20190411Staff 3-12 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
t.-':-1/r- n
tl,; i-fll I I Plt 31 58
bl'lLir
Street Address for Express Mail:
472W. 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 AUTHORITY
TO INCREASE ITS RATES FOR ELECTRIC
SERVICE TO R-ECOVER COSTS ASSOCIATED
WITH THE NORTH VALMY PLANT.
CASE NO. IPC-E.I9.08
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by FRIDAY, APRIL l9r2019.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 person
preparing the document, and the name, location and phone number of the record holder and if
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s attomey
at [phone].
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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APRIL II,2OI9I
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3r.01.01.228.
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.3: Please provide the monthly capacity factors for each Valmy unit from
January I,2016 through March 31,2019.
REQUEST NO. 4: Please provide the monthly net generation for each Valmy unit from
January 1,2016 through March 31,2019.In addition, please show separately Idaho Power's portion
ofthe net generation.
REQUEST NO. 5: Please provide an update to Exhibit No. 3 of Harvey Direct Testimony
reflecting start and completion dates for each project listed.
REQUEST NO. 6: In order to see how the Company's capital investment plans have
changed over time, please provide the Company's capital investment plan, (including a detailed
project description and need for each project, the dollar amounts, and planned start and completion
dates for each project) completed by the Company in2015,2076,2077,2018, and2019. For the
investments in each plan, please indicate if the investment is tied to Valmy Unit l, Unit 2, andlor
common plant.
REQUEST NO. 7: In order to understand how the Company and NV Energy made
decisions about future capital investments relative to NV Energy and the Company's agreement,
please provide the decision criteria and considerations used to determine whether a capital
investment should be made specific to Valmy Unit 1, Unit2, or common plant considering
anticipated closure dates. Please provide a detailed explanation of the criteria, including any
guidelines or parameters that were used.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL II,2OI9
REQUEST NO. 8: Please provide copies of e-mails, meeting notes, and/or records of
discussion between the Company and NV Energy related to the decision whether or not to move
forward with capital investments for Unit 1, Unit 2, or common plant considering proposed closure
dates and earlier alternative closure dates for Unit 1.
REQUEST NO. 9: Please provide a detailed explanation and supporting documentation
and analysis substantiating the statement quoted below from Harvey's Direct Testimony, on Page
No. 22. Please include a description and a breakdown of the "certain costs" that could be reduced
and why remaining cost categories could not be reduced.
Therefore, it is unlikely that Idaho Power's exit from Unit 2 operations prior
to 2025 would result in material savings because the only payment obligation
relief would come from a reduction in certain costs associated with Idaho
Power's capacity reduction in Unit 2 operations.
REQUEST NO. 10: In reference to Harvey's Direct Testimony, Page Nos. 22 and23,
please further explain and provide supporting documentation and details related to the statement:
Moreover, as detailed in the 2017 IRP Appendix C, Idaho Power's ownership
share of Valmy's capacity is utilized to meet the Company's current peak-
hour load and resource balance. Without it, Idaho Power could experience a
deficit during the year, with potential deficits growing in subsequent years
through 2025. Valmy is a necessary, although relatively infrequent,
contributor to system reliability through 2025.
REQUEST NO. 1l: In reference to the prior production request, what analysis has the
Company made to determine other options available to offset the required Valmy generation which
could be provided at a lower overall cost recognizing an earlier closure of Unit #2.
REQUEST NO. 12: Has the Company been involved in any discussion or made any effort
with an interested party to negotiate a sale of one or more units of the North Valmy plant? If the
answer is no, please explain why not.
SECOND PRODUCTION REQUEST
TO IDAHO POWER APRIL II,2079J
DATED at Boise,Idaho, this 1rt' day of April 2019.
Edward J
Deputy General
i : umisc:prodreq/ipce I 9. Sejrk prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 APRIL II,2OI9
-<--)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l lth DAY OF APRIL 2019,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO. IPC-E-19-08,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : [e-mail]
dockets@ idahopower. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE TD 83702
E-MAIL: [e-mail]
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
CERTIFICATE OF SERVICE