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Home My WebLink About200401201st Request of Micron to ID Power.pdfConley E. Ward (ISB No. 1683) GIVENS PURSLEY LLP 601 W. Bannock Street O. Box 2720 Boise, ID 83701-2720 Telephone No. (208) 388-1200 Fax No. (208) 388-1300 cew~givenspursley.com F\tCE1VEO F!LED ~.. 2004 J,M~ I 3 Pi'i 2: 5~ , ' :jDLiC UTiL ITiES') COt"iI"1ISS ION Attorneys for Micron Technology, Inc. S:\CLIENTS\4489\17\Micron First Disc Req to IPCDOC BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS INTERIM AND BASE RATES AND CHARGES FOR ELECTRIC SERVCE Case No. IPC-03- MICRON TECHNOLOGY INc.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY YOU WILL PLEASE TAKE NOTICE that Micron Technology, Inc. ("Micron requests that Idaho Power Company ("Idaho Power ) answer, the following discovery requests in accordance with the Idaho Public Utilities Commission s Rules of Procedure. Definitions and Instructions The interrogatories and document requests are governed by the following definitions and instructions: Definitions You " " your" or "Idaho Power" means or pertains to the named respondent in this matter and includes, without limitation, Idaho Power, its officers, directors employees, agents, attorneys, corporate subsidiaries and affiliates OR\G\N~~ MICRON TECHNOLOGY, INC.S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - Persons" means any and all natural persons, corporations, businesses, firms companies, partnerships, unincorporated associations, governmental or public agencies, joint ventures and all other entities, including, without limitation, all employees, representatives, consultants and agents of any of the foregoing. Documents" means any and all written, electronic or graphic matter, of any kind or description, however created, produced, reproduced or stored, whether sent or received, or whether originals, copies or drafts, including, but not limited to every side of every page of all letters, papers, books, correspondence, bulletins circulars, instructions, telegrams, cables, telex messages, facsimiles, memoranda notes, notations, work papers, transcripts, minutes, reports, recordings of notes or meetings, conferences, interviews or telephone or other conversations, affidavits statements, summaries, opinions, studies, analyses, evaluations, work sheets contracts, agreements, journals, statistical records, desk or pocket calendars appointment books, diaries, lists, tabulations, advertisements, sketches, drawings blue prints, catalogs, audio or video records, photographs, computer printouts, e- mail transmissions, data processing input and output, deeds, microfilm, all other records kept by electronic, photographic or electrical means, and things similar to any of the foregoing however denominated. Relating to" or "Relate(s) to" means directly or indirectly mentioning, consisting , evidencing, describing, referring to, pertaining to, being connected with, or reflecting upon the stated subject matter. The words "any" and "all" shall be considered to include each and every. MICRON TECHNOLOGY, INC.S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - The singular of any word shall include the plural and the plural of any word shall include the singular. The word "expert" as used herein includes any person who will be offering expert testimony on behalf of Idaho Power or who has been consulted or relied upon by any person who assisted in the preparation of the responses to these interrogatories and document production requests or who will be offering testimony on behalf of Idaho Power in this matter. Instructions In answering these interrogatories and document requests, you are required to furnish all information that is available to you, or subject to your reasonable inquiry, including the information in the possession of you, your attorneys or other persons directly, or indirectly employed by, or connected with, you or your attorneys, and anyone else other wise subject to your control. In answering each interrogatory and document request: Identify by title, heading or caption, date, sender, recipient, location and custodian, each document relied upon, reviewed or which forms a basis for the response given or which corroborates or relates to the response given or the subject of what is given in response to these discovery requests; State whether the information furnished is within the personal knowledge of the person responding and, if not, the name, if known, of each person to whom the information is a matter of personal knowledge; Identify each person who assisted or participated in preparing and/or supplying any ofthe information given in response to or relied upon in preparing responses to these discovery requests; MICRON TECHNOLOGY, INc.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - Where a discovery request calls for a response in multiple parts, each part should be separated in the response so that the response is clearly understandable and complete; Where the name or identity of a person is requested, state the full name, business address, and any telephone numbers of each person; If any of your responses require the production of documents, label the documents to indicate the discovery request to which you are responding. If you object to the production of any document called for in these document requests, for each such document state the following: (1) the reasons for the objection and any facts supporting the objection; (2) give a description of each document including, without limitation, the date, sender, recipient(s), persons to whom copies have been furnished, job titles of each of the persons, subject matter of the document, number of pages of the document, the number(s) of the request to which such document is responsive and the identity of the person in whose custody the document is presently located. If any document is withheld under claim of privilege or work product, furnish a list identifying each document for which the privilege or work product is claimed, together with the following information for each such document: date, sender, recipient(s), persons to whom copies were furnished, job titles of each of those persons, subject matter of the document number of pages of the document, the bases on which the privileges or work product is claimed the paragraph(s) ofthese requests to which the document responds, the person in whose custody the document is presently located, and whether any matter that is not privileged or is not work product is discussed or mentioned in each document. If any document requested was, but is no longer in the possession or subject to the control ofldaho Power, or is no longer in existence, state whether it: (1) is missing or lost; (2) MICRON TECHNOLOGY, INc.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 4 has been destroyed; (3) has been transferred voluntarily or involuntarily to others and state the identity of the persons to whom it has been transferred; (4) has otherwise been disposed of, or in each instance explain the circumstances surrounding such disposition, state the date or approximate date thereof and the identity of the persons with knowledge of such circumstances; (5) identify the documents that are missing, lost, destroyed, transferred or otherwise disposed of by author, date, subject matter, addressee(s), and the number of pages. If you do not clearly understand, or have any questions about, these definitions instructions interrogatories or requests, contact counsel for Micron promptly for clarification. These discovery requests are continuing in nature and require supplemental responses upon the discovery or receipt of new or additional information. DISCOVERY REQUESTS 1. Please confirm or deny that the energy allocators used in Idaho Power s sponsored cost of service study, specifically on page 5 of 6, Exhibit No. 40, are monthly allocators weighted by marginal energy costs. 2. On page 14, lines 23-25 and page 15, lines 1-3 of her testimony, Ms. Brilz indicates that she has allocated demand-related costs according to a weighted 12 Coincident Peaks allocation method. Are the generation and transmission demand allocators actually used in the final cost study allocations the weighted 12-CP allocators shown on page 2 and 3 of 6 of Exhibit 40 as stated in Ms. Brilz testimony? If not, please explain. 3. Are the generation and transmission demand allocators actually used in the final cost study allocations a simple average of the unweighted and weighted allocators? 4. If the answer to 3 above is yes, please reference Company testimony in these proceedings that explains this, or state why the referenced weighted demand allocators D 1 0 and D 13 where not used, despite testimony saying they were. 5. Please re-do the Exhibit 40 cost of service study using the Weighted 12 Coincident Peaks generation and transmission demand allocators. 6. Please provide a copy ofldaho Power s Integrated Resource Plan currently on file with the Idaho Public Utilities Commission. Also, please provide a copy of any draft Integrated Resource Plan. MICRON TECHNOLOGY, INc.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 7. Please provide copies of all FERC jurisdictional power supply contracts with a term of greater than one year in effect during any portion ofthe calendar years from 1996-2003 inclusive. Include both sale and purchase contracts. DATED this 13th day of January 2004. Con y GIV NS PURSLEY LLP Attorneys for Micron Technology, Inc. MICRON TECHNOLOGY, INC.S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 13th day of January 2004, I caused to be served a true and correct copy of the foregoing by the method indicated below, and addressed to the following: Jean Jewell Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, ID 83720-0074 S. Mail Hand Delivered Overnight Mail Facsimile Mail S. Mail Hand Delivered Overnight Mail Facsimile Mail S. Mail Hand Delivered Overnight Mail Facsimile Mail S. Mail Hand Delivered Overnight Mail Facsimile Mail Barton L. Kline Monica B. Moen Idaho Power Company O. Box 70 Boise, ID 83707 John R. Gale Vice President Regulatory Affairs Idaho Power Company O. Box 70 Boise, ID 83707 Lisa Nordstrom Weldon Stutzman Deputy Attorney Generals Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, ID 83720-0074 Peter J. Richardson Richardson & O'Leary 99 E. State Street, Ste. 200 O. Box 1849 Eagle, ID 83616 u.S. Mail Hand Delivered Overnight Mail Facsimile Mail Don Reading Ben Johnson Associates 6070 Hill Road Boise, ID 83703 S. Mail Hand Delivered Overnight Mail Facsimile Mail MICRON TECHNOLOGY, INC.S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - Randall C. Budge S. Mail Eric L. Olsen Hand Delivered Racine, Olson, Nye, Budge, Bailey Overnight Mail 201 E. Center Facsimile O. Box 1391 Mail Pocatello, ID 83204-1391 Anthony Yankel S. Mail 29814 Lake Road Hand Delivered Bay Village, OH 44140 Overnight Mail Facsimile Mail Lawrence A. Gollomp S. Mail Assistant General Counsel Hand Delivered S. Department of Energy Overnight Mail 1000 Independence Ave. SW Facsimile Washington, DC 20585 Mail Dennis Goins S. Mail Potomac Management Group Hand Delivered 5801 Westchester Street Overnight Mail Alexandria, VA 22310-1149 Facsimile Mail Dean 1. Miller S. Mail McDevitt & Miller Hand Delivered O. Box 2564 Overnight Mail Boise, ID 83701 Facsimile Mail Jeremiah J. Healy S. Mail United Water Idaho Inc.Hand Delivered O. Box 190420 Overnight Mail Boise, ID 83719-0420 Facsimile Mail William M. Eddie S. Mail Advocates for the West Hand Delivered O. Box 1612 Overnight Mail Boise, ID 83701 Facsimile Mail MICRON TECHNOLOGY, INc.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8 Nancy Hirsh u.S. Mail NW Energy Coalition Hand Delivered 219 First Ave. South, Ste. 100 Overnight Mail Seattle, W A 98104 Facsimile Mail Dennis E. Peseau, Ph.S. Mail Utility Resources, Inc.Hand Delivered 1500 Liberty Street SE, Ste. 250 Overnight Mail Salem, OR 97302 Facsimile Mail Brad M. Purdy S. Mail Attorney at Law Hand Delivered 2019 N. 17th Street Overnight Mail Boise, ID 83702 Facsimile Mail Michael Karp S. Mail 147 Appaloosa Lane Hand Delivered Bellingham, W A 98229 Overnight Mail Facsimile Mail Michael L. Kurtz S. Mail Kurt J. Boehm Hand Delivered Boehm, Kurtz & Lowry Overnight Mail 36 E. Seventh Street, Ste. 2110 Facsimile Cincinnati, OH 45202 Mail Thomas M. Power S. Mail Economics Department Hand Delivered Liberal Arts Building 407 Overnight Mail University of Montana Facsimile 32 Campus Drive Mail Missoula, MT 59812 MICRON TECHNOLOGY, INc.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY -