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Home My WebLink About200402122nd Response of ID Power to NW Energy Coalition.pdfBARTON L. KLINE ISB #1526 MONICA B. MOEN ISB #5734 Idaho Power Company P. O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 FAX Telephone: (208) 388-6936 Idaho Public Utilities Commission Office of the SecretaryRECEIVED FEB 1 2 200~ Boise, Idaho Attorney for Idaho Power Company Street Address for Express Mail 1221 \!yest 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 SECOND PRODUCTION REQUEST OF NW ENERGY COALITION COMES NOW, Idaho Power Company ("Idaho Power" or "the Company and in response to the Second Production Request of the NW Energy Coalition to Idaho Power Company, herewith submits the following information: REQUEST NO. 11: Are costs associated with the preparation of the Annual Reports (years 1995 through 2001) on the status of the Idaho Springsnail , Bliss Rapids Snail , Utah Valvata, Banbury Springs Lanx, Snake River physa included in the Company s calculation of revenue requirement? If such costs are included, please state the amount. IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF NW ENERGY COALITION Page RESPONSE TO REQUEST NO. 11: Capitalized relicensing costs relating to mid-Snake invertebrate studies and preparing the reports for 1997 through 2001 are included in the Company s calculation of revenue requirement. While the Company does not separate costs specifically to the single category requested, activities including field data collection , sample taxonomy, and report preparation , are included in this case in the amount of $1 ,016 520. Costs incurred in 1995 and 1996 were expensed. The response to this request was prepared under the direction of Maggie Brilz , Pricing Director, Idaho Power Company, in consultation with Barton L. Kline Senior Attorney, Idaho Power Company. REQUEST NO. 12: Are costs associated with Dr. Gary Finni' independent review of the Annual Reports identified in Request No. 11 (above) included in the Company s calculation of revenue requirement? If such costs are included , please state the amount. RESPONSE TO REQUEST NO. 12: Costs of Dr. Finni's independent review have been incurred by the Company and are recorded in Construction Work In Progress - Account 107. Since these costs have not yet closed to Electric Plant In Service - Account 101 , they are not included in the revenue requirement calculation in this case. The response to this request was prepared under the direction of Maggie Brilz , Pricing Director, Idaho Power Company, in consultation with Barton L. Kline Senior Attorney, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF NW ENERGY COALITION Page 2 REQUEST NO. 13: Are costs associated with the preparation , filing, and withdrawal of petitions to the U.S. Fish and Wildlife Service to de-list the Bliss Rapid Snail and the Idaho Springsnail from the lists of "threatened" and "endangered" species respectively, under the Endangered Species Act , 16 U.C. 9 1531 et seq.included in the Company s calculation of revenue requirement? If such costs are included , please state the amount. RESPONSE TO REQUEST NO. 13: Capitalized relicensing costs specifically relating to some de-listing activities are included in the Company calculation of revenue requirement. The amount is $114 593. Costs of additional de- listing activities have been incurred by the Company and are recorded in Construction Work In Progress - Account 107. Since these costs have not yet closed to Electric Plant In Service - Account 101 , they are not included in the revenue requirement calculation in this case. The response to this request was prepared under the direction of Maggie Brilz, Pricing Director , Idaho Power Company, in consultation with Barton L. Kline Senior Attorney, Idaho Power Company. REQUEST NO. 14: Please state the amount of hydropower relicensing costs (including any expected future costs for relicensing) included in the Company calculation of revenue requirement associated with the following categories of activities: (a) collaborative processes, (b) field surveys, consultants , and preparation of technical reports, (c) application and environmental impact statement preparation and (d) litigation. IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF NW ENERGY COALITION Page 3 RESPONSE TO REQUEST NO. 14: Idaho Power Company does not segregate costs in the specific categories described in this request. Total capitalized relicensing costs included in the Company s calculation of revenue requirement in this case are $7,447 005. This amount includes collaborative process activities, field surveys, consultant services, and preparation of technical reports , applications and environmental assessments. Other relicensing related activities are included as well. There are no litigation costs included in the total. The response to this request was prepared under the direction of Maggie Brilz, Pricing Director, Idaho Power Company, in consultation with Barton L. Kline Senior Attorney, Idaho Power Company. .t-.\A DATED at Boise, Idaho, this day of February, 2004. '-- BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF NW ENERGY COALITION Page 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this ~ ~ ay of February, 2004 , I served a true and correct copy of the within and foregoing IDAHO POWER COMPANY' RESPONSE TO SECOND PRODUCTION REQUEST OF NW ENERGY COALITION 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 Hand Delivered S. Mail Overnight Mail FAX (208) 334-3762 Randall C. Budge Eric L. Olsen Racine , Olson , Nye , Budge & Bailey O. Box 1391; 201 E. Center Pocatello , ID 83204-1391 Hand Delivered S. Mail Overnight Mail FAX (208) 232-6109 Anthony Yankel 29814 Lake Road Bay Village, OH 44140 Hand Delivered S. Mail Overnight Mail FAX (440) 808-1450 Peter J. Richardson Richardson & O'Leary 99 East State Street, Suite 200 O. Box 1849 Eagle, ID 83616 Hand Delivered x U.S. Mail Overnight Mail FAX (208) 938-7904 Don Reading Ben Johnson Associates 6070 Hill Road Boise , ID 83703 Hand Delivered x U.S. Mail Overnight Mail FAX (208) 384-1511 Lawrence A. Gollomp Assistant General Counsel U. S. Department of Energy 1000 Independence Avenue , SW Washington , D.C. 20585 Hand Delivered S. Mail Overnight Mail FAX (202) 586-7479 CERTIFICATE OF SERVICE , Page Dennis Goins Potomac Management Group 5801 Westchester Street Alexandria, VA 22310-1149 Hand Delivered S. Mail Overnight Mail FAX Conley E. Ward Givens , Pursley LLP 601 W. Bannock Street O. Box 2720 Boise, ID 83701-2720 Hand Delivered x U.S. Mail Overnight Mail FAX (208) 388-1300 Dennis E. Peseau, Ph.D. Utility Resources, Inc. 1500 Liberty Street S., Suite 250 Salem , OR 97302 Hand Delivered S. Mail Overnight Mail FAX (503) 370-9566 Dean J. Miller McDevitt & Miller LLP O. Box 2564 Boise , ID 83701 Hand Delivered x U.S. Mail Overnight Mail FAX (208) 336-6912 Jeremiah Healy United Water Idaho, Inc. O. Box 190420 Boise , ID 83719-0420 Hand Delivered x U.S. Mail Overnight Mail FAX (208) 362-7069 William M. Eddie Advocates for the West O. Box 1612 Boise, ID 83701 Hand Delivered x U.S. Mail Overnight Mail FAX (208) 342-8286 Nancy Hirsh NW Energy Coalition 219 First Ave. South , Suite 100 Seattle , WA 98104 Hand Delivered S. Mail Overnight Mail FAX (206) 621-0097 Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise , ID 83702 Hand Delivered x U.S. Mail Overnight Mail FAX (208) 384-8511 Michael Karp 147 Appaloosa Lane Bellingham, WA 98229 Hand Delivered S. Mail Overnight Mail FAX (360) 724-5272 CERTIFICATE OF SERVICE, Page 2 Michael L. Kurtz, Esq. Kurt J. Boehm, Esq. Boehm , Kurtz & Lowry 36 East Seventh Street, Suite 2110 Cincinnati , OH 45202 Kevin Higgins 39 Market Street, Suite 200 Salt Lake City, UT 84101 Thomas M. Power Economics Department, LA 407 University of Montana 32 Campus Drive Missoula, MT 59812 CERTIFICATE OF SERVICE, Page 3 Hand Delivered S. Mail Overnight Mail FAX (513) 421-2764 Hand Delivered S. Mail Overnight Mail FAX Hand Delivered S. Mail Overnight Mail FAX /lli BARTON L. KLINE