20190501Staff 13-18 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0014
[phone]
IDAHO BAR NO. 10446
RECE IVEO
?019llAY - | Pll t: 03
IDA',-10 FUBLIC
IJTiLIT IES COMMISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-59T8
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 RECOVER COSTS ASSOCIATED
WITH THE NORTH VALMY PLANT.
CASE NO.IPC-E-19.08
THIRD 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 TUESDAY, MAY 7r2019.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 attorney
at [phone].
THIRD PRODUCTION REQUEST
TO IDAHO POWER
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I MAY 1,2019
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.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. 13: Please explain why in Exhibit No. 3, capital expenditures made from
August 1,2016 through December 31,2018 for Unit I are l25Yo greater or $2,034,457 above the
capital expenditures made for Unit 2 during this same period?
REQUEST NO. 14: Please explain why the 2017 budgeted amount of $24,185 for the
Valmy Unit I "TWIP Install" (Project No.27467689) is significantly less than the actual cost of
$274,822 shown in Exhibit No. 3.
REQUEST NO. 15: Please explain why the 2015116 budgeted amount of $287,575 for the
Valmy Unit 1 "Clarifier Recirculation Drives" (Project No. 27430166) is significantly less than the
actual cost of $541,177 shown in Exhibit No. 3.
REQUEST NO. 16: Please explain why the 2018 budgeted amount of $225,054 for the
Valmy Unit I "Pulverizer Rebuild" (Project No. 27501 I l6) is less than the actual cost of $319,565
shown in Exhibit No. 3.
REQUEST NO. 17: Please identify all capital projects over $200,000 where generally
similar work was completed on Units I and2. Where the differences in actual costs between the
two units exceed 25Yo please explain the basis for the difference.
REQUEST NO. 18: For each item identified above in Responses to Production Request
Nos. l4 through 17, please provide an itemized breakdown for each project and detailed invoices
showing the actual costs by component.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 MAY 1,20t9
rr
DATED at Boise, Idaho, this day of May 2019.
Edward
Deputy
i :umisc:prodreq/ipce I 9. 8ejrk prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER
General
J MAY 1,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I't DAY OF MAY 2019, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY,TN 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
BOISE rD 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-MAIL: [e-mail]
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE tD 83707-0070
E-mail : [e-mail]
CERTIFICATE OF SERVICE