20170317Staff 31-36 to IPC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. IOI77
-r :-llEiVID
, ,, j ;,i..1 i ? Pi! l: 30
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 F'OR AUTHORITY
TO INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS ASSOCIATED
WITH THE NORTH VALMY PLANT.
CASE NO. IPC.E.I6.24
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey 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
FRIDAY, APRIL 7,2017.
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
person preparing 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.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY
)
)
)
)
)
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MARCH I7,2OI7
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. 31: Please provide a description of the categories of cost included in
the Fixed Cost column reflected in Harvey Exhibit No. 6. For each forecasted year, please
provide a breakdown of fixed costs by Valmy Unit #1, Valmy Unit#2, and Valmy common
facilities and then further broken down by cost category and/or identified by FERC account.
REQUEST NO.32: Please provide the same breakdown of costs provided as a result of
the previous request but using a2019 Valmy Unit #1 and2025 Valmy Unit#2 closure scenario.
REQUEST NO.33: Please provide Valmy plant annual operation and maintenance
expense currently embedded in base rates broken out by FERC account.
REQUEST NO.34: Please provide actual Valmy plant operations and maintenance
expense broken out by FERC account for the past 12 months.
REQUEST NO. 35: Exhibit No. 6 of Mr. Harvey's Testimony shows total power supply
costs generated by AURORA. Please provide the version of AURORA software used and
provide all AURORA files and other worksheets (with formula intact) associated with the
calculation.
REQUEST NO. 36: Idaho Power's Response to Staff s Production Request No. 2 states
that a supplemental analysis is being prepared for filing to help clarify the differences between
the December 31, 2019, and December 31, 2025, Valmy Unit #1 shutdown dates. Please provide
the version of AURORA software used in the analysis and provide all AURORA files and other
worksheets (with formula intact) associated with the calculation.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY )MARCH I7,2OI7
Dated at Boise, Idaho, this I ?
Technical Staff: Rick Keller (31-34)
Yao Yin (35-36)
i:umiscprodre{ipcel5.24ccdryy prod rcq4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY
{i-vr
day of Marchz0l7.
tn** t,L**e*-
carhitte Christen
Deputy Attomey General
3 MARCH I7,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF MARCH 2017,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, N 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 6119
POCATELLO ID 83205
E-mail: [e-mail]
BEN OTTO
ENERGY ASSOCIATE
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-mail: [e-mail]
THORVALD A NELSON
ET AL
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIR
STE 5OO
GREENWOOD VILLIAGE CO 8OI I I
E-mail: [e-mail]
fschmidt@.ho llandhan. com
[e-mail]
bthansen@hollandhart. com
MATTHEW T. LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVE
I.INIT 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]
[e-mail]
kmtrease @hollandhart. com
CERTIFICATE OF SERVICE
TRAVIS RITCHIE
ASSOCIATE ATTORNEY
SIERRA CI,UB
2IOI WEBSTER ST STE I3OO
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.sov
,-l- /l"A*,
sEcRErAaY/
CERTIFICATE OF SERVICE