20170509IPC to ICIP 1-17 Redacted.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
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Enclosures
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Lisa D. Nordstrom
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An IDACORP Company
P.O. 8ox 70 (83707)
1221 W. ldaho St.
Boise, lD 83702
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May 9, 2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-17-06
2017-2018 Power Cost Adjustment - ldaho Power Company's Response to
the First Production Request of the lndustrial Customers of ldaho Power
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an origina! and three (3) copies of
ldaho Power Company's Redacted Response to the First Production Request of the
lndustrial Customerc of ldaho Power. Also enclosed forfiling are an originaland three (3)
copies of ldaho Power Company's Confidential Response to the lndustrial Customers of
ldaho Power's Production Request No. 6.
ln addition, enclosed are four (4) copies each of non-confidential and confidential
disks containing information responsive to the lndustrial Customers of ldaho Powe/s
production requests. Please handle the confidential information in accordance with the
Protective Agreement executed in this matter.
Very truly yours,
LISA D. NORDSTROM (!SB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
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lnordstrom@ hooower.com
Attomey for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT POWER
cosr ADJUSTMENT (PCA) RATES FOR
ELECTRIC SERVICE FROM JUNE 1,2017
THROUGH MAY 31,2018.
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CASE NO. !PC-E-17-06
IDAHO POWER COMPANY'S
REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the lndustrial Customers of ldaho Power
dated May 2,2017, herewith submits the following information:
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCT]ON REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 1: Please provide al! 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see ldaho
Powe/s written and electronic responses to the ldaho Public Utilities Commission
Staffs Audit Request Nos. 1-16 and 17-18 provided on the non-confidential and
confidential CDs. The confidential CD will only be provided to those parties that have
executed the Protective Agreement in this matter. AII other responses to other parties'
discovery have previously been provided to the lndustrial Customers of ldaho Power.
The response to this Request is sponsored by Kimberly Towell, Executive
Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 2: Please provide a working electronic
copy of Table 1 contained in Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
: Please provide a copy of ldaho Powe/s
March 30, 2017 Operating Plan that was used to support the forecast in Table 1 of
Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The Operating Plan
used for the PCA is part of the Risk Management Committee minutes and is
confidential. lt is available for onsite review. Please contact Matt Larkin at (208) 388-
2461 or Camilla McClusky at [phone] to schedule a time to review the
document.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCT]ON REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 4: Please provide a working electronic
copy of Table 2 contained in Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: PIease see the ExceI
file provided on the non-confidentia! CD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE ]NDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
REQUEST 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 15 yearc.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the Excel
file provided on the non-confidential CD which contains the yearly generation by unit
(2002-2016) for the Jim Bridger power plant ("Bridge/').
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST 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 coa! to
increase and ultimately contributed to a 13o/o increase in coal cost from last yea/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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see the
confidentia! Excel file provided on the confidential CD, which provides the basis for the
increase in forecast fuel costs at Bridger for calendar year 2018. The confidential CD
will only be provided to those parties that have executed the Protective Agreement in
this matter.
The 2016 Bridger Coal Company ("BCC') budget included a forecast of !
I tons of deliveries to Bridger. However, due to low market prices, low natural gas
prices, and an abundance of renewable generation, the total projected output for
Bridger was reduced during the first quarter of 2016. As a result, Bridger reduced its
total deliveries of BCC coa!. Actual deliveries to Bridger in 2016 totaled tons
versus the budgeted tons. Additionally, the 2017 BCC budget includes a
forecast of I tons of deliveries to Bridger. Reducing the delivered tons to the
plant increased the BCC cost per ton from I per ton to I per ton, which in
tum increased the total cost of coa! from a forecast amount of I per ton to I
per ton.
The response to this Request is sponsored by Elizabeth Finley, Senior Mine
Operations Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 7: On page 11 ot 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 prcjects, their cost and expected output included the
calculation of average cost.
RESPONSE TO REQUEST FOR PRODUGTION NO. 7: Please see the
confidential Excel file provided on the confidential CD. The confidential CD will only be
provided to those parties that have executed the Pnrtective Agreement in this matter.
This file lists the estimated generation and estimated cost of PURPA projects
included in the 2017-2018 PCA filing.
The response to this Request is sponsored by Michael Danington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER. S
REQUEST FOR PRODUCTION NO. 8: On page 11 of Nicole Blackwell's Direct
Testimony she states "By comparison, the average market purchase price for this yea/s
PCA forecast is $23.46 per MWh." Please provide, on a per MWh basis, what ldaho
Powe/s rate payefti are paying for the output from Langley Gulch when capital (rate
base) costs are included along with the fixed and variable costs of generation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The PCA is a rate
mechanism that quantifies and tracks annual variances in actual net power supply
expenses ("NPSE') and NPSE recovered in rates. Page 11 of Nicole Blackwell's Direct
Testimony referenced in this request includes a discussion of the average market
purchase price, which is a variable cost component of the PCA. Because the PCA
pertains to variable power supply costs, not capital costs, the requested capital cost
information is not relevant nor within the scope of the Company's cunent filing.
Therefore, the Company is only providing the variable per-unit cost of production for
Langley Gulch included in the 2017-2018 PCA forecast, which is $22.08 per megawatt-
hours.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUGTION NO. 9: PIease provide a working electronic
copy of Table 3 contained in Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
]DAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1O
REQUEST FOR PRODUCTION NO. 10: Please provide a working electronic
copy of Table 4 contained in Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please see the Excel
file provided on the non-confidential GD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER. 11
REQUEST FOR PRODUCTION NO. 11: Please provide a working electronic
copy of Table 5 contained in Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Nicole Blacl<well, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
REQUEST FOR PRODUCTION NO. 12: Please prcvide a working electronic
copy of Table 6 contained in Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: PIease see the Excel
file provided on the non-confidentia! CD.
The response to this Request is sponsored by Nicole Blackwel!, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13
REQUEST FOR PRODUCTION NO. 13: Please provide a working electronic
copy of Exhibit No. 1 attached to Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUGTION NO. 13: PIease see the ExceI
file provided on the non-confidentia! CD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Gompany.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF ]DAHO POWER - 14
REQUEST FOR PRODUCTION NO. 14: Please provide a working electronic
copy of Exhibit No. 2 attached to Nicole Blacl<well's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Please see the Excel
file provided on the non-confidential CD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 15
REOUEST FOR PRODUCTION NO. 15: Please provide a working electronic
copy of Exhibit No. 5 attached to Nicole Blackwell's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Please see the Exce!
file provided on the non-confidential CD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 16
REQUEST FOR PRODUCTION NO. 16: Please provide a working electronic
copy of Attachment No. 2 to ldaho Powe/s Application.
RESPONSE TO REQUEST FOR PRODUGTION NO. 16: Please see the Excel
file provided on the non-confidentia! CD.
The response to this Request is sponsored by Nicole Blackwell, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 17
REQUEST FOR PRODUCTION NO. 17: Please provide copies of all
corespondence, reports or other written materials provided to shareholders, financia!
institutions, stock rating agencies, govemmental units or any other entity discussing the
impact or potentia! impact of the cunent PCA on the Company's eamings, financial
status and/or stock price.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Please see the
attachment provided on the non-confidential CD. The attachment includes copies of the
pages of presentations made to Standard & Poods and Moody's on April 11, 2017,
which included mention of the then pending PCA filing. As the filing had not yet been
made, the amount and magnitude of the filing was not discussed with either Standard &
Poo/s or Moody's.
ln addition, on May 4,2017, the Company discussed the cunent PCA filing on
page 48 of the Securities and Exchange Commission Form 10-Q, which is publicly
available for viewing at htto://www.idacorpinc.com/investor-relations/financlal-
i nfo rmatio n/sec-fi I i nqs.
The response to this Request is sponsored by Justin S. Forsberg, Director of
lnvestor Relations, ldaho Power Company.
DATED at Boise, ldaho, this th day of May 2017.
D
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 18
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this th day of May 2017 | served a true and conect
copy of IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
upon the following named parties by the method indicated below, and addressed to the
fo!lowing:
Gommission Staff
Brandon Karpen
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702')
P.O. Box 7218
Boise, ldaho 83707
X Hand Delivered_U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mai!
_Ovemight Mail
_FAXX Email [e-mail]
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
_Hand DeliveredX U.S. Mail
_Ovemight Mail
FAX
x Email d [e-mail]
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Kim rly , Executive Assistant
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 19