200402101st Response of ID Power to Micron.pdf

BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
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 FORELECTRIC SERVICE.
CASE NO. IPC-03-
IDAHO POWER COMPANY'
RESPONSE TO MICRON
TECHNOLOGY INC.'S FIRST SET
OF DISCOVERY REQUESTS
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in response to the First Set of Discovery Requests to Idaho Power Company dated
January 13, 2004 , herewith submits the following information:
REQUEST NO.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.
RESPONSE TO REQUEST NO.The energy allocators used in Idaho
Power s cost-of-service study and included on pages 5 and 6 of 6 of Exhibit No. 40 are
IDAHO POWER COMPANY'S RESPONSE TO MICRON TECHNOLOGY
INC.'S FIRST SET OF DISCOVERY REQUESTS Page
the ratios of the summer and non-summer normalized monthly energy consumption
adjusted for losses and weighted by marginal energy costs.
The response to this request was prepared by Maggie Brilz, Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO.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.
RESPONSE TO REQUEST NO.2: Yes. The generation and
transmission demand allocators actually used in the cost-of-service study are the
weighted 12-CP allocators shown on pages 1 through 4 of Exhibit No. 40.
The response to this request was prepared by Maggie Brilz , Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO.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?
RESPONSE TO REQUEST NO.3: Yes. The generation and
transmission demand allocators actually used in the cost-of-service study are a simple
IDAHO POWER COMPANY'S RESPONSE TO MICRON TECHNOLOGY
INC.'S FIRST SET OF DISCOVERY REQUESTS Page 2
average of the weighted and unweighted ratios for the summer and non-summer
months.
The response to this request was prepared by Maggie Brilz , Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO.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 D1 0 and D13 where not used, despite testimony saying
they were.
RESPONSE TO REQUEST NO.4: Lines 2 through 9 on page 17 of the
testimony of Company witness Brilz describes the steps taken to compute the average
of the actual and weighted generation and transmission demand ratios. The referenced
section of the testimony refers generically to the ratios D10 and D13 for simplicity in
describing the steps taken to compute the averages. As pointed out by Micron , the
ratios D1 0 and D13 are not used as allocators in the cost-of-service study. Lines 2
through 11 on page 18 of the testimony of Company witness Brilz explain how weighted
factors for both the summer and non-summer seasons were computed and specify that
the factors used to allocate the demand-related portion of production plant and
transmission plant are the factors designated as D10S , D10NS, D13S, and D13NS.
Exhibit No. 40 details the derivation of these allocation factors.
The response to this request was prepared by Maggie Brilz , Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO MICRON TECHNOLOGY
INC.'S FIRST SET OF DISCOVERY REQUESTS Page 3
REQUEST NO.5: Please re-do the Exhibit 40 cost of service study using
the Weighted 12 Coincident Peaks generation and transmission demand allocators.
RESPONSE TO REQUEST NO.5: Exhibit No. 40 is the spreadsheet
used to develop the weighted allocation factors for demand-related production plant and
transmission plant using the 12 coincident peak demands for each customer class. The
weighted factors developed on Exhibit No. 40 are the allocators used in the class cost-
of-service study. Exhibit No. 40 develops the weighted 12 coincident peak demand
allocation factors.
The response to this request was prepared by Maggie Brilz , Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO.6: Please provide a copy of Idaho 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.
RESPONSE TO REQUEST NO.6: Idaho Power s 2002 Integrated
Resource Plan currently on file with the Idaho Public Utilities Commission has
previously been provided in response to the Idaho Irrigation Pumpers Association
Second Data Requests to Idaho Power Company, Request No. 33. Idaho Power does
not currently have a draft of an Integrated Resource Plan.
The response to this request was prepared by Gregory W. Said , Director
of Revenue Requirement, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO MICRON TECHNOLOGY
INC.'S FIRST SET OF DISCOVERY REQUESTS Page 4
REQUEST NO.7: Please provide copies of all FERC jurisdictional power
supply contracts with a term of greater than one year in effect during any portion of the
calendar years from 1996-2003 inclusive. Include both sale and purchase contracts.
RESPONSE TO REQUEST NO.7: The requested material is voluminous
and as such will be made available for review at Idaho Power s Corporate
Headquarters. Any party desiring to review documents in the discovery room should
call Myrna Aasheim at 388-2558 to arrange a time for such review. In 2003 the
Company signed a purchase contract with PPL Montana that is scheduled to begin in
June of 2004. That agreement is not included in the material provided.
The response to this request was prepared by Phil A. Obenchain , Senior
Analyst, Pricing and Regulatory Services, Idaho Power Company, in consultation with
Barton L. Kline , Senior Attorney, Idaho Power Company.
DATED at Boise , Idaho, this 10th day of February, 2004.
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO MICRON TECHNOLOGY
INC.'S FIRST SET OF DISCOVERY REQUESTS Page 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of February, 2004, I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO MICRON TECHNOLOGY INC.'S FIRST SET OF DISCOVERY
REQUESTS upon the following named parties by the method indicated below , and
addressed to the following:
Lisa D. Nordstrom
Weldon B. Stutzman
Deputy Attorneys General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
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Randall C. Budge
Eric L. Olsen
Racine , Olson, Nye, Budge & Bailey
O. Box 1391; 201 E. Center
Pocatello , ID 83204-1391
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Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
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Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle , ID 83616
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Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
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Lawrence A. Gollomp
Assistant General Counsel
U. S. Department of Energy
1000 Independence Avenue , SW
Washington , D.C. 20585
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Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
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Conley E. Ward
Givens , Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise , ID 83701-2720
Dennis E. Peseau , Ph.D.
Utility Resources , Inc.
1500 Liberty Street S., Suite 250
Salem, OR 97302
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, ID 83701
Jeremiah Healy
United Water Idaho, Inc.
O. Box 190420
Boise, ID 83719-0420
William M. Eddie
Advocates for the West
O. Box 1612
Boise, ID 83701
Nancy Hirsh
NW Energy Coalition
219 First Ave. South , Suite 100
Seattle, WA 98104
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
Michael Karp
147 Appaloosa Lane
Bellingham , WA 98229
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
Boehm , Kurtz & Lowry
36 East Seventh Street , Suite 2110
Cincinnati , OH 45202
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Kevin Higgins
39 Market Street , Suite 200
Salt Lake City, UT 84101
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Thomas M. Power
Economics Department , LA 407
University of Montana
32 Campus Drive
Missoula, MT 59812
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BARTON L. KLINE
CERTIFICATE OF SERVICE, Page 3