20170310Staff 29-30 to IPC.pdf

CAMILLE CHzuSTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. TOI77
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS ASSOCIATED
WITH THE NORTH VALMY PLANT.
CASE NO. IPC.E-I6.24
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Camille Christen, Deputy Attorney General, request that Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, or by
FRTDAY, MARCH 24, 2017.r
This Production Request is continuing, and Idaho Power is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question and supporting workpapers that provide detail or
are the source of information used in calculations. Idaho Power is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 MARCH IO,2OI7
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person prepadng the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 29: Please provide an explanation for the calculation of all income tax
inputs, including the deferred income tax amounts in the detail worksheets for Exhibit 2. Please
provide all supporting documentation, calculations, and source documents. In addition, please
provide a narrative description for, and calculation of, the "Reversing Flow-Through Allocation"
with a rate of 39.93%. Please provide the source documents for the various tax rates used in the
spreadsheet.
REQUEST NO.30: Please quantify the dollar revenue requirement difference between
the Company's proposal to accelerate Valmy depreciation rates, and leaving the currently-
approved depreciation rates in place, i.e. no acceleration, regardless of the actual retirement dates
for Valmy 1 and Valmy 2 under each of the following scenarios:
a. Including full recovery of the forecasted capital additions and including
decommissioning costs, with Valmy I scheduled for retirement as currently planned
in2031 and Valmy 2 scheduled for retirement as currently planned in2035.
b. Without including recovery of the forecasted capital additions but including
decommissioning costs, with Valmy retiring at203l as currently scheduled and
Valmy 2 retiring at2035 as currently scheduled.
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Dated at Boise, Idaho, this 10 day of March2017
0r^-r,l* (r}rn^
Camille Christen
Deputy Attorney General
Technical Staff: Kathy Stockton (29-30)
i:umisc:prodreq/ipcel6.24ccmlmerksd prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MARCH IO,2OI7
CERTIFICATE OF' SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IOth DAY OF MARCH 2017,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
coMMrssloN STAFF TO IDAHO POWER, IN CASE NO. IPC-E-16-24, By
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : [e-mail]
[e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l 19
POCATELLO ID 83205
E-mail: [e-mail]
BEN OTTO
ENERGY ASSOCIATE
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE TD 83702
E-mail: [e-mail]
THORVALD A NELSON
ET AL
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIR
STE 5OO
GREENWOOD VILLIAGE CO 80111
E-mail : [e-mail]
fschmidt@hollandhart. com
etcocian@hollandhart. com
bthansen@hol landhart. com
MATTHEW T. LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-mail: [e-mail]
PETE BENNETT
MICRON TECHNOLOGY INC
SOOO S FEDERAL WAY
BOISE ID 83707
E-mail: [e-mail]
E-MAIL ONLY
[e-mail]
klhall @hollandhan. com
kmtrease @hollandhart. com
CERTIFICATE OF SERVICE
TRAVIS RITCHIE
ASSOCIA]E ATTORNEY
SIERRA CLI.'B
2IO1 WEBSTER ST STE 13OO
OAKLAI{D CA946I2
E-mail: [e-mail]
STEVEN PORTER
US DEPT OF ENERGY
IOOO INDEPENDENCE AVE SW
ROOM 6D-033
WASHINGTON DC 20585
E-mail: steven.porter@hq,doe. gov
CERTIFICATE OF SERVICE