20190408IPC to Staff 1-2.pdf

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An IDACORP Company
JULIA A. HILTON
Senior Counse!
ihi [e-mail]
April 8, 2019
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-19-08
Recovery of Costs Associated with North Valmy Power Plant - ldaho Power
Company's Response to the First Production Request of the Commission
Staff
Dear Ms. Hanian:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the First Production Request of the Commission Staff.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information provided in response to Staffs requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
lf you have any questions aboutthe enclosed documents, please do not hesitate to
contact me.
Very
Julia A. Hilton
JAH:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
JULIA A. HILTON (lSB No. 7740)
LISA D. NORDSTROM (!SB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83701
Telephone: [phone]
Facsimile: [phone]
i h i lton@ idahopower. com
RfiCIIVED
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Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE NORTH
VALMY POWER PLANT
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CASE NO. tPC-E-19-08
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated April 3, 2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 1
REQUEST NO. 1: Please provide all workpapers, tables, and exhibits presented
in both Larkin and Harvey Direct Testimonies in electronic format with formulas intact.
Staff also requests a meeting with the Company, on or about April 11,2019. The
purpose of this meeting is to allow the Company to walk through the Company's
application and workpapers to provide Staff with a better understanding of the
calculations in the case.
RESPONSE TO REQUEST NO. 1:Please see the following files provided on
the non-confidential and confidential CDs:
o Attachment 1 includes Exhibit No. 1 and the associated workpapers
that support the quantification of the Valmy levelized revenue requirement discussed in
the direct testimony of Mr. Larkin.
o Confidential Attachment 2 is Exhibit No. 2, the North Valmy Project
Framework Agreement between NV Energy and ldaho Power dated as of February 22,
2019.
o Attachment 3 is Exhibit No. 3, which details the investments made at
Valmy since July 31 ,2016, including the investment by unit or common facility and a
classification as to whether the investment was for environmental compliance, the safe
and economic operation of the plant, or for reliability purposes for those projects over
$100,000. Attachment 3 also includes a description of all investments made since July
31,2016, and justification for all those investments over $100,000. Please note,
Attachment 3 provided on the enclosed non-confidential CD includes the correction of
two typos found in the original version that was filed with Mr. Harvey's direct testimony
on March 8,2019.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
All workpapers or tables presented in the direct testimony of Mr. Harvey have
been included in Exhibit Nos. 2 and 3 provided on the confidential and non-confidential
CDs, respectively.
ldaho Power, ldaho Public Utilities Commission Staff ("Staff'), and the ldaho
Conservation League are working towards scheduling a meeting forApril 15,2019, to
allow the Company to walk through the application, exhibits, and workpapers and
provide a better understanding of the levelized revenue requirement calculations
performed in this case.
The confidential CD will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, ldaho Power Company, and Tom Harvey, General
Manager of Power Supply, Planning and Operations, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 2: ln reference to Larkin testimony pages 13 and 14, please
provide workpapers that document the $12.2 million reduction in overall costs for
customers.
RESPONSE TO REQUEST NO. 2: Please see Attachment 1 provided with the
Company's response to Staffs Request No. 1 for the workpaper that documents the
$12.2 million reduction in overall costs for customers and is referenced in Mr. Larkin's
direct testimony. The quantification of the $12.2 million is summarized on the
"Framework Savings Summary" tab.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
DATED at Boise, ldaho, this 8th day of April 2019.
J IAA N
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of April 2019 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Idaho Conservation League
Benjamin J. Otto
!daho Conservation League
710 North 6th Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.5