20040217Supplemental 1st Resp of IPC to Industrial Cust Part I.pdf

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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 FIRST
PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in response to the balance of the First Set of Production Requests of the Industrial
Customers of Idaho Power received by Idaho Power, hereby responds to the following
requests:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.1: Please provide any and alllPC data and analyses
projecting the monthly billing impact on each Schedule 19 customer of the proposed
mandatory time-of-use rates for a full 12 month calendar cycle.
RESPONSE TO REQUEST NO.1: Idaho Power does not disclose
information that its customers expect Idaho Power to maintain as confidential
information. A number of Schedule 19 customers directly compete with each other and
the requested information would be competitively valuable information. A redacted
version of the requested information will be made available upon execution of an
appropriate confidentiality agreement.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.2: Please provide any and all data and analyses of the
benefits, savings and increased revenues from implementation of mandatory time-of-
use rates for Schedule 19 versus other IPC rate classes.
RESPONSE TO REQUEST NO.2: No analyses attempting to identify
any potential benefits or savings associated with mandatory time-of-use rates for
Schedule 19 customers have been performed. The time-of-use rates are designed to
be revenue neutral. As such , no increased revenues are anticipated from the
implementation of time-of-use rates.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.3: Please provide any and all data and analyses of the
benefits , savings and increased revenues from implementation of mandatory time-of-
use rates for any other rate class.
RESPONSE TO REQUEST NO.3: In September 2002, Idaho Power
submitted to the Commission a Residential Time-of-Use Pricing Viability Study. A copy
of the study is enclosed with this response. No other studies have been prepared.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.4: With reference to Request for Production No., if no
such analysis was conducted for any other rate class, please explain why not.
RESPONSE TO REQUEST NO.4: No additional analyses have been
performed for other rate classes because the Company is not proposing to implement
mandatory time-of-use rates for other rate classes.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.5: Please provide any and all data and analyses
supporting mandatory time-of use rates for the Schedule 19 rate class only.
RESPONSE TO REQUEST NO.5: The requirement that all customers
with loads of a certain size or greater take service under a time-of-use schedule is
relatively common in jurisdictions surrounding Idaho. For example , customers with
loads of 1 000 kW or more taking service from Sierra Pacific Power in Nevada and
Pacific Power & Light in Washington and Wyoming are required to take time-of-use
service. In California , customers with loads of 500 kW or more served by Pacific Power
& Light and Southern California Edison are required to take mandatory time-of-use
service. The threshold for mandatory time-of-use service for California customers of
Sierra Pacific Power is 200 kW of load and for all new commercial customers of San
Diego Gas & Electric is 20 kW of load. Idaho Power took these mandatory
requirements of neighboring utilities into account in making its determination to propose
mandatory time-of-use service for its Schedule 19 customers.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.6: Please provide any and all data and analyses that
demonstrate that Schedule 19 customers are responsible versus other IPC rate classes
for IPC's need for new peaking resources.
RESPONSE TO REQUEST NO.6: The need for new generation
(including peaking) resources is determined by comparing existing generation
capabilities to total system loads. Individual customer class loads contribute to the total
system load , however the Company does not perform studies to determine class
responsibility" for the need to add additional resources. Once a resource is added , the
costs of that resource are included in the total of all resource investments which are
allocated to jurisdictions and customer classes based upon the jurisdictional and class
contributions to total system peak and load.
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 FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.7: Please explain IPC's rationale including data and
analyses in proposing rates that place more fixed costs in demand and customer
charges rather than keeping them in the energy charge.
RESPONSE TO REQUEST NO.7: Please refer to the testimony of
Company witness Brilz, page 25 , line 3 through page 26, line 9 for the rationale for
proposing rates that place more fixed costs in demand and customer charges. Please
refer to Exhibit No. 42 for the data detailing the unit costs for each metered customer
class.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.8: Please provide any and all data and analyses used to
determine which distribution facilities and customer service related expenses do not
vary with the amount of energy being used and are proposed to be removed from the
energy charge and placed in the proposed Service Charge for alllPC rate classes.
RESPONSE TO REQUEST NO.8: Exhibit No. 42 details the specific
costs for each customer class categorized into the Service Charge component.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.9: Please provide any and all data and analyses that
support IPC's request to change the Power Factor Adjustment provisions in proposed
Schedules 9 , 19 , and 24 that increases the minimum power factor from 85% to 90%.
RESPONSE TO REQUEST NO.9: Idaho Power requires the distribution
system reactive loads to be fully compensated to minimize losses and maintain system
capacity. The increase in the minimum power factor from 85% to 90% brings the
requirement for reactive load for individual customers closer to the system requirement.
Idaho Power took the power factor requirements of neighboring utilities into account in
making its determination to increase the minimum power factor to 90%.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO.1 0: By what standard does Ms. Brilz' conclude that a
customer power factor between 85% and 90% is "poor
RESPONSE TO REQUEST NO.1 0: A customer s power factor is
considered poor if it does not meet the stated level. The Company has proposed
raising the stated level required from 85% to 90%. The power factor of any customer
that does not attain the 90% would be considered poor.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 12: Please provide any and all analyses IPC plans to use
to calculate "the amount of capacity required" at a single point of delivery as stated in
Ms. Brilz' testimony regarding changes to Rule C. Reference Ms. Brilz' testimony at
page 31.
RESPONSE TO REQUEST NO. 12: The current process undertaken by
Idaho Power to determine the amount of capacity required at a single point of delivery
involves discussions with the individual customer to identify the equipment to be utilized
and any anticipated growth in service needs in the next few years. Based on these
discussions, the amount of capacity required at the point of delivery is agreed upon by
the customer and the Company. The Company intends to continue using this process
to determine the amount of capacity provided under the Uniform Service Agreement
proposed under Rule C.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 14: Please provide records that show location and size of
service transformers for all Schedule 19 customers.
RESPONSE TO REQUEST NO. 14: The number of transformers by kVa
size and county location for those Schedule 19 customers utilizing Company-owned
facilities is enclosed with this response.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 15: Please provide copies of the SCE , PG&E and CSU
pricing schedules as referenced in M. Brilz' testimony.
RESPONSE TO REQUEST NO. 15: The requested information is
enclosed with this response.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 16: Please provide copies of records of all Contributions-
in-Aid-of Construction for substation and transmission facilities requested by Idaho
Power Company from 1993 to 2003.
RESPONSE TO REQUEST NO. 16: The Company does not maintain
records of requests for service that do not reach fruition. Please see the Response to
Request No. 17 for Contributions in Aid of Construction received for projects that were
constructed.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 17: Please provide copies of records of all Contributions-
in-Aid-of Construction paid by Idaho Power Company customers from 1993 to 2003.
RESPONSE TO REQUEST NO. 17: The requested information for the
years 1998 through 2002 is enclosed with this response. The information for the years
1993 to 1997 is not readily available due to the conversion to new financial software.
The response to this request was prepared by Darrell R. Tomlinson
Finance Team Leader, Financial Research/Support , Idaho Power Company, in
consultation with Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 18: Please provide copies of all records of the amount of
substation and transmission CIAC collected from 1993 to 2003 that was allocated to the
Schedule 19 rate class.
RESPONSE TO REQUEST NO. 18: The amount of substation CIAC
assigned to the Schedule 19 customer class is detailed on pages 4 and 5 of the
workpapers of Company witness Brilz. No transmission CIAC has been directly
assigned to the Schedule 19 customer class.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO .19: Please provide copies of all records of "net plus
CIAC" data and analyses. Reference page 24 of Ms. Brilz' testimony.
RESPONSE TO REQUEST NO. 19: All data and analyses supporting the
net plus CIAC" distribution substation investment can be found in the workpapers of
Company witness Brilz at pages 2 through 9 and in the workpapers of Company
witness Obenchain at pages 17 through 34.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 20: Please provide copies of all documents that detail
and identify the "non-interruptible seasonal loads" referenced in Mr. Said's testimony.
RESPONSE TO REQUEST NO. 20: The addition of "non-interruptible
seasonal loads" mentioned in Mr. Said's testimony refers to the loads discussed in the
previous lines of the paragraph from which the quote contained in the question was
taken. As stated by Mr. Said in those lines of testimony, "the FMC load had an
interruptible component." Idaho Power has no other customer loads that are subject to
economic interruption provisions so all load growth has been non-interruptible. Mr.
Said's testimony then states that "Load growth within various customer classes has
tended to be much more seasonal." Residential , commercial and irrigation loads tend
to be the most seasonal , however, any individual customer within any customer class
may have seasonal consumptive patterns.
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 FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 21: Please provides the anniversary dates of all
Schedule 19 customers.
RESPONSE TO REQUEST NO. 21: Idaho Power does not voluntarily
disclose information that its customers expect Idaho Power to maintain as confidential
information. In order to protect the confidentiality of the Schedule 19 customers , any
identifying information has been removed from the information provided.
The annual review provision included under Schedule 19 provides that
each customer s account will be reviewed for continued eligibility during the billing
period in which the anniversary date falls. Because only the month of the billing period
is necessary to perform the annual review, Idaho Power tracks only the anniversary
month, not the month and year. Enclosed is a listing showing the number of customers
for each anniversary month.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 22: Please provide a copy of the bill form for the
proposed Schedule 19 mandatory time-of-use rate.
RESPONSE TO REQUEST NO. 22: Enclosed is a sample bill form that
illustrates the time-of-use rate structure proposed for Schedule 19. The rates used in
the sample are simply placeholder rates utilized to test the rate structure within the
Company s billing system and are not reflective of the Company s request.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 23: Please provide data and analyses that document the
change in annual system load factor for each year from 1993 to 2003.
RESPONSE TO REQUEST NO. 23: The requested information has
previously been provided in Idaho Power Company s Response to AARP's First
Production Request, Request No. 14.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 24: Please provide data and analyses that document the
change in annual load factor for each rate schedule for each year from 1993 to 2003.
RESPONSE TO REQUEST NO. 24: The requested information for the
years 1996 - 2002 is enclosed with this response. The information for the years 1993 -
1995 is not readily available.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 25: Please provide all data and analyses for classification
of distribution accounts 364, 365 , 366 , 367 and 368 including data and analyses used
in developing classification factors for these accounts.
RESPONSE TO REQUEST NO. 25: The requested data has previously
been provided in Idaho Power Company s Response to Idaho Irrigation Pumpers
Association s Second Data Request, Request No. 41 (f).
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 26: Please provide copies of all customer satisfaction
surveys from 1993 to 2003.
RESPONSE TO REQUEST NO. 26: Customer satisfaction surveys are
available from 1995 to 2003. Because of its volume, the requested information is
available in the Company s discovery room located 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.
The response to this request was prepared by Sue Fullen , General
Manager Qf Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 27: Please provide copies of any and all documents
detailing efforts to improve customer relations with Schedule 19 customers.
RESPONSE TO REQUEST NO. 27: Because of its volume, the
requested information is available in the Company s discovery room located 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.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 28: Please provide by year from 1993 to 2003 copies of
all conservation , demand side management and renewable energy programs executed
by Idaho Power.
RESPONSE TO REQUEST NO. 28: The Company s annual
Conservation Plans for each of the years 1993 through 2002 and information on the
Company s Green Power Program provide the requested information. Because of their
volume, the Conservation Plans and information on the Company s Green Power
Program are available in the discovery room located 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.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 29: Please provide all data and analyses documenting
costs and results of all conservation , demand side management and renewable energy
programs executed by Idaho Power from 1993 to 2003.
RESPONSE TO REQUEST NO. 29: The requested information is
provided in response to Request No. 28.
The response to this request was prepared by Sue Fullen , General
Manager of Customer Services and Metering, Idaho Power Company, in consultation
with Barton L. Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 30: Please provide monthly load profile reports for all rate
schedules for 2003.
RESPONSE TO REQUEST NO. 30: In the ordinary course of its
business , Idaho Power does not produce monthly load profile reports and is unable to
do so without undertaking significant analysis and program design. Such an
undertaking would be unreasonably burdensome.
The response to this request was prepared under the direction of Maggie
Brilz, Director of Pricing, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 31: Please provide lists of any and all costs referred to as
fixed and unrelated to usage patterns" referred to in Ms. Brilz' testimony.
RESPONSE TO REQUEST NO. 31: The testimony of Company witness
Brilz does not include the text referenced by the ICIP in its request. The specific
context of the ICIP's request is therefore not clear. In order to be responsive , however
the Company has assumed that the ICI P is requesting a listing of the costs categorized
for inclusion in the service charge. The specific components identified for inclusion
the service charge can be found for each customer class on Exhibit No. 42 under the
column heading "Service , ($/cust/mo)".
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 33: Please provide data and analysis supporting any and
all changes proposed for Rule H.
RESPONSE TO REQUEST NO. 33: The Company has not proposed any
changes to Rule H.
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 FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 34: Please explain the rationale for closing the option of
Schedule 25 to new participants while at the same time proposing a mandatory TOU for
Schedule 19 customers.
RESPONSE TO REQUEST NO. 34: Time-of-use service to irrigation
customers currently requires the installation of a new meter capable of recording usage
by both in- and out-of-season and by time-of-use period. All Schedule 19 customers
currently have the metering in place to accommodate time-of-use service. Additionally,
the Company desires to evaluate the potential impact of time-of-use pricing on irrigation
system equipment design and the subsequent impact on system load any changes in
design might have prior to determining any expansion or elimination of the irrigation
time-of-use service.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 35: Please explain Idaho Power s rationale for proposing
a new Schedule 19 rate that can have as many as 3 demand charges on one monthly
bill.
RESPONSE TO REQUEST NO. 35: As stated by Company witness Brilz
in her testimony at page 27, lines 9 through 18 , the seasonal time-of-use rates are
intended to encourage reduced consumption during both the summer months and the
daily peak hours. The addition of an on-peak demand charge for Schedule 19
customers is intended to provide the price signal to encourage reduced consumption
during the higher cost on-peak period.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 36: Please provide records of any and all meetings
and/or discussions Idaho Power has had with Schedule 19 customers as a group
regarding the proposed changes in Schedule 19.
RESPONSE TO REQUEST NO. 36: Maggie Brilz, Pricing Director
Warren Kline, General Manager of Regional Operations , and Ric Gale, Regulatory
Affairs Vice President, Regulatory Affairs , met with the Industrial Customers of Idaho
Power regarding rate case proposals on September 2 2003. Ms. Brilz, Mr. Gale, and
other Idaho Power representatives have met with other Schedule 19 customers and
Special Contract Customers individually.
The response to this request was prepared by John R. Gale , Vice
President, Regulatory Affairs , Idaho Power Company, in consultation with Barton L.
Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 37: Please provide copies of any and all data and
analyses documenting the potential economic impact on Idaho s economy of the
proposed Schedule 19 changes.
RESPONSE TO REQUEST NO. 37: No analyses as described have
been prepared.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 38: Please explain the contractual process required of
Schedule 9 and Schedule 19 customers as their capacity requirement increases above
1000 KW or drops below 1000 KW respectively.
RESPONSE TO REQUEST NO. 38: Idaho Power currently monitors the
usage of its Schedule 9 customers to identify those customers whose usage is
approaching or has exceeded 1 000 kW. Idaho Power also monitors the usage of its
Schedule 19 customers to identify those customers whose usage has dropped below
000 kW. Schedule 9 customers whose usage is either approaching or has exceeded
000 kW and Schedule 19 customers whose usage has dropped below 1 000 kW are
contacted by the Company s delivery services representatives to discuss the customers
future energy requirements. The process described in the Company s response to ICIP
Request No. 12 is then followed to determine the amount of capacity required by an
individual customer. Under the proposed changes to Rule C, any customer who
requires 1 000 kW of capacity or more will be presented with a Uniform Service
Agreement specifying the agreed upon amount of capacity available at the service
point. The Uniform Service Agreement for those customers who no longer require
000 kW of capacity will be terminated as described on page 9 of Exhibit No. 49.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 39: Please provide copies of any and all data and
analyses that support keeping the relationship between Schedule 9 and Schedule 19
Basic and Demand charges the same for different service levels.
RESPONSE TO REQUEST NO. 39: The data detailing the costs
associated with the demand and basic charges is included on Exhibit No. 42.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 40: Please provide copies of any and all data and
analyses that support the overall increase of 24% for Primary and Transmission service
level customers for Schedule 9 customers.
RESPONSE TO REQUEST NO. 40: The requested data is shown on
Exhibit No. 42 , page 4 , line 540, columns (C) and (D).
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 41: Please provide copies of any and all data that
support Schedule 9 and Schedule 19 having the same Basic charge for primary and
Transmission service.
RESPONSE TO REQUEST NO. 41: The data detailing the costs
associated with the basic charge is included on Exhibit No. 42.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 42: Please provide copies of any and all data that
support Schedule 9 and Schedule 19 having the same Non-Summer Demand charge
for primary and Transmission service.
RESPONSE TO REQUEST NO. 42: The data detailing the costs
associated with the non-summer demand charge is included on Exhibit No. 42.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 43: Please provide any and all data and analyses that
support the proposal for no seasonality in the Basic and Service Charge for Schedule 9
and 19.
RESPONSE TO REQUEST NO. 43: The data detailing the costs
associated with the basic and service charges is included on Exhibit No. 42.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 44: Please provide any and all data and analyses
supporting Idaho Powers selection of the proposed time blocks for Schedule 19.
RESPONSE TO REQUEST NO. 44: The proposed time blocks for
Schedule 19 were developed by the Company s power supply department. The
proposal is based on industry accepted heavy and light load periods and on Idaho
Power s peak hour data. During the non-summer months , the mid-peak and off-peak
time blocks proposed for Schedule 19 coincide with the heavy and light load periods of
7:00 a.m. to 11 :00 p.m. and 11 :00 p.m. to 7:00 a., respectively. During the summer
months , the on-peak period coincides with Idaho Power s historical data indicating peak
hour. Historically, the summer peak has not occurred prior to 1 :00 p.m. nor later than
8:00 p.m. Because the usage during the hour ending 9:00 p.m. can remain high , the
on-peak period was established as 1 :00 p.m. to 9:00 p.m. The mid-peak period of 7:00
m. to 1 :00 p.m. and 9:00 p.m. to 11 :00 p.m. encompasses the remaining hours
designated as the heavy load period. The off-peak period encompasses the hours
designated as the light load period.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 45: Please provide any and all data and analyses
supporting Idaho Powers selection of June, July and August as Summer Months and
the remaining months of the year as Non-Summer Months.
RESPONSE TO REQUEST NO. 45: The selection of June , July, and
August as summer months and the remaining months of the year as non-summer
months was based on the identified capacity deficits in the Company s 2002 Integrated
Resource Plan.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 46: Please provide any and all data and analyses used to
calculate the energy charges for Schedule 19 for Summer and Non-Summer Months.
RESPONSE TO REQUEST NO. 46: Please refer to Exhibit No. 42 , page
5 and Exhibit No. 45 for the data and analysis used to calculate the energy charges for
Schedule 19.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 47: Please provide copies of any and all data and
analyses Idaho Power proposes to use to anticipate a customer s need that
immediately exceeds 1000 KW as referenced in Ms. Brilz' testimony.
RESPONSE TO REQUEST NO. 47: Please refer to Idaho Power
response to ICIP Request No. 38.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 48: Please provide copies of all of Idaho Power
Distribution Reliability Indices records from 1993 to 2003.
RESPONSE TO REQUEST NO. 48:
Idaho Power Company System Performance (10 Years)
YEAR SAIDI SAIFI
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
9022
2510
5403
9135
1792
7211
0318
0356
9772
9099
5054
3385
6847
1205
3411
1 .6738
0315
7448
4564
8059
2389
1 .9843
SAIDI (System Average Interruption Duration Index) = Sum of Customer Interruption
Durations / Total number of Customers Served.
SAIFI (System Interruption Frequency Index) = Total number of Customer
Interruptions / Total number of Customers Served.
The response to this request was prepared by Darrell R. Tomlinson
Finance Team Leader, Financial Research/Support , Idaho Power Company, in
consultation with Barton L: Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 49: Has Idaho Power ever developed a method for
weather normalization of peak loads? If so, please provide copies of all such studies.
RESPONSE TO REQUEST NO. 49: , Idaho Power has never
developed a method for weather normalizing peak loads by class for the purpose of a
Cost of Service study. However, weather-adjusted system peaks were estimated for
the purpose of the Marginal Cost Study published in January 1994. No studies have
been done since then.
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 FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 50: Was weather normalization of peak loads used in the
preparation of this rate case? If not , please fully explain why not.
RESPONSE TO REQUEST NO. 50: No. Idaho Power does not have a
methodology in place to weather normalize peak loads by class for the purpose of a
Cost of Service study.
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 FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 51: Does the Company anticipate any future use of
weather normalization of peak loads? If not please explain fully why not.
RESPONSE TO REQUEST NO. 51: No. At this time the Company is not
developing any methodology to weather normalize peak loads by class for the purpose
of a Cost of Service study.
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 FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 52: Please explain how peak load data was used in this
rate case filing that would impact the:
Estimates of Revenue Requirement; and
RESPONSE TO REQUEST NO. 52(1): Monthly coincident peak
demands by jurisdiction (Idaho, Oregon , FERC Sales for Resale and FERC
Transmission) are used to develop the Average of 12 Coincident Peak (Avg12CP)
allocator. This demand allocator is used to allocate demand related costs among
jurisdictions (Obenchain , DI: page 19-20). The allocation of these demand related
costs are a component of the resulting jurisdictional revenue requirement.
The response to this request was prepared by Phil A. Obenchain, Senior
Pricing Analyst , Pricing and Regulatory Services , Idaho Power Company, in
consultation with Barton L. Kline, Senior Attorney, Idaho Power Company.
Estimates of Class Cost of Service Assignments.
RESPONSE TO REQUEST NO. 51(2): The monthly coincident peak
demands for each customer class are used to develop the weighted demand-related
allocation factors D1 OS , D10NS , and D13. These three factors are used to allocate
demand-related production plant (D1 OS and D1 ONS) and transmission plant (D13) to
the various customer classes. Exhibit No. 40 details the derivation of the weighted
demand-related allocation factors.
The response to this request was prepared by Maggie Brilz , Director of
Pricing, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 53: Please provide monthly operating hours and MWh
production from the Danskin Station from its on line date to the present. (Response to
Staff 3rd set has a total of 104 721 for the period from being on-line and Oct. 2003
please provide the monthly Mwh output from the online date to Oct 2003 , and please
provide the monthly Mwh output from the online date and the latest month available.
RESPONSE TO REQUEST NO. 53: The monthly operating hours and
MWh generated at the Danskin station from September 2001 through December 2003
are enclosed.
The response to this request was prepared by Gregory W. Said , Director
of Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 54: Please indicate for the date provided in response to
No. 53 above , for each month , how much was used to serve native load and how much
was generated for off system sales. For the generation used for off system sales please
provide the price received for that power.
RESPONSE TO REQUEST NO. 54: The Company does not identify the
source of generation that is sold as surplus from the system. However, because
Danskin is the highest cost Company-owned resource and in order to make a good faith
effort to respond to this request, in the attached information the Company has assumed
that in any hour that the Company was a net purchaser, generation from Danskin was
used to serve native load; and conversely, in any hour that the Company was a net
seller, generation from Danskin was generated for off system sales. Pricing
assumptions were also made in order to respond to this request. A complete detailing
of assumptions and the resulting estimates of the information requested is enclosed. In
actual operation of the plant, there were short periods of time when the plant was
required to run for testing of equipment or training of operators, regardless of the
market price.
The response to this request was prepared by Gregory W. Said, Director
of Pricing, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 55: Reference to Exhibit 33, page 1 , line 14: Please fully
explain the charge identified as "Fixed Capacity Charge -Gas Transportation ($ x
1000)" .
RESPONSE TO REQUEST NO. 55: Idaho Power Company holds 24 523
MMBtu / day of firm capacity on Northwest Pipeline (NWP). The "Fixed Capacity
Charge" consists of the charge to reserve firm capacity ($.31 / MMBtu) and the annual
cost of facilities for the lateral line from the main NWP pipeline to Danskin ($436 000).
The response to this request was prepared under the direction of Gregory
W. Said , Director of Revenue Requirement, Idaho Power Company, in consultation with
Barton L. Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 56: Line 13 on page one of Exhibit 33 is labeled "Cost
($x 1000). Is this the cost of gas needed to generate the output listed on line 12 on the
same page? If not please fully explain the import of the quoted language.
RESPONSE TO REQUEST NO. 56: Yes. The amount shown on line 13
of Exhibit 33 includes the cost of gas needed to generate the output shown on line 12
and other variable costs used in dispatch decisions.
The response to this request was prepared under the direction of 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 FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 57: Please fully document the planning process for
construction of the Danskin Station. Include copies of all company memoranda
planning studies, minutes from meetings (at Board of Directors level and below) at
Idaho Power, IdaCorp and IdaCorp Energy Services.
RESPONSE TO REQUEST NO. 57: The construction of Danskin Station
was one of many activities undertaken by Idaho Power Company early in 2001 in
response to the combination of high-energy market prices and drought. Other efforts
included the Astaris contract, the irrigation load reduction program , portable diesel
generators, a demand exchange program , a customer information campaign , and an
early PCA filing to stimulate a demand response. A cross-functional Idaho Power group
of Idaho Power employees developed the collective efforts as a team.
The requested records describing the alternatives considered and
analyses performed is voluminous and as a result is available for inspection in the
discovery room 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.
The response to this request was prepared by John R. Gale, Vice
President, Regulatory Affairs, Idaho Power Company, in consultation with Barton L.
Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 58: Please provide copies of all communications
between Idaho Power and IdaCorp Energy Services regarding the Danskin Station.
RESPONSE TO REQUEST NO. 58: Please see response to ICIP
Request for Production No. 57. The information requested is voluminous and as a
result is available for inspection in the discovery room 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.
The response to this request was prepared by John R. Gale, Vice
President, Regulatory Affairs, Idaho Power Company, in consultation with Barton L.
Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 59: What consumer groups were contacted during the
planning phase for the Danskin Station. Please provide copies of all communications
with said consumer groups.
RESPONSE TO REQUEST NO. 59: There were extensive contacts with
the public throughout the planning and permitting process for the Danskin Station
including (1) a general public meeting to commence the permitting process
(2) customer mailings to those living near the impacted areas , (3) meetings with the
neighborhood association , (4) presentations to the business community, service clubs
and chamber representatives, and the planning and zoning board , and (4) public notice
and opportunity to comment provided in conjunction with the Company s application to
the Commission for a certificate of public convenience and necessity for the Danskin
Plant.
Presentation materials are included with the information provided in
response to Request Nos. 57 and 58.
The response to this request was prepared by John R. Gale , Vice
President , Regulatory Affairs , Idaho Power Company, in consultation with Barton L.
Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 60: Please describe and document the public
involvement engaged in by Idaho Power during the planning phase for the Danskin
Station.
RESPONSE TO REQUEST NO. 60: Public involvement during the
planning phase of the Danskin Station can be segmented into three categories:
(1) public involvement during the preparation of the 2000 IRP , which identified a
resource equivalent to a 250 MW simple-cycle combustion turbine as a part of Idaho
Power s optimal resource acquisition strategy, (2) public involvement during the siting
and permitting process, and (3) public notice and opportunity to comment during the
Commission s proceedings on the Company s application for a certificate of public
convenience and necessity for the Danskin Power Plant.
Public involvement during the planning phase involved the local citizens in
the Mountain Home area. Idaho Power personnel met with city officials , individual
citizens living near the project site , and conducted and attended several public
meetings in Mountain Home. In fact, the Danskin site was moved in response to input
and concerns identified as a result of the public involvement during the planning and
permitting phase of the project.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
The response to this request was prepared by John R. Gale , Vice
President, Regulatory Affairs, Idaho Power Company, in consultation with Barton L.
Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 61: Who made the final decision to construct the Danskin
Station?
RESPONSE TO REQUEST NO. 61: Idaho Power Company
management and its Board of Directors.
The response to this request was prepared by John R. Gale , Vice
President, Regulatory Affairs, Idaho Power Company, in consultation with Barton L.
Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
REQUEST NO. 62: Does Idaho Power expect to add any capacity to the
Danskin Station? If so, how much additional capacity and when would the additional
capacity be brought on line?
RESPONSE TO REQUEST NO. 62: While Idaho Power does not have
any current plans to add additional capacity to the Danskin Station , this site is a
potential candidate for future expansion. The expansion of the site could follow either
or both of the following scenarios. First, the existing units could be converted to
combined cycle operation and , second , an additional generating unit (either simple
cycle or combined cycle) can be added. The amount of additional capacity added
would range from about 40 MW (if the existing units were converted to combined cycle)
to about 250 MW (if a combined cycle unit utilizing a turbine similar to the Bennett
Mountain Pant were added).
The response to this request was prepared by John R. Gale, Vice
President, Regulatory Affairs , Idaho Power Company, in consultation with Barton L.
Kline , Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
DATED at Boise , Idaho, this 13th day of February, 2004.
---
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BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of February, 2004, I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER 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 [phone]
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 [phone]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Hand Delivered
S. Mail
Overnight Mail
FAX [phone]
Peter J. Richardson
Richardson & 0' Leary
99 East State Street , Suite 200
O. Box 1849
Eagle, ID 83616
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise , ID 83703
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
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 [phone]
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
CERTIFICATE OF SERVICE , Page
Hand Delivered
S. Mail
Overnight Mail
FAX
Conley E. Ward
Givens, Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise , ID 83701-2720
Dennis E. Peseau, Ph.
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, I D 83702
Michael Karp
147 Appaloosa Lane
Bellingham , W A 98229
Michael L. Kurtz, Esq.
Kurt J. Boehm , Esq.
Boehm , Kurtz & Lowry
36 East Seventh Street, Suite 2110
Cincinnati , OH 45202
CERTIFICATE OF SERVICE , Page 2
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
-2L Overnight Mail
FAX [phone]
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x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
-2L Overnight Mail
FAX [phone]
Hand Delivered
x U.S. Mail
Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
-2L Overnight Mail
FAX [phone]
Hand Delivered
S. Mail
-2L Overnight Mail
FAX [phone]
Kevin Higgins
39 Market Street , Suite 200
Salt Lake City, UT 84101
Hand Delivered
S. Mail
---L- Overnight Mail
FAX
Thomas M. Power
Economics Department, LA 407
University of Montana
32 Campus Drive
Missoula, MT 59812
Hand Delivered
- U.S. Mail
---L- Overnight Mail
FAX
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BARTON L. KLINE
CERTIFICATE OF SERVICE, Page 3