20170804Staff 25-35 to IPC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. IOI77
Street Address for Express Mail
472 W , 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 A
DETERMINATION OF HELLS CANYON
COMPLEX RELICENSING COSTS THROUGH
2015 AS PRUDENTLY INCURRED.
CASE NO. IPC.E.16.32
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, by FRIDAY,
AUGUST 25,2017.
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
3r.01.01.228.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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AUGUST 4,2017
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. 25: Has a contingency plan been formed in the event that the re-
licensing impasse between stakeholders, states, and agencies cannot be resolved? If so, please
describe. If not, please explain why not.
REQUEST NO. 26: Please provide the projected timeline and milestones for the
completion of Hells Canyon Complex re-licensing by 2021. Tatum Direct at 10.
REQUEST NO. 27: Please provide an update on the status of the CWA $401
certification applications filed with Idaho and Oregon in July of 2016. Randolph Direct at 3 I
REQUEST NO. 28: Please provide a detailed account of costs and activities,
referencing work order numbers, associated with the Reservoir Temperature control structures.
Randolph Direct at 33. Please explain why these expenses were necessary and what the project
accomplished.
REQUEST NO. 29: Please provide the Company's policy regarding determination of
Hells Canyon Complex settlement conditions and monetary expenditures.
REQUEST NO. 30: Please provide the term sheets for the 2003 County of Baker,
Oregon Settlement Agreement , the 2004 Interim Settlement Agreement, and proposed 2013
comprehensive settlement agreement. Randolph Direct at 44.
REQUEST NO.31: Please provide a list of expenses and description of each expense,
referencing work order numbers, associated with settlement activities performed with the County
of Baker, Oregon. Randolph Direct at 45. Please explain why these expenses were necessary
and what the project accomplished.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 4,2017
REQUEST NO. 32: Please provide a detailed account of costs and activities,
referencing work order numbers, associated with the Surface Collector project. Randolph Direct
at 52. Please explain why these expenses were necessary and what the project accomplished.
REQUEST NO. 33: Please provide a list of expenses and description for each expense
associated with protection, mitigation, and enhancement (PM&E) measures. Please reference
applicable work order numbers. Please explain why these expenses were necessary and what the
project accomplished.
REQUEST NO. 34: Please provide the Agency Comments listed in Randolph Exhibit 3
REQUEST NO.35: For each of the following topics and sub-topics listed in section a,
please provide the information requested in b, c, d, and e:
a. Topics
i. Aquatics:
l. Bull Trout
2. Salmon/Steelhead
3. Resident Fish
4. Mollusks
5. Sturgeon
6. Hatcheries
7. PassagelReintroduction
ii. Cultural Resources
iii. Project Operations
iv. Recreation
v. Sediment Depletion
vi. Terrestrial - Botanical Resources
vii. Water Quality
1. Dissolved Oxygen
2. Total Dissolved Gas
3. Water Temperature (CWA $-401)
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY AUGUST 4,2017J
b. Please describe the issue raised by stakeholders.
c. Identify the study or studies used to investigate the issue.
d. Provide and summarizethe agreement reached between the Company and
stakeholders that resolved the issue.
e. Provide the total expense incurred on each topic, including the costs of all studies and
mitigation measures. Please provide the work order number, vendor, date, amount,
and brief description.
Dated at Boise, Idaho, this
r+{4. -\ ,/ day of August 2017
k{General
Technical Staff: Rachelle Farnsworth (25-33)
Stacey Donohue (34-35)
i:umisc:prodreq/ipcel6.32ccrfsd prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 AUGUST 4,2077
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF AUGUST 2017,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAY, [N 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 rD 83707-0070
E-MAIL : I nor:dstrorn/,0tidahopower. qorn
c1 o ckets IjiJ.i claho porver. c cim
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-mail: elo/i"rechohawk.corn
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE TD 83702
E-MAIL: peter(Oricharclsonaclams.com
BENJAMIN J OTTO
7IO N 6TH STREET
BOISE ID 83702
E-mail : botto(f&idahoconsen ation.org
TIM TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: ttatum(0idahqpower.com
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-mail : tony(gyankel.net
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : dreadin g/A-}n i ndsori n g.com
Y
CERTIFICATE OF SERVICE