20230427Staff 1-11 to IPC.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-23-12
AUTHORITY TO IMPLEMENT POWER )COST ADJUSTMENT RATES FOR )ELECTRIC SERVICE FROM JUNE 1,2023,)FIRST PRODUCTION
THROUGH MAY 31,2024 )REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than THURSDAY,MAY 4,2023.1
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 workpapersthat provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
i Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0357.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 APRIL 27,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide the monthlynumber of megawatt-hours ("MWh")
associated with the system base and with the actual net power costs,for all Net Power Supply
Expense ("NPSE")Accounts including Federal Energy Regulatory Commission ("FERC")
accounts 501 (Coal),account 536 (Water for power),account 547 (Gas),account 555 (Non-
PURPA),account 565 (3rd party transmission),account 447 (Surplus Sales),account 555,
(PURPA),and account 555 (Demand Response Incentives).
REQUESTNO.2:In a manipulatable spreadsheet,please provide the daily totals for
November,December,and January of the deferral period for the followingitems:
a.MWh and run hours for each natural gas plant;
b.MWh and run hours for each coal plant;
c.MWh and run hours for each major hydro plant;
d.MWh and price for non-firm power purchases;and
e.MWh of total native load.
REQUESTNO.3:Please confirm if the Company redistributed or smoothed base
NPSE in Exhibit No.2 from the Aurora-generatedNPSE that was last authorized by the
Commission.If so,please provide workpapers that reflect the calculations/method used to
derive the redistributed base.Please include all workpapers in electronic format with
calculations intact.
REQUESTNO.4:Please provide an electronicallysortable list offorced downtime
(unscheduled)events that Company-owned generation facilities/units experienced each month
during the deferral period.For each forced downtime event,please include the facility/unit
name,the facility/unit nameplate capacity,the type of generation,the length of downtime,the
amount of lost production in MWhs,and the cause and resolution of the event.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 27,2023
REQUESTNO.5:Please provide an electronically sortable list of all Company-owned
facility/unit unforced downtime (scheduled)events during the deferral period.For each event,
include the facility/unit name,the facility/unit nameplate capacity,the type of generation,the
date range,length of time,and purpose.
REQUESTNO.6:Please describe when the Company knew that shortages of coal were
going to occur for the Bridger Coal Plant.Please provide all coal delivery schedules that were
developed for the Bridger Coal Plant starting January 1,2022 throughMarch 31,2023.For each
schedule,please provide the followinginformation:
a.Scheduled deliveries for at least each month across the delivery schedule time
horizon including both available-to-promise (committed)and forecasted amounts;
b.For each month,please provide the amount of coal in tons and the approximate
amount of MWh the amount should produce;and
c.For each schedule,please provide the reason,with documentation,for any
changes in the monthlyamounts from the previous month's schedule.
REQUESTNO.7:Please provide the actual amount of coal delivered,the amount of
coal consumed and the ending inventoryin tons for each month from January 1,2022,through
March 31,2023,for the Bridger Coal Plant.
REQUESTNO.8:For the alternative source of coal from Powder River Basin for the
Bridger plant,when did the Company begin considering it and activelyestablishing it?Please
provide evidence.
REQUESTNO.9:When did the Company know that shortages of coal were going to
occur for the Valmy Coal Plant?Please provide all coal delivery schedules that were developed
for the Valmy Coal Plant starting January 1,2022 through March 31,2023.For each schedule,
please provide the followinginformation:
a.Scheduled deliveries for at least each month across the delivery schedule time
horizon including both available-to-promise (committed)and forecasted amounts;
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 APRIL 27,2023
b.For each month,please provide the amount of coal in tons and the approximate
amount of MWh the amount should produce;and
c.For each schedule,please provide the reason,with documentation,for any
changes in the monthly amounts from the previous month's schedule.
REQUESTNO.10:Please provide the actual amount of coal delivered,the amount of
coal consumed and the ending inventoryin tons for each month from January 1,2022,through
March 31,2023,for the Valmy Coal Plant.
REQUESTNO.11:Please provide the order lead time for coal deliveries to the Valmy
plant from all established vendors.Please provide evidence of the lead times including how the
lead times changed starting January 1,2022,through March 31,2023.
DATED at Boise,Idaho,this day of April 2023.
Claire Sharp,
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.12csms prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 APRIL 27,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27"'DAY OF APRIL 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-23-12,BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
MEGAN ALLEN GOICOECHEA MATTHEW T LARKINLISADNORDSTROMTIMOTHYETATUMIDAHOPOWERCOMPANYJESSIBRADY
PO BOX 70 IDAHO POWER COMPANYBOISEID83707-0070 PO BOX 70E-MAIL:BOISE ID 83707-0070
[e-mail] E-MAIL:[e-mail]@idahopower.com [e-mail]
[e-mail] [e-mail]
TR
CERTIFICATEOF SERVICE