20181203IIPA 2-1, 2-9 to PAC.pdf

IIEIVSD
Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: (208) 478-167 0
Email: [e-mail]
Attorney for Intervenor ldaho lrrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
:;;r [[: 13 A]{ t0:08
;rliih4lSSiON
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR
AUTHORIZATION TO CHANGE
DEPRECIATION RATES APPLICABLE TO
ELECTRIC PROPERTY
CASE NO. PAC.E.18-08
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S SECOND
SET OF DATA RE,QUESTS
Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its Second Data
Requests to Rocky Mountain Power, pursuant to Commission Rule 225, as follows:
IIPA 2-1: Regarding the proposed early retirement of the Cholla Unit 4, please provide the
following:
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed intta" abovg?c. Was the conversion to natural gas considered as an alternative to early retirement of the
plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was rejected.f. For each time that the natural gas option was considered and rejected, please provide a
copy of the forecasted natural gas prices that were used.
IIPA2-2: Regarding the proposed early retirement of the Jim Bridger Unit 1, please provide
the following:
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed in
toa" above?
c. Was the conversion to natural gas considered as an alternative to early retirement of the
plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was rejected.
f. For each time that the natural gas option was considered and rejected, please provide a
copy of the forecasted natural gas prices that were used.
Regarding the proposed early retirement of the Jim Bridger Unit 2, please provideIIPA 2-3:
the following
ITPA2-4:
following:
IIPA 2-5:
following:
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed
in "a" above?
c. Was the conversion to natural gas considered as an alternative to early retirement of
the plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was
rejected.
f. For each time that the natural gas option was considered and rejected, please provide
a copy of the forecasted natural gas prices that were used.
Regarding the proposed early retirement of the Craig Unit l, please provide the
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed
in "a" abovg?
c. Was the conversion to natural gas considered as an altemative to early retirement of
the plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was
rejected.
f. For each time that the natural gas option was considered and rejected, please provide
a copy of the forecasted natural gas prices that were used.
Regarding the proposed early retirement of the Craig Unit2, please provide the
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. SECOND SET OF DATA REQEUSTS - Page 2
Case No. PAC-E-18-08
b. What options were considered as a means of meeting the environment standards listed
in "a" above?
c. Was the conversion to natural gas considered as an alternative to early retirement of
the plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was
rejected.
f. For each time that the natural gas option was considered and rejected, please provide
a copy of the forecasted natural gas prices that were used.
Regarding the proposed early retirement of the Craig Unit 3, please provide theIIPA 2-6:
following:
ITPA 2-7:
following:
IIPA 2-8:
following
IDAHO IRRIGATION PUMPERS ASSOCIATION, lNC. SECOND SET OF DATA REQEUSTS - Page 3
Case No. PAC-E-18-08
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed
in"a" above?
c. Was the conversion to natural gas considered as an altemative to early retirement of
the plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was
rejected.
f. For each time that the natural gas option was considered and rejected, please provide
a copy of the forecasted natural gas prices that were used.
Regarding the proposed early retirement of the Craig Unit 4, please provide the
a- What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed
in"a" above?
c. Was the conversion to natural gas considered as an alternative to early retirement of
the plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was
rejected.
f. For each time that the natural gas option was considered and rejected, please provide
a copy of the forecasted natural gas prices that were used.
Regarding the proposed early retirement of the Craig Unit2, please provide the
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed
in"a" above?
c. Was the conversion to natural gas considered as an alternative to early retirement of
the plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was
rejected.
f. For each time that the natural gas option was considered and rejected, please provide
a copy of the forecasted natural gas prices that were used.
IIPA 2-9: Regarding the proposed early retirement of the David Johnston plant, please
provide the following:
a. What and when were the environmental standards adopted that are associated with the
early retirement of this plant?
b. What options were considered as a means of meeting the environment standards listed
in"d'above?
c. Was the conversion to natural gas considered as an alternative to early retirement of
the plant?
d. If the conversion to natural gas was considered, when was it considered?
e. If the conversion to natural gas was considered, please provide a copy of each
review/report that discusses the consideration where the natural gas option was
rejected.
f. For each time that the natural gas option was considered and rejected, please provide
a copy of the forecasted natural gas prices that were used.
DATED this ZdWay of November,20l8.
HA & OLSEN
L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. SECOND SET OF DATA REQEUSTS - Page 4
Case No. PAC-E-18-08
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this ffiayof Novemb er,2018, I served a true, correct
and complete copy of Idaho Irrigation Pumpers Association, Inc. First Set of Data Requests to
each of the following, via U.S. Mail or private courier, email or hand delivery, as indicated below:
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise,ID 83720-0074
diane.holt@,puc.idaho. eov
Yvonne R. Hogle
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Email: [e-mail]
Email : ted.weston@,pacifi corp.com
Stoel Rives, LLP
D. Matthew Moscon
Lauren Shurman
201 South State Street, Suite I100
Salt Lake City, Utah 8411I
Email: [e-mail]
Email: [e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
Email : datarequest@,pacifi corp.com
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
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Hand Delivered
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Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. SECOND SET OF DATA REQEUSTS - Page 5
Case No. PAC-E-18-08
Attorney for ldaho Conservation League
Benjamin J. Otto
710 N 6th Street
Boise,ID 83701
Email : botto @idahoconservation.org
Attorneys for Monsanto Company
Racine Olson, PLLP
Randall C. Budge
Thomas J. Budge
P.O. Box 1391;201E. Center
Pocatello, Idaho 83204-1391
Email: [e-mail]
Email: [e-mail]
Brubaker & Associates for Monsanto
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
Email: [e-mail]
Email: [e-mail]
Idaho Irrigation Pumpers Association, Inc.
Dr. Lance D. Kaufman
4801 W. Yale Ave.
Denver, CO 80219
Email: lance@aesisinsi ght.com
Idaho Irrigation Pumpers Association, Inc.
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Email: tony@,yankel.net
Attorney for PacificCorp Idaho Industrial
Customers
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise,ID 83701
Email: [e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Ovemight Mail
Telecopy (Fax)
Electronic Mail (Email)
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. SECOND SET OF DATA REQEUSTS - Page 6
Case No. PAC-E-18-08
PIIC Customer
Idahoan Foods
Jim Duke
Email: [e-mail]
PIIC Customer
BYU Idaho
Kyle Williams
Email: williamsk@byucdu
PIIC Customer
Nu-West Industries, Inc.
Val Steiner
Email: [e-mail]
Attorney for Sierra Club
Matthew Gerhart
1536 Wynkoop St., Suite 200
Denver, CO 80202
Email: matt. [e-mail]
Sierra Club
Ana Boyd
2101 Webster St., Suite 1300
Oakland, CA94612
Email: [e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
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Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
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Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
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P-6 zoo-R* v
Rebecca Berls, Paralegal
Echo Hawk & Olsen, PLLC
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. SECOND SET OF DATA REQEUSTS _ Page 7
Case No. PAC-E-18-08