20170427Staff 1-9 to IPC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT POWER COST
ADJUSTMENT (PCA) RATES FOR ELECTRIC
SERVICE FROM JUNE I,2OI7 THROUGH
MAY 31,2018.
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO.IPC-E-I7-06
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission request that Idaho Power Company
provide the following documents and information as soon as possible, by THURSDAY,
MAY 4,2017.r This Production Request is continuing, and the Company 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, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 APRIL 27,2017
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
31.0r.0t.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. 1: Please provide monthly net power supply expense (NPSE) and the
corresponding amount of energy (MWh) for each FERC NPSE account for the April2016
through March 2017 defenal period similar to Exhibit No. I included in the Company's
application. Please provide a further breakdown of Account 501 and Account 547 by plant.
REQUEST NO. 2: Please provide monthly average coal cost ($/ton) for Boardman,
Bridger, and Valmy coal plants during the April 2016 through March 2017 deferral period and
coal price forecasts for the April2017 through March 201 8 forecast period. If there were any
increases in costs, please provide a detailed explanation.
REQUEST NO.3: Specific to the Bridger plant, please provide a detailed explanation
of the top 3 reasons why coal costs have increased and the NPSE impact of each. If not in the
top 3 reasons, please also include an explanation and the NPSE impact of the Bridger mine long
wall collapse.
REQUEST NO. 4: In the Company's forecast, please explain why Langley Gulch is not
planned to generate April2017 through June of 2017, especially since Bridger is planned to run
and coal costs are assumed to increase based on Nicole Blackwell's direct testimony (pp. 8 -10).
What other resources (or market) have lower dispatch costs than Langley Gulch during this time
frame?
REQUEST NO. 5: Please provide monthly dispatch costs for each generation plant used
to develop the Company's forecast. Please include all workpapers with formula intact.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 27,2017
REQUEST NO. 6: Please provide all planned and unplanned downtime for the Langley
Gulch power plant during the April2016 through March 2017 defenal period. In addition,
please provide the time period and an explanation why the plant was down for each occurrence.
REQUEST NO. 7: Please provide a detailed description of the Langley Gulch
equipment damage and related downtime that happened in October of 2016. Include any
documentation or analysis that indicates root cause.
REQUEST NO. 8: In reference to the October 2016 outage, please provide the
reduction in NPSE had the Langley Gulch facility remained operational. Please include the
resources, amounts of energy, and cost used to backfill lost generation. Include all workpapers
with formula intact.
REQUEST NO. 9: Please provide all warranty terms and conditions, information or
insurance policies that could potentially apply to the October 2016Langley Gulch outage. Did
the Company file for any warranty or insurance claims? Please explain, why or why not. If the
Company is eligible for insurance or warranty coverage, please provide the amount the Company
is entitled to receive.
Dated at Boise, Idaho, this )?V day of April2017
General
Technical Staff: Mike Louis (l-9)
i:umisc:prodreq/ipce I 7.6bkml prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER J
Brandon
APRIL 27,2017
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 27fi DAY OF APzuL 201.7,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER IN CASE NO. IPC.E,I7.O6, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
TAMI WHITE
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail: [e-mail]
ttatum@ idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
PO BOX 7218
BOISE ID 83702
E-mai I : oeter (d.ichardsonadam s. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
S Y
CERTIFICATE OF SERVICE