20170502ICIP 1-17 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise,Idatro 83702
Telephone : [phone]
Fax: [phone]
peter@richardsonadams. com
gre g@richardsonadams. com
Attorneys for the lndustrial Customers of tda]ro Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
IMPLEMENT POWER COST
ADruSTMENT ("PCA") RATES FROM
CASE NO.IPC.E.I7.O6
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POV/ER
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)JI.iNE 1 2OI7 THROUGH MAY 31 2018
Pursuant to Rule 225 of tke Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of ldaho Power ("ICIP") by and through their
attomey of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considered as 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 one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; [e-mail]
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
TFO D N
Please provide all discovery responses related to this docket, whether 'formal' or
informal and all exchanges of information along with workpapers and attachments
provided IPUC Staff and/or other entities, whether or not they are a Party.
REOUEST FOR PRODUCTION NO. 2
Please provide a working electronic copy of Table I contained in Nicole Blackwell's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 3
Please provide a copy of ldaho Power's March 30,2017 Operating Plan that was used to
support the forecast in Table 1 of Nicole Blackwell's Direct Testimony.
REOUEST FOR PRODUCTION NO. 4
Please provide a working electronic copy of Table 2 contained in Nicole Blackwell's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 5
On page 9 of Nicole Blackwell's Direct Testimony she states that generation at the
Bridger plant "has experienced a downward trend over the last three years". Please
provide the generation from each of the Bridger units over the past l5 years.
REOUEST FOR PRODUCTION NO. 6
On pages 9 and 10 of Nicole Blackwell's Direct Testimony she states that lower coal
production at the BCC mine have resulted in fixed costs being recovered over fewer tons
have caused the cost per ton of coal to increase and ultimately contributedto al3Yo
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF TDAHO
POWER
IPC-E-17-06
PAGE 2
increase in coal cost from last year's forecast. Please provide the analysis that was used to
find the increase in coal costs including the fixed costs, coal production before and after
the volume reduction along with any other factors that resulted in coal cost increase.
REOUEST FOR PRODUCTION NO. 7
On page11 of Nicole Blackwell's Direct Testimony she states that PURPA costs "in this
case has an average cost of $62 .42 per MWh." Please provide the PURPA projects, their
cost and expected output included the calculation of average cost.
REOUEST FOR PRODUCTION NO. 8
On pagel I of Nicole Blackwell's Direct Testimony she states'oBy comparison, the
average market purchase price for this year's PCA forecast is $23.46 per MWh." Please
provide, on a per MWh basis, what Idaho Power's rate payers are paying for the output
from Langley Gulch when capital (rate base) costs are included along with the fixed and
variable costs of generation.
REOUEST FOR PRODUCTION NO. 9
Please provide a working electronic copy of Table 3 contained in Nicole Blackwell's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 10
Please provide a working electronic copy of Table 4 contained in Nicole Blackwell's
Direct Testimony.
REOUEST FOR PRODUCTION NO. I I
Please provide a working electronic copy of Table 5 contained in Nicole Blackwell's
Direct Testimony.
FIRST PRODUCTION REQUEST OF THE TNDUSTRTAL CUSTOMERS OF IDAHO
POWER
IPC-E-17-06
PAGE 3
REOUEST FOR PRODUCTION NO. 12
Please provide a working electronic copy of Table 6 contained in Nicole Blackwell's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 13
Please provide a working electronic copy of Exhibit No. 1 attached to Nicole Blackwell's
Direct Testimony
REOUEST FOR PRODUCTION NO. 14
Please provide a working electronic copy of Exhibit No. 2 attached to Nicole Blackwell's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 15
Please provide a working electronic copy of Exhibit No. 5 attached to Nicole Blackwell's
Direct Testimony.
REOUEST FOR PRODUCTION NO. 16
Please provide a working electronic copy of Attachment No. 2 to ldaho Power's
Application.
FOR
Please provide copies of all correspondence, reports or other written materials provided
to shareholders, financial institutions, stock rating agencies, governmental units or any
other entity discussing the impact or potential impact of the current PCA on the
Company's eamings, financial status and/or stock price.
FIRST PRODUCTION REQUEST OF THE TNDUSTRIAL CUSTOMERS OF IDAHO
POWER
rPC-E-17-06
PAGE 4
DATED this 2nd day of May,2017
Richardson PLLp
Peter J. Richardson
Industrial Custorners of Idaho Power
CERTIFICATE OF SERVICE
I hereby certify that on May 2"d 2017, copies of the foregoing First Production Request
of the Industrial Customers of Idaho Power in Docket No. IPC-E-17-06 were hand delivered to:
LisaNordstrom
Idaho Power Company
1221 West ldaho Street
P.O. Box 70
Boise,Idaho 83707
lnordstrom@ idahopower. com
dockets@ idahopower. com
Tami White
Timothy E Tatum
1221 West Idatro Street
P.O. Box 70
Boise,Idaho 83707
twhite@ idahopower. com
ttatum@ idahopower. com
Diane Hanian
Idaho Public Utilities Com'n
472West ldaho
Boise, tdaho 83702
[e-mail]. gov
Kandi W*ers
Administrative Assistant
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-17-06
PAGE 5