20210819Staff 12-16 to IPC.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
-r, r.r \r',.:l-r.rr,-tt'i
Street Address for Express Mail:
1 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
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 RE,COVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLANT
CASE NO. IPC.E-21-17
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,
Erick Shaner, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY, SEPTEMBER 9, 2021.
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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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AUGUST 19,2021
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 12: In reference to the potential for one or more units of Jim Bridger
being converted to natural gas, please respond to the following:
a. Has Idaho Power performed an analysis on converting units of Jim Bridger to
natural gas? Please explain and provide the analysis if performed; and
b. How would the natural gas conversion of one or more units of Jim Bridger affect
the Company's proposed depreciation schedule, balancing account, and revenue
requirement provided in this case? Please explain.
REQUEST NO. 13: In reference to State Implementation Plan ("SIP") provided in
Response to Staff s Production Request No. 7. Please respond to the following:
a. When was the SIP submitted to the U.S. Environmental Protection Agency; and
b. Have Idaho Power and PacifiCorp been modeling the Voluntary Visibility Enhancing
Emissions Limits discussed in the SIP in their Jim Bridger IRP analyses? If so,
provide an explanation of the assumptions used in modeling the Voluntary Visibility
Enhancing Emissions Limits, such as when the Limits would start. If not, explain
why the Limits were not included.
REQUEST NO. 14: Please provide a list of all assumptions used for each Bridger unit
in the Company's IRP modeling analysis.
REQUEST NO. 15: In reference to the file named "Request I - CONFIDENTIAL
Attachment I - Exhibit No. 1 and workpapers - Bridger Levelized Rev Req" provided in
Response to the Industrial Customers of Idaho Power's First Production Request No. I as
Confidential Attachment 1. Please explain the amount shown for Unit 3 capital expense for the
year 2025 in the ooCapex Forecast" tab.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST I9,2O2I
REQUEST NO. 16: In the Project Proposals provided in Response to StafPs Production
Request No. 9c, it states the work will be competitively bid to multiple contractors. Please
explain the competitive bidding process, and provide copies of all competitive bids received and
short-list/final bidding scoring for the following Appropriation Requests ("APR"):
a. APR - 10007088, Project Title - Jim Bridger Unit 2 Turbine Upgrade High
Pressure/Intermediate Pressure/Low Pressure;
b. APR - 90000565, Project Title - Jim Bridger Unit2 Turbine Upgrade High
Pressure/Intermediate Pressurellow Pressure;
c. APR - 10015937, Project Title - U4 Absorber Reline l6; and
d. APR - 90001005, Project Title - U4 Absorber Reline 16.
/a4/ / day of August 2021DATED at Boise, Idaho, this
i :umisc:prodreq/nsww2 l l esksk prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Erick
Deputy Attomey General
J AUGUST I9,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lgth DAY OF AUGUST 2021, SERVED
THE FOREGOING SECOND PRODUCTION REQTIEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPAI{Y, IN CASE NO. IPC-E-21-17, By E-MAILING A COpy
THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets(Didahopower.com
PETER J zuCHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-MAIL : peter(@,richardsonadams.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
ROSE MONAHAN
ANA BOYD
SIERRA CLUB
21OI WBSTER ST STE 13OO
OAKLAND CA946I2
E-MAIL: [e-mail]
ana. boyd.@,sierrac I ub. org
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL : kelser"@kelse],_iae.com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : mlarki n(a-tidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : dreading(r?mi ndsprinq. coni
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEYS OFF
PO BOX 500
BOISE rD 83701-0500
E-MAIL: BoiseCitvAttorney@cityolboi se.ors
[e-mail]
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTLINITIES FOR
IDAHO
3778 PLANTATION DR, SUITE 102
BOISE ID 83703
E-MAIL:
es.com
co urtney @cl eanenerg),opportunit i es. com
JIM SWIER
MICRON TECHNOLOGY INC
8OO SOUTH FEDERAL WAY
BOISE TD 83707
E-MAIL: jswier@.micron.com
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A NELSON
AUSTIN W JENSEN
HOLLAND & HART LLP
555 ITTH ST STE 32OO
DENVER CO 80202
E-MAIL: [e-mail]
tnelson@hollandhart. com
awj ensen@holl andhart. com
ac I ee (Eho I I andhart. com
gl garganoamari @hollandhart. com
CERTIFICATE OF SERVICE