20170317Staff 15-24 to IPC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. IOI77
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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 O['
IDAHO POWER COMPANY FOR A
DETERMINATION OF HELLS CAI\IYON
COMPLEX RELICENSING COSTS THROUGH
2015 AS PRUDENTLY INCURRED.
CASE NO.IPC.E-I6.32
SECOND 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, by FRIDAY,
APRrL 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
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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I MARCH I7,2OT7
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. 15: In Chris Randolph's testimony (p. 20), he states the Collaborative
Team included over 100 organizational affrliations and Resource Work Groups that undertook
over 90 studies to evaluate the project-related impacts of Hells Canyon Complex (HCC)
operations. Please explain why it was necessary to complete over 90 studies and to include over
100 organizational affiliations on the Collaborative Team. Furthermore, please explain how the
Company used a least-cost approach to manage the relicensing process and to evaluate the
project-related impacts of HCC operations.
REQUEST NO. 16: In Chris Randolph's testimony (p. 20), he states that there were
over 90 studies to evaluate the project-related impacts of HCC operations. If some of these
studies are not outlined in Exhibit No. 2, please explain the purpose of the study. Please also
provide the cost of each study, including those shown in Exhibit No. 2. Furthermore, please
explain the Company's criteria for determining if studies were "reasonable and necessary," as
shown for the first step of the second stage.
REQUEST NO. 17: In Tim Tatum's testimony (p. 11), he states "Assuming total HCC
relicensing costs of $400 million and 1,167 MW generating capacity,Idaho Power estimates the
HCC cost per kilowatt ("kW") is $358." Please provide the total estimated cost per kilowatt,
including investments that could be necessary to comply with long-term HCC relicensing
requirements. Please supply supporting workpapers with cost categories identified.
REQUEST NO. 18: In the Company's response to Audit Request No. 2(c), the
Company indicated that some contracts were destroyed in compliance with the Idaho Power
records retention policy. Please provide a list of all contracts destroyed that related to Hell's
Canyon relicensing efforts.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MARCH 17 ,2017
REQUEST NO. 19: In the Company's response to Audit Request No. 2(c), the
Company provide a copy of the contract with the Oregon Dept. of Fish and Wildlife (ODF&W)
The terms of the contract state that Idaho Power is to pay the full amount of the overdue
reauthorization fees, plus interest of 7o/o per annum from the date payments were originally due.
Please provide all overdue llate payment fees, including interest charges.
REQUEST NO. 20: The Company's response to Audit Request No. 2(c) identifies the
terms of the contract that the reauthorization fee structure and the current fee structure may
change legislatively on January 1, 2000. Please provide any updates to the fee structures and the
dates that the updates became effective.
REQUEST NO. 21: In the Company's response to Audit Request No. 2(c), the contract
with ODF&W states that any studies or additional work undertaken by ODF&W at the request of
Idaho Power may require reimbursement and that those arrangements would be negotiated
separately. Please provide detailed narratives, including scope of work and costs, of any separate
negotiations that occurred with ODF&W.
REQUEST NO. 22: Please provide a description of the process on how labor costs are
assigned to work orders, including direct or indirect, as well as annualized vs. non-annualized
labor.
REQUEST NO.23: Please provide a list showing a summary of all consultants and
attorneys (internal and external) who have performed services for the HCC relicensing process
Please include services performed, accounts charges, and amounts paid.
REQUEST NO.24: Please provide details regarding the estimation of the $20-$30M
annual licensing cost on page 10, lines 13-20, of Tim Tatum's direct testimony.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY J MARCH 17 ,2017
Y
Dated at Boise,Idatro, this l+day of March 2017.
t *t^^;LlA
Camille Christen
Deputy Attorney General
Technical Staff: Matt Elam (15-17)
Haleena Ard (18-24)
i:umiscprodrcq/ipcel6.32cdramc prod rcq2
SECOND PRODUCTION REQI.JEST
TO IDAHO POWER COMPANIY 4 MARCH I7,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF MARCH 2017,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAY, IN CASE NO. IPC-E-16-32,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom(g)idahopower.com
[e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-mail: elodDechohawk.com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
BENJAMIN J OTTO
710 N 6TH STREET
BOISE TD 83702
E-mail: botto(@.idahoconservation.org
TIM TATUM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVE
LINIT 2505
LAKEWOOD OH 44107
E-mail: tony(g)yankel.net
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: dreading@.mindsprins.com
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SECRETARY /
CERTIFICATE OF SERVICE