200403011st Request of ID Power to Staff.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'S FIRST
NTERROGA TORI ES AND
PRODUCTION REQUEST TO
COMMISSION STAFF
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company
by and through its attorneys and hereby requests that the Commission Staff answer the
following interrogatories and provide the following information and documents in
accordance with the Commission s Rules of Procedure and applicable scheduling orders
and notices issued by the Commission in this proceeding.
This production request is to be deemed continuing in nature and the
Commission Staff is requested to provide, through supplementation , additional documents
or information that is responsive to this request that it , or any person acting on its behalf
may later come into possession or become aware of.
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page
REQUEST NO.1: Please provide a detailed list of the rate base items
and corresponding dollar amounts removed from or added to the Company s filed value
of $1 547,443 530 for the Idaho jurisdiction used to arrive at the Staff's Idaho
jurisdictional value of $1 ,481 ,824,492 contained in Staff Exhibit No.1 01. If this data is
contained in an exhibit or work papers , please specify the location of such data by page
and line.
REQUEST NO.2: Please provide a detailed list of the expense items and
corresponding dollar amounts removed from or added to the Company s filed Idaho
jurisdictional expense amount of $505 694 281 Staff used to arrive at its Idaho
jurisdictional expense amount of $483 313 015 contained in Staff Exhibit No.1 01. If this
data is contained in an exhibit or work papers, please specify the location of such data
by page and line.
REQUEST NO.3: Please provide a detailed list of the revenue items. and
corresponding dollar amounts removed from or added to the Company s filed Idaho
jurisdictional other operating revenue amount of $32 092 783 Staff used to arrive at its
Idaho jurisdictional other operating revenue amount of $35,975,990 contained in Staff
Exhibit No.1 01. If this data is contained in an exhibit or work papers , please specify the
location of such data by page and line.
REQUEST NO.4: Please provide a detailed list of the items and
corresponding dollar amounts removed from or added to the Company s filed Idaho
jurisdictionallERCO income amount of $7 124,486 Staff used to arrive at its Idaho
jurisdictionallERCO income amount of $7 131 020 contained in Staff Exhibit No.1 01.
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 2
this data is contained in an exhibit or work papers , please specify the location of such
data by page and line.
REQUEST NO.5: Referring to the testimony of Mr. Holm , pages 25-
did Mr. Holm review any prior Commission orders in arriving at his recommendations for
the income tax adjustments that he proposes? If so , please provide a copy of the
Commission orders that Mr. Holm reviewed in arriving at his recommendations
concerning income taxes and the pages in those orders he believes are relevant.
REQUEST NO.6: Did Mr. Holm obtain any recommendations or opinions
from any individuals or entities as to the appropriateness of his income tax proposals?
If yes, please identify the source of the recommendation or opinion and provide a copy
of those recommendations or opinions. If a recommendation or opinion was not
provided in writing, please identify the source and provide a summary and/or discussion
of those recommendations or opinions.
REQUEST NO.7: Is Mr. Holm aware of any state in which an historical
average effective income tax rate is used to set rates for an electric utility? If so, please
identify the state and the electric utility and provide any orders or documents that
address the use of an average effective income tax rate.
REQUEST NO.8: Referring to Mr. Holm s testimony, please explain how
the average salary figure for State of Idaho employees he cites on page 15 was
calculated. In addition to explaining how the calculation was made, please provide a list
of the classified positions , by salary level , for all classifications included in the
calculation and copies of any documents or data Staff relied on in computing the
average salary figure.
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 3
REQUEST NO.9: On page 6 of his testimony, Mr. Holm describes Staff's
adjustment of $1.3 million to the December 2003 revenue and expense forecast
amount. Please provide data and documentation that explain the calculation of that
adjustment. If this data is contained in an exhibit or work papers, please specify the
location of such data by page and line.
REQUEST NO.1 0: Please provide Staff's total system and jurisdictional
current income tax calculations for federal , Idaho, Oregon , and other states. If
available , please provide a copy of all schedules or work papers supporting these
calculations in Excel with the formulas intact. If this data is contained in an exhibit or
work papers, please specify the location of such data by page and line.
REQUEST NO. 11: Please provide Staff's total system and jurisdictional
deferred income tax calculations for federal, Idaho, Oregon , and other states. If
available, please provide a copy of all schedules or work papers supporting these
calculations in Excel with the formulas intact. If this data is contained in an exhibit or
work papers , please specify the location of such data by page and line.
REQUEST NO. 12: Please provide Staff's total system and jurisdictional
investment tax credit calculations for federal , Idaho, Oregon, and other states. If
available , please provide a copy of all schedules or work papers supporting these
calculations in Excel with the formulas intact. If this data is contained in an exhibit or
work papers, please specify the location of such data by page and line.
REQUEST NO. 13: Please provide Staff's total system and jurisdictional
interest synchronization calculation. If available , please provide a copy of all schedules
or work papers supporting these calculations in Excel with the formulas intact. If this
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 4
data is contained in an exhibit or work papers, please specify the location of such data
by page and line.
REQUEST NO. 14: Referring to Mr. Holm s testimony, please explain
how the turnover figures for the State of Idaho he cites on page 15 were calculated.
Please separate by types of terminations (voluntary, involuntary, retirement , disability,
and the like) and identify the types of employees (full-time, part-time , seasonal) used to
make the calculation and provide copies of any documents Staff relied upon in
computing the turn-over figures.
REQUEST NO. 15: Regarding the three salary surveys referred to by Mr.
Holm on page 15 , line 12 , please provide the documentation for the surveys, including
the methodology behind the survey data, the source of the data, the industries
represented in the data, companies participating, the size of companies represented in
the data (by measures such as revenue , total employees and the like), how the data
was gathered and analyzed , and the methods employed by the survey provider to
ensure the data was valid and reliable.
REQUEST NO. 16: On page 15 of his testimony, Mr. Holm testifies that
Idaho Power s "base salary and benefits are already generous when compared to local
salaries and wages." Please provide the data including employer, position title, position
descriptor and salary level for all positions that were compared to Idaho Power positions
and salaries in support of Mr. Holm s testimony.
REQUEST NO. 17: Please provide any salary information Staff reviewed
or considered that focused on electric utility data or compared salaries and benefits paid
in the electric utility industry.
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 5
REQUEST NO. 18: Please provide the data and any analysis Staff used
to support its comparisons of benefits costs and allocation of these costs between
employee and employer in the Boise market referred to in Mr. Holm s testimony on p 16.
REQUEST NO. 19: Please explain how Staff calculated the average
salary for a full-time worker in Boise referred to in Mr. Holm s testimony on page 17. In
addition to the calculation , please provide a list of the positions , salary levels , and types
of companies and industries included in the calculation and copies of any documents
relied on in performing the calculation.
REQUEST NO. 20: On page 17 of his testimony, Mr. Holm refers to the
average salaries for all U.S. workers. Please provide the specific survey sources and
the methodology Staff used to calculate the average salary for all U.S. workers. Please
list the job classifications that are included in this salary figure and what industries and
employer revenue amounts were considered for comparison purposes.
REQUEST NO. 21: On page 23 of his testimony, Mr. Holm describes the
adjustments Staff made to remove capitalized incentive compensation costs from rate
base. Please explain the methodology and provide the calculations used to make the
adjustments of $7 741 ,747 to rate base and $230,594 to annual depreciation expense
relating to incentive compensation.
REQUEST NO. 22: Please provide an itemized list of the charges that
make up the $352 544 amount Staff removed from the Company s legal expenses.
(English testimony on pages 30-31.If this data is contained in an exhibit or work
papers , please specify the location of such data by page and line.
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 6
REQUEST NO. 23: Please provide a detailed list of all pension expense
amounts removed from the Company s filed Idaho jurisdictional income amount.
REQUEST NO. 24: On page 10 of his testimony, Mr. English testifies that
Idaho Power s revenue requirement under the Service Cost method will be greater than
it would be under the Net Periodic Pension Cost method. Please provide the
computations, assumptions , spread sheets, models or other documentation that support
that conclusion. If this data is contained in an exhibit or workpapers , please specify the
location of such data by page and line.
REQUEST NO. 25: On page 11 of his testimony, Mr. English states that
actuarial assumptions rarely change barring some major event. Please provide any
data, analysis or other documentation that Staff believes supports that testimony.
Please provide this data for the past three years.
REQUEST NO. 26: On page 13 of his testimony, Mr. English refers to
Exhibit No.1 08 and the historical rates of return of Idaho Power s retirement plan over
the last fifteen years. Please describe how Staff selected a fifteen-year investment
horizon for the return analysis referred to in Mr. English's testimony.
REQUEST NO. 27: On page 19 of his testimony, Mr. English states it is
unlikely that Idaho Power will contribute to its pension plan for several years. Please
provide copies of all analyses and documentation , including assumptions, spread
sheets or models , used to support Staff's projection.
REQUEST NO. 28: On page 14 of his testimony, Mr. English addresses
Staff's recommendation to reduce pension expense by $1 379,149. Please provide all
documentation , including spread sheets, assumptions or models, used to calculate the
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 7
379 149 reduction of pension expense due to change in projected long-term rate of
return on assets.
REQUEST NO. 29: Ms. Carlock testifies on page 11 that "Due to changes
in the markets and the dividend cut for IDACORP , I believe the projected price range of
$25 to $35 with a growth rate of 4% is the most representative." Please provide all of
the analysis and documentation relied upon by Ms. Carlock to support her projected
stock price range of $25 to $35. If this information is contained in an exhibit or work
papers , please specify the location of the data by page and line.
REQUEST NO. 30: In her testimony on pages 11 and 12 , Ms. Carlock
testifies in support of her projected growth rate of 3% to 5%. She states "This expected
growth rate was derived from an analysis of various historical and projected growth
indicators, including growth in earnings per share , growth in cash dividends per share
growth in book value per share and the sustainable growth for Idaho Power and
IDACORP." Please provide all data, analyses and documentation relating to the various
historical and projected growth indicators, including growth in earnings per share
growth in cash dividends per share , growth in book value per share, and the sustainable
growth for Idaho Power and IDACORP Ms. Carlock used to support her growth rate
conclusions in her testimony. If this information is contained in an exhibit or work paper
please specify the location of the information by page and line.
REQUEST NO. 31: On page 14 of her testimony, Witness Carlock states
that her recommended 10% return on equity point estimate is based on a review of the
market data and comparables, average risk characteristics for Idaho Power and the
updated capital structure." Please provide all of the data, documentation , and source
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 8
documents that Ms. Carlock relies upon to support her 10% return on equity
recommendation in this case. If this information is contained in an exhibit or work
papers, please specify the location of the information by page and line.
REQUEST NO. 32: Please provide a copy of the source documents for
the 4.18% dividend yield cited on page 11 of Ms. Carlock's testimony.
REQUEST NO. 33: Please provide a copy of the analysis of historical and
projected growth indicators , including all source documents referenced in Ms. Carlock'
testimony on pages 12 and 13.
REQUEST NO. 34: Please clarify what is meant by "summer" as it relates
to Staff's proposed rate design that would include a higher charge for kWh consumed
above 800 kWh per month as detailed on page 18, lines 21 through 23 of the direct
testimony of Mr. Schunke. If "summer" is a period other than June 1 through
August 31 , please provide the rationale for the selected dates.
REQUEST NO. 35: Please provide any and all data used to support the
statement that "Much of the base load energy used for refrigeration , lighting, water
heating and small appliances occurs off-peak" as found on page 19, lines 12 through 14
of the direct testimony of Staff witness Schunke.
REQUEST NO. 36: Please provide the rationale used by Staff in
proposing a summer and non-summer demand charge for Schedule 9 Secondary
service that is lower than the corresponding demand charges for Schedule 9 Primary
and Transmission service.
REQUEST NO. 37: Please clarify whether or not Staff supports
mandatory time-of-use rates for all Schedule 19 customers.
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 9
REQUEST NO. 38: Please provide the rationale used by Staff in
proposing an increase in the Service Charge to $100 per month for Schedule 9 Primary
and Transmission customers while proposing the Service Charge remain at $85.71 per
month for Schedule 19 Primary and Transmission customers.
REQUEST NO. 39: On page 33 of his testimony, Mr. English describes
an additional adjustment of $29,418.50 decreasing the test year interest expense.
Please provide a description of how that amount was calculated and provide any
analysis and documentation which supports Mr. English's testimony on that point. If this
data is contained in an exhibit or work papers, please specify the location of such data
by page and line.
REQUEST NO. 40: On page 35 of Mr. English's testimony, he identifies
an adjustment reducing long-term interest expense by $3,083 000. His testimony refers
to Ms. Carlock's testimony to discuss this adjustment. Please provide a work paper
showing how this interest rate adjustment was calculated and include any analysis and
documentation that supports the calculation. If this data is contained in an exhibit or
work papers , please specify the location of such data by page and line.
REQUEST NO. 41: Please provide a detailed calculation of the
depreciation adjustment proposed by the Staff, Exhibit No.1 02 and stipulated to in
Case No. IPC-03-13. Please show the calculation by FERC Account and the
depreciation rate used to derive Staff's recommended result. If this data is contained in
an exhibit or workpapers, please specify the location of such data by page and line.
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 1 0
DATED at Boise , Idaho, this 27th day of February, 2004.
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BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S FIRST INTERROGATORIES AND
PRODUCTION REQUEST TO COMMISSION STAFF Page 11
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 27th day of February, 2004, I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'S FIRST
INTERROGATORIES AND PRODUCTION REQUEST TO COMMISSION STAFF 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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S. Mail
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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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CERTIFICATE OF SERVICE , Page
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
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Dennis E. Peseau , Ph.D.
Utility Resources, Inc.
1500 Liberty Street S., Suite 250
Salem, OR 97302
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Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, ID 83701
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Jeremiah Healy
United Water Idaho, Inc.
O. Box 190420
Boise , ID 83719-0420
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William M. Eddie
Advocates for the West
O. Box 1612
Boise , ID 83701
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Nancy Hirsh
NW Energy Coalition
219 First Ave. South , Suite 100
Seattle , W A 98104
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Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise , ID 83702
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CERTIFICATE OF SERVICE, Page 2
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
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
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