducted by ldaho 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 ldaho Power review the testimony or exhibits of NV Energy in its
2017-2036 Triennial lntegrated Resource Plan with respect to the treatment of North
Valmy? lf so, who at IPC reviewed the NV Energy filing, and which materials were
reviewed?
f. ls ldaho 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
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE.5
is likely to operate at or below a 5.5% capacity factor in every year between now and
2025? lf not, why not?
RESPONSE TO REQUEST NO. 2.3:
a. No. ldaho Power has not 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 lntegrated Resource Plan. However, ldaho Power is preparing a supplemental
analysis to be provided in response to Staff DR No. 2i. and as part of the 2017 lRP.
b. Yes. ldaho Power has informally assessed the economic value of North
Valmy.
c. The enclosed Confidential Excel Workbook to this response shows a
preliminary analysis in preparation for the 2017 lRP. The 2017 IRP is focused on
Boardman to Hemingway and Jim Bridger selective catalytic reduction investments.
The analysis forecasted various shutdown dates for Valmy and Jim Bridger Units and
the impact on the load and resource balance. The forecast results used 2015 IRP
assumptions and dated fixed cost assumptions therefore the results have not used
except in helping inform the impact of unit closures on costs and resource needs in
preparation for the 2017 lRP.
d. Please see the confidential attachment provided with this response.
e. Yes. ldaho Power did review portions of the NV Energy Triennial
lntegrated Resource Plan focusing on the treatment of North Valmy. Tom Noll PhD.,
Senior Planning Analyst, in Power Supply Planning reviewed the filing as posted on the
Nevada Public Utility Commission website.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 6
t. While Idaho Power has no opinion on the "likely operation" of NV Energy's
portion of the Valmy plant, ldaho Power agrees it is possible Valmy may operate at or
below 5.5o/o capacity factor in the yearc before 2025.
The confidentia! attachment 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, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 7
REQUEST NO. 24: 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 Life Span
Analysis Process Update.
a. Did NV Energy provide a Valmy Life Span Analysis, 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 ldaho Power Company with respect to a Valmy Life Span Analysis
on or after June 26,2014, up through the present day.
c. Aside from the 2015 lRP, has ldaho Power Company shared any form of
Life Span Analysis with respect to North Valmy after June 26,2014?
d. Provide any workbooks, presentations, whitepapers, or draft filings shared
by ldaho Power Company with Nevada Power Company with respect to a Valmy Life
Span Analysis on or after June 26, 2014, up through the present day.
RESPONSE TO REQUEST NO. 2.4:
a. NV Energy provided ldaho Power two Excel files on Life Span Analysis
Process ("LSAP") assumptions after June 26,2014. The files referenced in this request
were independently prepared by NV Energy for use in NV Energy's LSAP and provided
to ldaho Power for informational purposes only. These files are provided as confidential
Attachments 1 and 2 on the confidential CD.
b. PIease see confidential Attachments 1 and 2 provided on the confidential
cD.
c. No.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 8
d. Please see the response to c.
The confidential attachments 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, ldaho Power Company.
]DAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE.9
REQUEST NO. 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 Life Span Analysis
Process Update with attachment "Valmy LSAP assumptions v3.xlsx"
a. Did ldaho Power Company make any changes or recommendations to
change this workbook? lf not, did ldaho Power Company approve of the assumptions
made in this workbook?
b. Provide any correspondence or feedback from ldaho Power Company
back to NV Energy with respect to LSAP assumptions after July 14, 2014, or document
the nature of phone calls with respect to the LSAP conducted at this time between Mr.
Harvey and Mr. Shil, or their representatives.
c. Refer to the attachment, tab "lnfra," line 25 with respect to
I Does ldaho Power Company agree that are
not sustainable at North Valmy? !f so, what exactly does this mean to IPC? lf not, why
not? Provide supporting evidence.
d. Refer to the attachment, tab "lnfra," lines 27 and 28 with respect to f
I. Does ldaho Power Company agree are not sustainable
at North Valmy? lf so, what exactly does this mean to IPC? If not, why not? Provide
supporting evidence.
e. Refer to the attachment, tab "lnfra," line 34 with respect to I
Does ldaho Power Company agree that Valmy is
lf not, why not? Provide
supporting evidence and any studies conducted by lPC demonstrating that such f
by Valmy.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 1O
RESPONSE TO sT NO. 2-5:This request refers to an email dated July
14, 2014; however, after review of previously provided information, ldaho Power
believes this request was intended to reference an emai! dated July 10, 2014, and has
prepared its response accordingly. Additionally, the file referenced in this request was
independently prepared by NV Energy for use in NV Energy's LSAP and was provided
to ldaho Power for informational purposes only.
a. No. ldaho Power did not make any changes or recommendations, nor did
it approve any of the assumptions made in this workbook.
b. No correspondence or feedback occurred with respect to these LSAP
assumptions after July 1O,2014.
c-e. As discussed above, the file referenced in this request was independently
prepared by NV Energy, and the Company did not provide feedback with regard to the
assumptions contained in this file, nor did it approve any of these assumptions.
Therefore, ldaho Power has not formed an opinion with respect to ther,""or assumptions as
co nta ined i n the above-referenced attachment.
The confidential response 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
& Operations Director, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE. 11
REQUEST NO. 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 emai! in this chain from Kevin Geraghy on April 15 at 9:52
AM with respect to a by NV Energy
a. Please provide a!! conespondence between ldaho Power Company and
NV Energy with respect to this
I Provide correspondence at any level of management, executive or
otherwise.
b. Please provide all intema! conespondence at ldaho Power Company with
respect to this
RESPONSE TO REQUEST NO. 2.6:
a. These particular conversations related to whether NV Energy had an
interest in NV
Energy determined
Please refer to the May 2, 2016, email in this
chain from Kevin Geraghty related to NV Energy's decision to
b. There is no additional intemal correspondence responsive to this request.
The confidential response 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, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 12
REQUEST NO. 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.
Cal!.
a. Please refer to the first email in this chain from Mr. Harvey on April 15 at
8:44 AM. What is the OPC refened to in this email? Provide a copy of the OPC with
Mr. Harvey's redlines, and a final copy of the OPC.
b. Refer to the email in this chain from Kevin Geraghy on April 15 at 9:52
AM. Did ldaho Power ever receive a formal or informal from NV Energy?
Please describe the nature of the initia!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 "capacity requirements" discussed here, and include
any supporting documentation or workpapers as used or considered by the Company at
such time.
d. Refer to the email in this chain from Mr. Geraghy on May 2 at 10:46 AM.
Did IPC consider lf 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.
RESPONSE TO REQUEST NO. 2.7:
a. The "OPC" is the Operating Procedures Criteria for the North Valmy
Station. Please see confidential Attachment 1 which includes the redlines on the
confidential CD. A final OPC has not yet been negotiated to completion.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 13
b. Idaho Power did not receive a
see the Company's response to Request No. 2-6 above.
c. As part of the discussion of
Please
and as such there are no supporting
documentation or workpapers.
d. No. Please see the response to b above.
e. lt was agreed, internally, to cancel the call and set one up when the OPC
redline was complete. The internal continuation of the confidential emai! string being
discussed in this request is provided as confidential Attachment 2 on the confidential
CD. This intemal continuation was not provided in earlier discovery as it was not
between NV Energy and ldaho Power.
The confidential response and attachments wi!! 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, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 14
REQUEST NO. 2-8:Please refer to SC-ICL 5 Attach 1 Conf., email from Rick
Haender [sic/ to Tom Harvey on January 5, 2016, subject RE: RE: Valmy Life
Assessment Analysis.
a. Did the Gompany have discussions intemally with respect to earlier Valmy
Unit shutdowns as a result or following this email? lf 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 earlier Valmy
Unit shutdowns as a result or following this email? lf so, describe the nature of those
discussions and provide any notes or memoranda memorializing such discussions.
RESPONSE TO REQUEST NO. 2.8:
a. No internal discussions about an earlier than 2019 shutdown resulted from
orfollowed this email.
b. No discussions with NV Energy about an earlier than 2019 shutdown
resulted from or followed this email.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 15
REQUEST NO. 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 Iabor agreement(s) with North Valmy employees as a function
of the Company's changing use of the power plant?
b. Has ldaho 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. lf 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. lf the answer to either (a) or (b) above is affirmative, provide the contract
prior to any negotiation or appea!, and the contract resulting from such negotiation or
appeal, if available.
e. Provide the annua! 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.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE. 16
RESPONSE TO REQUEST NO. 2.9:
a. Yes. On October 15, 2014, a Letter of Agreement was signed, which
restructured generation employees' job classifications. The Letter of Agreement is
provided as confidentialAttachment 1 on the confidential CD.
b. No.
c. The Company revised certain job classifications to allow flexibility for
cross-training and enhance plant reliability. Negotiations were conducted between
March 2013 and October 15, 2014, the date of the Letter of Agreement.
d. The collective bargaining agreement remained the same - all that was
added was the Letter of Agreement. The origina! collective bargaining agreement is
provided as confidentialAttachment 2 on the confidential CD.
e. The average number of full-time workers at North Valmy from 2008
through 2016 was !.
f. Cunently there are ! full-time workers at North Valmy. Employment is
expected to by 2025
The confidential response and attachments 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, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REOUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE- 17
REQUEST NO.2.1O:
a. Has Nevada Energy, at any time, alleged default or the potential of default
to IPC?
b. Has lPG, at any time, alleged default or the potentia! of default to Nevada
Energf
c. !f either of the above is affirmative, provide the notice of the alleged
default and the response from the allegedly defaulting party.
RESPONSE TO REQUEST NO. 2.10:
a. No.
b. No.
c. PIease refer to the responses to a. and b.
The response to this Request is sponsored by Tom Harvey, Resource Planning
and Operations Director, ldaho Power Company.
DATED at Boise, ldaho, this 2nd day of March 2017.
*uA
SA D. NORDSTROM
Attorney for ldaho Power Com ny
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 18
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of March 2017 I served a true and
conect copy of IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
SECOND 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 Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Micron Technology, lnc.
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 FederalWay
Boise, ldaho 83707
ldaho lrrigation Pumpers Association, lnc.
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
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[e-mail]
etcocian@holland hart.com
bhansen@holland hart. com
klhal l@hol land hart.com
kmtrease@ hol land hart. com
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x Email camille.ch .idaho.oov
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE - 19
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, ldaho 83701
Sierra Club
Travis Ritchie
Siena Club
2101 WebsterStreet, Suite 1300
Oakland, Califomia 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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Assistant
6
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SECOND SET OF
DATA REQUESTS OF THE SIERRA CLUB AND THE IDAHO CONSERVATION LEAGUE-20