200312291st Request of Federal Executive gencies to Idaho Power.pdf

Department of Energy HECEIVED
Washington, DC 20585 F' J LED
2003 DEC 29 Pi, 3: 34
VIA FEDERAL EXPRESS
: :
J F'Ll i IC
UTiLlT!ES CQfrH,;fISSION
December 22, 2003
Barton L. Kline, Esq.
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
Re: Docket No.IPC-03-
Dear Mr. Kline:
Enclosed please find the First Set of Data Requests of the Federal Executive Agencies to
Idaho Power Company. Please provide an original copy of your responses to:
Mr. Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, Virginia 22310-1149
DGoinsPMG~aol.com
Tel: [phone]
Any questions regarding these Data Requests should be directed to Mr. Goins at (703)
313-6895.Thank you.
truly Your
. .
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
Cc: To all parties by U.S. mail and electronic mail
Printed with soy ink on recycled paper
Lawrence A. Gollomp
United States Department of Energy
Rm. 6D-033
1000 Independence Ave., S.
Washington, D.C. 20585
Telephone: [phone]
Fax: [phone]
Attorney for Intervenor
United States Federal Executive Agencies
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of Idaho
Power Company for Authority to Increase
Its Interim and Base Electric Rates and
Charges for Electric Service
Case No. IPC-O3-
FIRST SET OF INTERROGATORIES
PROPOUNDED BY THE UNITED STATES FEDERAL EXECUTIVE AGENCIES
The United States Federal Executive Agencies ("FEA") hereby requests that
Idaho Power Company ("Idaho Power or "Company ) provide the following
information and answer the following questions under oath. Each Request incorporates
fully by reference each and every Instruction and Definition as if set forth fully therein.
Any questions , comments, or objections to said Requests should be directed as soon as
feasible to the undersigned counsel in order to expedite the discovery process. Idaho
Power is requested to provide its responses on an as-available basis and in accordance
with the Commission s Rules of Practice and Procedure. In addition, please state the
name and address of the person preparing the response to each request.
INSTRUCTIONS
In answering each Request, state the text of the Request prior to providing the
response. Each Request and applicable response should be on a separate page.
Where there are subparts to a Request, each subpart and applicable response
should be on a separate page. Each Request is continuing in nature. Thus, if
Idaho Power acquires or discovers additional or different information with respect
to a Request after the Request has been initially answered, Idaho Power is
required to supplement its response immediately following the receipt of such
additional or different information, giving the additional or different information
to the same extent as originally requested. Idaho Power may not postpone serving
such responsive supplemental information until after the filing of any testimony
or supporting documents in this proceeding. Initial and supplementary responses
shall be full, complete and accurate since they will be relied upon by FEA for the
purposes of this proceeding. For each Request, list all assumptions made by
Idaho Power in answering said Request.
In the event that Idaho Power asserts that any of the information requested is
deemed by it to be privileged or proprietary, then Idaho Power in its written
response should identify any such data, and any supporting documents, by date
and general content. Idaho Power should also identify all persons who
participated in the preparation of the document and all persons, inside or outside
Idaho Power, who received a copy, read or examined any such document. In
addition, Idaho Power should indicate its claim of privilege with particularity and
describe the grounds upon which privilege is claimed. State the present location
of the document and all copies thereof and identify each person having custody or
control of the document and said copies.
For information considered proprietary or confidential by Idaho Power, FEA will
hold said information confidential and make it available only to FEA's counsel
and consultants in the present case, pending the execution of an appropriate
protective agreement or the entry of an appropriate protective order by the
Commission.
To the extent that Idaho Power asserts that any requested information is not
relevant or not material to any issue in the above-captioned matter, Idaho Power
in its written response hereto, should indicate a specific basis for said assertion in
the context of any issues arising in this proceeding.
In the event Idaho Power asserts that any requested information is not available in
the form requested, Idaho Power, in its written response thereto, should disclose
the following:
(a)the form in which the requested data currently exists (identifying
documents by title);
(b)whether it is possible under any circumstances for Idaho Power to provide
the data in the form requested;
(c)the procedures or calculation necessary to provide the data in the form
requested;
(d)the length of time (in hours or days) necessary for Idaho Power to prepare
the data in the form requested; and
(e)the earliest dates, time period, and location that representatives of FEA
may inspect Idaho Power s files, records or documents in which the
requested information currently exists.
The Requests contained herein contemplate that individual copies of any
documentary material requested will be provided to FEA as is the usual custom in
regulatory proceedings. In the event that Idaho Power asserts that any requested
documents are too voluminous , or, for some other reason, that copies cannot be
provided, Idaho Power is requested to make this documentary material available
for inspection. Selective copying shall also be provided by Idaho Power pursuant
to FEA's designation at that time.
In providing documents, Idaho Power is requested to furnish all documents or
items in its physical possession or custody, as well as those materials under the
physical possession, custody or control of any other person acting or purporting to
act on behalf of Idaho Power or any of Idaho Power s employees or
representatives, whether as an agent, independent contractor, attorney, consultant
witness, or otherwise.
To the extent any requested document cannot be provided in full, it shall be
provided to the extent possible, with an indication of what document or portion of
what document is being withheld and the reasons for withholding said document.
All documents shall be provided in the same order as they are kept or maintained
by Idaho Power. To the extent they are attached to each other, documents should
not be separated.
10.Documents not otherwise responsive to this Request shall be provided if such
documents are attached to documents responsive to this Request, and constitute
routing slips, transmittal memoranda, letters, comments, evaluations, or similar
materials.
11.For each Request answered, provide the name of the person or persons answering,
the title of such persons and the name of the witness or witnesses who will be pre-
pared to testify concerning the matters contained in each response or document
provided. Idaho Power shall provide all responses under oath.
12.Where these Requests seek quantitative or computational information (e.
models, analyses, databases, formulas) stored by Idaho Power or its consultants in
machine-readable form, in addition to providing hard copy, Idaho Power is
requested to furnish such machine-readable information, on CD-ROM for IBM
compatible PC for large files, as:
(i)Excel worksheet files;
(ii)ASCII text files; or
(iii)other IBM PC compatible worksheet or database files.
13.Responses to any of these Requests may include incorporation by reference to
responses to other Requests only under the following circumstances:
the reference is explicit and complies with instruction 11; and(a)
(b)unless the entirety of the referenced response is to be incorporated, the
specific information or documents of the referenced response shall be
expressly identified.
14.FEA requests that Idaho Power send by overnight delivery service (such as
Federal Express or a comparable service) copies of its responses to the following:
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington, DC 20585
Telephone: [phone]
Fax: [phone]
Email: Lawrence.Gollomp(l3),hq.doe.gov
Dennis Goins
Potomac Management Group
O. Box 30225
5801 Westchester Street
Alexandria, VA 22310
Telephone: [phone]
Fax: [phone]
Email: DGoinsPMG~aol.com
Responsive information and documents should be provided as they become available and
should not be withheld until a complete response to all of FE A's requests is available.
DEFINITIONS
Idaho Power" or the "Company refers to Idaho Power, its subsidiaries
affiliates, predecessors, successors, officers , directors , agents, employees, and
other persons acting in its behalf.
Commission" refers to the Idaho Public Utilities Commission.
Application" refers to the Application of Idaho Power filed with the Commission
by Idaho Power in Case No. IPC-O3-13.
Identify" means as follows:
(a)when used in reference to an individual, to state his full name and present
or last known residence address and telephone number, his present or last
known position and business affiliation, and his position and business
affiliation at the time in question;
(b)when used in reference to a commercial or governmental entity, to state its
full name, type of entity (e.corporation partnership, single
proprietorship), and its present or last known address;
(c)when used in reference to a document, to state the date, author, title, type
of document (e.letter, memorandum, photograph, tape recording, etc.
and its present or last known location and custodian;
(d)when used in reference to a communication, to state the type of
communication (i.letter, personal conversation, etc.), the date thereof
and the parties thereto and, in the case of a conversation, to state the sub-
stance, place, and approximate time thereof, and identity of other persons
in the presence of each party thereto; and
(e)when used in reference to an act, to state the substance of the act, the date
time, and place of performance, and the identify of the actor and all other
persons present.
The term "document" as used in the Requests contained herein is used in its
customary broad sense, and includes, without limitation, any kind of printed
recorded, written, graphic, or photographic matter and things similar to any of the
foregoing, regardless of their author or origin. The term specifically includes
reports, studies, statistics, projections, forecasts, decisions and orders, intra-office
and inter-office communications, correspondence, memoranda, financial data
summaries or records of conversations or interviews, statements, returns, diaries
, .
workpapers, graphs, sketches, computer printouts, summaries or reports of
investigations or negotiations, opinions or reports of consultants, photographs
brochures, bulletins, pamphlets, books, articles, advertisements , circulars, press
releases, graphic records or representations or publications of any kind (including
microfilm, videotape and records , however produced or reproduced), electronic
mechanical and electrical records of any kind (including, without limitation
tapes, tape cassettes, disks and records), other data compilations (including,
without limitation, input/output files, source codes, object codes , program
documentation, computer programs, computer printouts, cards, tapes , disks and
recordings used in automated data processing together with the programming
instructions and other material necessary to translate, understand or use the ' same),
all drafts , prints, issues, alterations, modifications, changes and amendments to
the foregoing, and all other documents or tangible things of whatever description
that constitute or contain information within the scope of a Request that are in the
possession of Idaho Power. A Request seeking the identification or production of
documents addressing, relating or referring to, or discussing a specified matter
encompasses documents having a factual, contextual, or logical nexus to the
matter, as well as documents making explicit or implicit reference thereto in the
body of the documents. Originals and duplicates of the same document need not
be separately identified or provided; however, drafts of a document or documents
differing from one another by initials, interlineations, notations, erasures , file
stamps, and the like shall be deemed to be distinct documents requiring separate
identification or production.
Communication" shall mean any transmission of information by oral, graphic
written, pictorial , or otherwise perceptible means, including, but not limited to
telephone conversations, letters, telegrams, and personal conversations. A
Request seeking the identity of a communication addressing, relating or referring
, or discussing a specified matter encompasses documents having factual
contextual, or logical nexus to the matter, as well as communications in which
explicit or implicit reference is made to the matter in the course of the
communication.
The "substance" of a communication or act includes the essence, purport or
meaning of the same, as well as the exact words or actions involved.
Words expressing the singular number shall be deemed to express the plural
number; those expressing the masculine gender shall be deemed to express the
feminine and neuter genders; those expressing the past tense shall be deemed to
express the present tense; and vice versa.
The unqualified term "" shall be construed either conjunctively or disjunctively
to bring within the scope of these Requests any matters that might otherwise be
construed to be outside their scope.
10.The unqualified term "person" shall mean an individual, corporation, partnership,
unincorporated association or other business or governmental entity.
11.The term indicates illustration by example, not limitation.
IDAHO POWER COMPANY CASE No. IPC-O3-
FEA's FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
FEA-
FEA-
FEA-
FEA-
Please provide copies of all requests for information submitted by other
parties to Idaho Power in this docket. This is an ongoing request.
Referring to the direct testimony of Maggie Brilz at page 15 , line 16 -
page 16, line 6:
( a) Provide a copy of the 2002 IRP.
(b) Define capacity deficits as used at page 15 , lines 19-20.
(c) Define generation-related marginal costs as used at page 15, line 25.
(d) Identify and explain in detail the principal causes underlying the
change from the early 1990s to the present in the months in which
Idaho Power s generation-related marginal costs are non-zero.
(e) Provide the magnitude (MW), date, and hour of Idaho Power
monthly system peaks from 1990 to the present.
Referring to the direct testimony of Maggie Brilz at page 16, line 16 -
page 18, line 13:
(a) Identify the sources of the generation-related marginal costs shown in
Exhibit No. 40 that were used to develop allocation factor DI0.
Provide all workpapers, studies, analyses , and documents supporting
and/or underlying the identified marginal costs.
(b) Identify the sources of the transmission-related marginal costs shown
in Exhibit No. 40 that were used to develop allocation factor D13.
Provide all workpapers , studies , analyses, and documents supporting
and/or underlying the identified marginal costs.
(c) Identify the sources of the energy-related marginal costs shown in
Exhibit No. 40 that were used to develop allocation factor EI0.
Provide all workpapers, studies, analyses, and documents supporting
and/or underlying the identified marginal costs.
(d) Explain in detail Idaho Power s rationale for selecting September-
May as nonsummer seasonal months in deriving the D IONS
allocation factor when generation capacity deficits occur only in
November-December during the nonsummer season.
Referring to the direct testimony of Maggie Brilz at page 17, lines 7-
(a) Explain in detail the rationale for averaging the actual and weighted
DI0 and D13 ratios.
IDAHO POWER COMPANY CASE No. IPC-O3-
FEA's FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
(b) Did Idaho Power consider using other methodologies in this case to
allocate generation capacity-related and transmission-related costs?
the answer is yes, identify and describe the methodology in detail and
explain Idaho Power s basis for rejecting each alternative allocation
methodology.
(c) Identify other utilities in the United States that use a methodology
identical to that used by Idaho Power to allocate generation capacity-
related and transmission-related costs. Provide all workpapers
studies, analyses, and documents supporting and/or underlying this
response.
FEA-Referring to the direct testimony of Maggie Brilz at page 17, lines 18-23:
(a) Explain in detail the rationale for weighting "the normalized monthly
energy usage for each customer class and special contract customer
by monthly marginal energy costs.
(b) Explain in detail what the EI0 ratio for each class is supposed to
indicate about that class' energy-related cost responsibility.
(c) Identify other utilities in the United States that use a methodology
identical to that used by Idaho Power to allocate energy-related costs.
Provide all workpapers, studies, analyses, and documents supporting
and/or underlying this response.
FEA-Referring to Exhibit No. 48:
(a) Describe in detail how Idaho Power determines whether service is
delivered at secondary, primary, or transmission voltage. Provide all
workpapers, studies, analyses, and documents supporting and/or
underlying this response.
(b) Provide all workpapers, studies, analyses, and documents supporting
and/or underlying the proposed voltage discounts in Schedules 9 and
19.
( c) Provide all studies and/or analyses of system losses by service voltage
prepared by or for Idaho Power in the past five years.
FEA-With respect to Idaho Power s last general rate case filed with the
Commission:
(a) Provide a copy of the cost-of-service study (both hard copy and
electronic copy on CD) filed in the case.
IDAHO POWER COMPANY CASE No. IPC-O3-
FEA's FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
(b) Provide a copy of the revenue (rate) spread (both hard copy and
electronic copy on CD) filed in the case in a format similar to the
format of Exhibit No. 61 filed in the current case. In addition
provide a copy of all testimony and exhibits (both hard copy and
electronic copy on CD) discussing and/or related to the revenue
spread filed in the last general rate case.
(c) Provide a copy of all testimony and exhibits (both hard copy and
electronic copy on CD) filed by the Company s cost-of-service
witness in the case.
(d) Provide a copy of any cost-of-service study (both hard copy and
electronic copy on CD) conducted by or for Idaho Power between the
date of the order in the last general rate case and the cost study filed
in the current case.
FEA-Referring to the direct testimony of John Gale at page 11 , line 20 through
page 13, line 1:
(a) Explain in detail why the 25 percent limit was placed on the increase
to the irrigation customer class. Provide all workpapers , studies
analyses, and documents supporting and/or underlying this response.
(b) Describe in detail Idaho Power s plans to reduce the interclass
revenue subsidy received by the irrigation customer class. Provide all
workpapers, studies, analyses , and documents supporting and/or
underlying this response.
(c) What rate of return is earned from each customer class following
Idaho Power s spreading "the revenue shortfall created by the
mitigation back to the other customer classes.
. ..
" (page 12, lines 20-
22) Provide all workpapers , studies, analyses, and documents
supporting and/or underlying this response.
(d) If we assume that further adjustments to move rates for irrigation
customers closer to cost of service cannot occur between general rate
cases, identify the date (or general time frame) when Idaho Power
expects to file its next general rate case.
CERTIFICATE OF SERVICE
CASE NO. IPC-O3-
I HEREBY CERTIFY that on this 22nd day of December, 2003, I served or caused to be
served a true and correct copy of the foregoing document upon on each of the parties listed
below by placing the same in the u.S. Mail, postage prepaid:
Barton L. Kline, Esq.
Monica Moen
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707-0070
Email: blkine(~jdahopower.com
mmoen~idahopower.com
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
Email: rgale~idahopower.com
Lisa Nordstrom, Esq.
Commission Counsel
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702-0074
Email: Inordst~puc.state.id.
wstutzm~puc.state.id.
Peter 1. Richardson, Esq.
Richardson & O'Leary
99 E. State Street, Suite 200
O. Box 1849
Eagle, ID 83616
Email: peter~richardsonanddoleary .com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
Email: dreading~mindspring.com
Federal Executive Agencies ' First Set of Data Requests to Idaho Power Company
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge
Bailey, Chartered
201 E. Center
O. Box 1391
Pocatello, ID 83204-1391
Email: rcb~racinelaw.net
elo~racinelaw .net
Anthony Yankel
29814 Lake road
Bay Village, OH 44140
Email: yankel~attbi.com
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
Email: dgoinspmg~aol.com
Dean 1. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, ill 83701
Email: ioe~mcdevitt-miller.com
Jeremiah J. Healy
United Water Idaho, Inc.
O. Box 190420
Boise, ID 83719-0420
Email: ierry.healy~unitedwater/cp.
William M. Eddie
Advocates for the West
O. Box 1612
Boise, ID 83701
Email: billeddie~rmci.net
Nancy Hirsh
NW Energy Coalition
219 First Ave. South
Suite 100
Seattle, W A 98104
Email: nancy~nwenergy.org
Federal Executive Agencies ' First Set of Data Requests to Idaho Power Company
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
Email: cew~givenspursley.com
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street, S.
Suite 250
Salem, OR 97302
Email: dennytemp~yahoo.com
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
Email: bmpurdy~hotmail.com
Michael Karp
147 Appaloose Lane
Bellingham, W A 98229
Email: michawl~awish.net
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
Email: bmpurdy~hotmail.com
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
Boehm, Kurtz & Lowry
36 E. Seventh Street, Suite 2110
Cincinnati, OH 45202
Email:mkurtzlaw~aol. com
Assistant General Counsel
United States Department of Energy
Federal Executive Agencies' First Set of Data Requests to Idaho Power Company