200512092nd staff request to IPC.pdf

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CECELIA A. GASSNER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6977
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS BASE RATES AND
CHARGES FOR ELECTRIC SERVICE IN THESTATE OF IDAHO.
CASE NO. IPC-05-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Cece1ia A. Gassner, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
FRIDAY, DECEMBER 23 2005.
This Production Request is to be considered as continuing, and Idaho Power Company 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 or information
produced.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY DECEMBER 9, 2005
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 who can sponsor the answer at hearing.
REQUEST NO. 18: Please provide an explanation of the gas prices for Henry Hub and
Danskin as used in the AURORA analysis for computing net power supply costs. Please cite the
source of the gas prices and the date on which the prices were published or developed.
addition, please identify the exact prices extracted from the source, and describe any
computations or manipulations done to the source prices to derive the prices entered into the
AURORA model for each of the five scenarios. Please provide a copy of any spreadsheets used
to derive the gas prices used in AURORA.
REQUEST NO. 19: Please discuss any differences between the Idaho Department of
Water Resources Snake River Basin Depleted Flow Model used to derive the normalized annual
generation of Idaho Power s hydropower plants in this rate case as compared to the study used
for the Company s previous rate case. Please identify the period of record used for the current
rate case analysis and quantify any amounts by which assumed hydro generation (capacity and
energy) is less than was assumed under previous studies.
REQUEST NO. 20: Please provide a copy of any spreadsheets and data used to derive
the normalized test year loads used in the AURORA analysis for Idaho Power ssrvice territory,
including monthly and hourly shaping factors.
REQUEST NO. 21: Please provide PDR 580 computer model output that show
generation at each of the Company s Hydro Power generating facilities under the streamflow
conditions used in this case. Also provide any spreadsheet calculations made using PDR 580
output that become input to the AURORA power supply model. Provide all of the same
information from the Company s last general rate case.
REQUEST NO. 22: Company witness Greg Said's Exhibit No. 23 lists distribution and
transmission upgrades to be completed by June 1 2006. If any of the transmission upgrades
have increased Idaho Power s energy transfer capability to or from other systems (AURORA
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY DECEMBER 9 , 2005
bubbles), please specify what that change in transfer capability is and identify where it can be
found in the AURORA input files.
REQUEST NO. 23: Variable Operation and Maintenance costs in $/MWh are included
in the AURORA model run for each ofldaho Power s gas and coal fired generation resources.
Please provide the following information:
a) The calculation of the Variable 0 & M factor for each individual plant
showing the components that make up the factor and the account from which
each component is taken.
b) Reports detailing the amounts in accounts 501 and 547 as included in this
case. Show the amounts by subaccount and provide a description of each
subaccount. Show any amounts that are used in the formulation of the
variable 0 & M factors.
Explain why variable 0 & M factors from accounts other than 501 and 547
included in the calculation of power supply costs are not recovered twice
when included by the Company in actual test year 0 & M expense accounts.
REQUEST NO. 24: The AURORA model includes availability factors for all of Idaho
Power s generating facilities. Please explain how these availability factors are determined. Also
provide any spreadsheets used in their calculation. If the calculation methodology has changed
in any way since the Company s last general rate case filing, please describe the changes and
provide availability factors for this case using the old methodology. Also provide the
calculations.
REQUEST NO. 25: The last column on page 118 (2005 Rate Case Estimate Schedule
M' s) of Celeste Schwendiman s workpapers as filed in this Case totals approximately $20
million. Staff understands that a more current version of this workpaper totals approximately
$33 million and matches line 701 on page 20 of the Company s Exhibit No. 33. Please review
the workpapers and exhibits filed in this case and provide the most current versions that correlate
to the revenue requirement components outlined in this case.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY DECEMBER 9, 2005
DATED at Boise, Idaho, this ~ day of December 2005.
Cecelia
Deputy Attorney General
Technical Staff: Keith Hessing
Patricia Harms
Rick Sterling
i:umisc:prodreq/ipceO5.28cckhphrps pr 2
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY DECEMBER 9, 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF DECEMBER 2005
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-05-, BY MAILING
A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
MONICA B MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAIL: bkline(?p,idahopower.com
mmoen(?p,idahopower .com
JOHN R GALE
VICE PRESIDENT REGULATORY
AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAIL: rgale(?p,idahopower.com
PETER J. RICHARDSON
RICHARDSON & O'LEARY LLP
515 N 27TH ST
PO BOX 7218
BOISE ID 83702
MAIL: peter~richardsonandoleary.com
DR. DON READING
6070 HILL ROAD
BOISE ID 83703
MAIL: dreading~mindspring.com
CERTIFICATE OF SERVICE