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Home My WebLink About20051129ICIP 1st request to Idaho Power.pdfCE!\/ED , :=. '\ JUJ(cJliII~JSJt!ilNl &x (I);iJ1~VATTORNEYS AT LAW ;:::9 7: 58Peter Richardson ;. LlC Tel: 208-938-7901 Fax: 208-938-7904 n\U!T:::~ Co;i;lISS!mJ pe rer(!!' r ic h a rdsonan dolea ry. com O. Box 7218 Boise, lD 83707 - 515 N. 27rh Sf. Boise, ID 83702 November 28, 2005 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 RE: Case No.lPC-E-O5- Dear Ms. Jewell: Enclosed please find three (3) copies of the FIRST PRODUCTION RE- QUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY in the above case. The original has been served on Idaho Power Company. I have also enclosed an extra copy to be service-dated and retumed to us for our files. Thank you. Sincerely, ~. CGJ\ tt Nina Curtis Administrative Assistant encl. I ,- r , : " L- - ' L:J Peter J. Richardson RICHARDSON & O'LEARY PLLC 515 n. 2ih Street Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~ri chardsonando I eary. com " ,', ' , c" ' -- - ':' a '1 . C ~I .,; . " J.. j~3L I:I,,SUI' ,; .:, " l Attorneys for the Industrial Customers of Idaho Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MA ITER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS BASE RATES AND CHARGES FOR ELECTRIC SERVICE TO ELECTRIC CUSTOMERS IN THE STATEOF IDAHO CASE NO. IPC-05- FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY Pursuant to Rule 225 ofthe Rules of Procedure of the Idaho Public Utilities Commission (the "Commission ), the Industrial Customers ofIdaho Power (ICIP) , by and through their attorney ofrecord, Peter J. Richardson, hereby request that Idaho Power Company ("Idaho Power ) provide the following documents. This production request is to be considered as continuing, and Idaho Power is requested to provide by way of supplementary responses additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. Please provide one copy of your answer to Mr. Richardson at the address noted above and one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness at hearing who can sponsor the answer. 1 - FIRST PRODUCTION OF THE lCIP TO IDAHO POWER ._-, REQUEST FOR PRODUCTION NO. Please provide any and all IPC data and analyses regarding the impact of time of use rates has had on its Schedule 19 customers since they were implemented. If no such analysis has been conducted by the Company please explain why not. REQUEST FOR PRODUCTION NO. On page 20 of Maggie Brilz Direct Testimony she states the Company s marginal cost study has been update since Case No. IPC-03-13. A copy of that update has been provided in Ms. Brilz s workpapers. Please provide a copy of the Company s marginal cost study used in Case No. IPC-03-13. REQUEST FOR PRODUCTION NO. On page 21 of Maggie Brilz Direct Testimony she states Since the conclusion of the Company s last general rate case it has been determined that the deficit months of June, July, August, November, and December used in the 2003 marginal cost analysis were primarily determined by firm generation supply acquisition needs rather than a determination of months in which a peak-hour deficiency occurred. The deficit months of January, May, June, July, August, September, November, and December used in the current marginal cost analysis are directly tied to peak-hour deficiency months identified in the 2004 IRP. Please explain in greater detail the change in the philosophy for defining deficit months. Please explain why the Company feels this change is necessary. Please explain why the deficit months would not be the same months as when the Company would be need to purchase firm generation supply. REQUEST FOR PRODUCTION NO. Schedule 1 ofIdaho Power s marginal cost study filed with Maggie Brilz s workpapers are values for the Marginal Generation Cost at Generation. These values were developed ITom the Aurora Power Supply Model 2005 to 2009. Please provide: 2 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER - - --'-W' a. Copies of the model output that were used to find these values b. All model input assumptions used to find these values c. All formula and algorithms used to find these values d. Is the same model run used to find these values the same model run used to find normalized power supply values found in Exhibit 20? REQUEST FOR PRODUCTION NO. On page 4 of Greg Said's Direct Testimony he states Under my supervision and at my request, a power supply simulation that is representative of the test year 2005 power supply expenses associated with 78 separate water conditions was prepared. These are the same values found in Exhibit 20. Please provide: a. Copies of the model output that were used to find these values b. All model input assumptions used to find these values c. All formula and algorithms used to find these values d. Is the model run used to find these values the same model run used to find Marginal Generation Cost at Generation used in the marginal cost study provided in Maggie Brilz workpapers? REQUEST FOR PRODUCTION NO. Please provide copies of all of Dr. Avera s prefiled testimony before any public utility commission in the United States on the issue of cost of capital in the last five years. REQUEST FOR PRODUCTION NO. Please provide a copy of the research report referenced by Mr. Gribble at page 8 of his prefiled testimony. REQUEST FOR PRODUCTION NO. Please provide a copy of the research report referenced by Mr. Gribble at page 9 of his prefiled testimony. REQUEST FOR PRODUCTION NO. 3 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER --~, Please provide a copy of the summary opinion update referenced on page 13 of Mr. Gribble s prefiled testimony. REQUEST FOR PRODUCTION NO. 10: Please provide a copy of the research report referenced by Mr. Gribble on page 14 of his testimony. REQUEST FOR PRODUCTION NO. 11: Please provide a copy of the publication referenced by Mr. Gribble on page 19 of his prefiled testimony. REQUEST FOR PRODUCTION NO. 12: Please provide the documentation supporting Mr. Gribble s assertion at page 16 of his prefiled testimony to the effect that "The mere dollar for dollar recovery of QF expenditures, but no return for the use of the Company s balance sheet and liquidity in managing QF programs, is viewed as a significant risk by the rating agencies. REQUEST FOR PRODUCTION NO. 13: Please provide the construction budgets referenced at page 15 of Mr. Gribble s prefiled testimony. DATED this 28th day of November 2005. RICHARDSON & O'LEARY PLLC rJAUpBy: Peter J. Richardson, ISB #3195 Attorneys for the Industrial Customers of Idaho Power 4 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER --~, CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 28th day of November 2005, a true and correct copy ofthe within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY was served by U.S. Mail, postage prepaid, to: Barton Kline Monica Moen Idaho Power Company PO Box 70 Boise, Idaho 80707-0070 John R. Gale Vice President Regulatory Affairs Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 ~CuA~ Nina Curtis Administrative Assistant --~.