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Home My WebLink About950822.docxSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET STATEHOUSE MAIL BOISE, IDAHO 83720-6000 (208) 334-0320 ATTORNEY FOR THE COMMISSION STAFF BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER) COMPANY’S 1995 ELECTRIC)CASE NO. IPC-E-95-8 INTEGRATED RESOURCE PLAN. ) )FIRST 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, Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company provide the following documents and information on or before TUESDAY, SEPTEMBER 12, 1995. This Production Request is to be considered as continuing, and Idaho Power 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. Request No. 1: What capacity reserve for short term operating requirements was used for planning prior to submittal of the 1995 IRP? If different from the 6% used in the 1995 IRP (see pg. 2), explain the rationale for the difference. Provide any evidence to support a change in capacity reserve. Request No. 2: Why is an average annual energy surplus of 242 average megawatts maintained by the base case resource plan throughout the 20-year planning period as discussed on page 4? Does this represent the capacity reserve? How does this relate to the surplus calculated in the last line of Table 1 on page 6? How does it relate to the 270 MWa surplus and the 215 MWa surplus discussed on page 61? Request No. 3: Has the Company made an economic analysis comparing relicensing costs of existing hydropower plants to acquisition of new resources? If so, what is the result of that analysis? What is the estimated cost of relicensing for projects whose licenses will expire during the 20-year planning horizon? Request No. 4: Describe the expected structure of the planned seasonal capacity and energy purchases in terms of duration of contracts, load factors, whether purchases will be firm or non-firm, and/or whether exchange agreements can meet seasonal requirements. Does the Company intend to pursue seasonal power exchange contracts after the expiration of the Seattle City Light and Montana Power agreements to meet seasonal deficits, rather than seasonal capacity and energy purchases from the wholesale power market? Request No. 5: Explain what is meant by pursuing relicensing of Shoshone Falls with an "option" to expand generating capacity (see pps. 4, 5, 65). When does Idaho Power anticipate making a decision on whether to pursue expansion at Shoshone Falls if the license expires in 1999 and the license application must be submitted in 1997? Request No. 6: Provide workpapers or any other supporting evidence showing how Idaho Power estimated that 200,000 acre feet of water would be purchased from existing water users to aid in salmon recovery as discussed on page 10. Why has the Company estimated 200,000 acre-feet would be available when the Council's plan calls for 1,000,000 acre-feet? Request No. 7: Provide copies of the December 1994 Amendments to the Northwest Power Planning Council Fish and Wildlife Program upon which Idaho Power's estimates of federal water releases and voluntary water purchases is based. Request No. 8: Does the Company expect the on-line dates of the following projects to remain the same as listed in Table 2 on page 12: Auger Falls Horseshoe Bend Shoshone II Magic West Magic Valley If the expected on-line dates have changed, what are the new expected dates? Request No. 9: Provide workpapers or other explanation showing how the prevailing market rates for energy and capacity were determined. Provide workpapers showing how the expected future purchase prices for winter and summer capacity and energy were estimated as discussed on page 33. Request No. 10: Explain how the probabilities associated with gas prices were determined (pg. 41). Request No. 11: Why was 10% chosen as the assumed restriction of peaking capacity at Hells Canyon for relicensing uncertainty? Specifically, what restriction was assumed on run-of-river operations at the Strike, Bliss and Lower Salmon plants? (pg 42) Request No. 12: Explain the rationale for the second screening step as discussed on page 43. Why are mid-high load growth and high gas price used? What is meant by "favorable" and "adverse" uncertainty conditions? Request No. 13: Provide a list of resources eliminated in each step of the cost effectiveness screening discussed on page 43. Request No. 14: Explain the monthly energy deficits that appear on Figure 15, page 63. Isn't the base plan supposed to eliminate all deficits, both peak and energy? Request No. 15: Provide any evidence relied on by the Company showing the availability of market resources in the region during the next 10 years. Request No. 16: Explain the 20 average megawatts of winter purchases from the years 2003 through 2014 as shown in Table 1 on page 6. Are the purchases for capacity or energy? Reconcile the purchases with the discussion of winter purchases on page 33, Figure 13 on page 60, and Figures 14 and 15 on pages 62 and 63. Request No. 17: Page 50 of the Technical Appendix says that the UAMPS and Washington City contracts will automatically renew for additional terms of five years upon their expiration. The Company's load forecast however does not seem to make this same assumption. Will these contracts indeed be renewed? Does the Company expect any other purchase, sale or exchange contracts to be renewed? Request No. 18: Why is there a fuel cost associated with the Bridger efficiency improvement as shown on page 119 of the Technical Appendix? Does the fuel cost affect the levelized cost for the project? Request No. 19: Has the Company established any guidelines limiting the amount of planned seasonal capacity or energy purchases to a specified amount, or established a threshold for seasonal purchases above which the Company chooses to build its own resources or acquire long term firm contracts? Request No. 20: For the six scenarios analyzed using decision tree analysis, how would the average levelized retail rates compare? DATED at Boise, Idaho, this day of August 1995. ______________________________________ Scott Woodbury Deputy Attorney General ______________________________________ Rick Sterling Staff Engineer sw/rs:gdk/pr/ipce958.sw