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Home My WebLink About20051227Micron 1st requests to IPC.pdf::~I\' Conley E. Ward (ISB No. 1683) GIVENS PURSLEY LLP 601 W. Bannock Street P. O. Box 2720 Boise, ID 83701-2720 Telephone No. (208) 388-1200 Fax No. (208) 388-1300 cew~givenspursley.com r:'; l,; i " , :: ,LiC ... '; : , " ', ( "' ' " I " ('J';,i~~~)i..,uiL:I:::;JION Attorneys for Micron Technology, Inc. S:\CLIENTS\4489\24\Micron First Disc Req to !PC.DOC 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 THE STATE OF IDAHO Case No. IPC-05- MICRON TECHNOLOGY INc.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY YOU WILL PLEASE TAKE NOTICE that Micron Technology, Inc. ("Micron requests that Idaho Power Company ("Idaho Power ) answer, the following discovery requests in accordance with the Idaho Public Utilities Commission s Rules of Procedure. Definitions and Instructions The interrogatories and document requests are governed by the following definitions and instructions: Definitions You " " your" or "Idaho Power" means or pertains to the named respondent in this matter and includes, without limitation, Idaho Power, its officers, directors employees, agents, attorneys, corporate subsidiaries and affiliates MICRON TECHNOLOGY, INC'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - Persons" means any and all natural persons, corporations, businesses, firms companies, partnerships, unincorporated associations, governmental or public agencies, joint ventures and all other entities, including, without limitation, all employees, representatives, consultants and agents of any of the foregoing. Documents" means any and all written, electronic or graphic matter, of any kind or description, however created, produced, reproduced or stored, whether sent or received, or whether originals, copies or drafts, including, but not limited to every side of every page of all letters, papers, books, correspondence, bulletins circulars, instructions, telegrams, cables, telex messages, facsimiles, memoranda notes, notations, work papers, transcripts, minutes, reports, recordings of notes or meetings, conferences, interviews or telephone or other conversations, affidavits statements, summaries, opinions, studies, analyses, evaluations, work sheets contracts, agreements, journals, statistical records, desk or pocket calendars appointment books, diaries, lists, tabulations, advertisements, sketches, drawings blue prints, catalogs, audio or video records, photographs, computer printouts, e- mail transmissions, data processing input and output, deeds, microfilm, all other records kept by electronic, photographic or electrical means, and things similar to any of the foregoing however denominated. Relating to" or "Relate(s) to" means directly or indirectly mentioning, consisting , evidencing, describing, referring to, pertaining to, being connected with, or reflecting upon the stated subject matter. The words "any" and "all" shall be considered to include each and every. MICRON TECHNOLOGY, INC'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 2 The singular of any word shall include the plural and the plural of any word shall include the singular. The word "expert" as used herein includes any person who will be offering expert testimony on behalf of Idaho Power or who has been consulted or relied upon by any person who assisted in the preparation of the responses to these interrogatories and document production requests or who will be offering testimony on behalf ofIdaho Power in this matter. Instructions In answering these interrogatories and document requests, you are required to furnish all information that is available to you, or subject to your reasonable inquiry, including the information in the possession of you, your attorneys or other persons directly, or indirectly employed by, or connected with, you or your attorneys, and anyone else other wise subject to your control. In answering each interrogatory and document request: Identify by title, heading or caption, date, sender, recipient, location and custodian, each document relied upon, reviewed or which forms a basis for the response given or which corroborates or relates to the response given or the subject of what is given in response to these discovery requests; State whether the information furnished is within the personal knowledge of the person responding and, if not, the name, if known, of each person to whom the information is a matter of personal knowledge; Identify each person who assisted or participated in preparing and/or supplying any ofthe information given in response to or relied upon in preparing responses to these discovery requests; MICRON TECHNOLOGY, INC'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 3 Where a discovery request calls for a response in multiple parts, each part should be separated in the response so that the response is clearly understandable and complete; Where the name or identity of a person is requested, state the full name, business address, and any telephone numbers of each person; If any of your responses require the production of documents, label the documents to indicate the discovery request to which you are responding. If you object to the production of any document called for in these document requests, for each such document state the following: (1) the reasons for the objection and any facts supporting the objection; (2) give a description of each document including, without limitation, the date, sender, recipient(s), persons to whom copies have been furnished, job titles of each of the persons, subject matter of the document, number of pages of the document, the number(s) of the request to which such document is responsive and the identity of the person in whose custody the document is presently located. If any document is withheld under claim of privilege or work product, furnish a list identifying each document for which the privilege or work product is claimed, together with the following information for each such document: date, sender, recipient(s), persons to whom copies were furnished, job titles of each of those persons, subject matter of the document number of pages of the document, the bases on which the privileges or work product is claimed the paragraph(s) of these requests to which the document responds, the person in whose custody the document is presently located, and whether any matter that is not privileged or is not work product is discussed or mentioned in each document. If any document requested was, but is no longer in the possession or subject to the control ofIdaho Power, or is no longer in existence, state whether it: (1) is missing or lost; (2) MICRON TECHNOLOGY, INC'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 4 has been destroyed; (3) has been transferred voluntarily or involuntarily to others and state the identity of the persons to whom it has been transferred; (4) has otherwise been disposed of, or in each instance explain the circumstances surrounding such disposition, state the date or approximate date thereof and the identity of the persons with knowledge of such circumstances; (5) identify the documents that are missing, lost, destroyed, transferred or otherwise disposed of by author, date, subject matter, addressee(s), and the number of pages. If you do not clearly understand, or have any questions about, these definitions instructions interrogatories or requests, contact counsel for Micron promptly for clarification. These discovery requests are continuing in nature and require supplemental responses upon the discovery or receipt of new or additional information. DISCOVERY REQUESTS 1. Please provide all the workpapers, data and spreadsheets in Excel format for each of the Cost of Service Studies (Traditional COS, Normalized COS , and Non-Weighted COS) prepared for this case. 2. Please provide complete copies of Idaho Power Company s 200, 2002, and 2004 IRPs. 3. Please provide, in Excel format, all the workpapers, data and spreadsheets used to normalize the loads used to develop allocators for the "Normalized COS. 4. Please provide in numerical format the monthly energy and peak hour surplus/deficiency data by year used to generate Figures 6 and 7 for the 2004 IRP and reproduced in Ms. Brilz s workpapers in Page 67. 5. Please provide similar monthly energy and peak hour surplus/deficiency data to that requested in Request No.4 for the 2000 and 2002 IRPs. 6. Please provide all workpapers, data and spreadsheets used to develop normalized revenues, kwh sales, and customers by month for the 2005 test period as used in the COS studies. 7. Please provide all workpapers, data, spreadsheets and other model output, including Aurora or other model output, used to develop the monthly peak hour surplus/deficiencies included in the 2004 IRP in Figures 6 and 7. MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 5 8. Please provide actual and normalized customer counts by month for the 2005 test period. 9. Please provide all workpapers, data and spreadsheets, in Excel format, used to develop the monthly growth based weights to seasonalized transmission demands and allocators discussed at page 22, line 24, through page 23 , line 4 of Ms. Brilz s testimony, as used in the COS studies. 10. Please provide all data, workpapers and spreadsheets, in Excel format, and the output of other models, including the Aurora model, used to develop monthly marginal costs in the 2005 Marginal Cost Study included in Ms. Brilz s workpapers, and used to develop weighted allocators in the COS studies. 11. Please provide all LOLP or other capacity risk or load loss studies performed by or for Idaho Power Company during the last three years. 12. Please provide all requests for proposals for firm energy purchases, including all terms and conditions, issued by Idaho Power Company during the last three years. 13. Please provide monthly generation amounts for all Idaho Power Company owned resources by resource and month for the last three years. 14. Please provide monthly firm purchased energy amounts for all energy purchased by supplier and month for the last three years. 15. Please provide a copy of any draft Integrated Resource Plan for Idaho Power Company. 16. Please provide copies of all materials previously submitted to the Commission Staff or other parties in connection with this rate case. You need not include discovery responses or other material already served on Micron s representatives. DATED this ~ 1Wday of December 2005. ~C. Conley E. Ward GIVENS PURSLEY LLP Attorneys for Micron Technology, Inc. MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this -rt.7tkc1ay of December 2005, I caused to be served a true and correct copy of the foregoing by the method indicated below, and addressed to the following: Donald L. Howell, II Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Street P. O. Box 83720 Boise, ID 83720-0074 S. Mail Hand Delivered Overnight Mail Facsimile Mail u.S. Mail Hand Delivered Overnight Mail Facsimile Mail S. Mail Hand Delivered Overnight Mail Facsimile Mail S. Mail Hand Delivered Overnight Mail Facsimile Mail Jean Jewell Idaho Public Utilities Commission 472 W. Washington Street P. O. Box 83720 Boise, ID 83720-0074 Barton L. Kline Monica B. Moen Idaho Power Company P. O. Box 70 Boise, ID 83707 John R. Gale Vice President Regulatory Affairs Idaho Power Company P. O. Box 70 Boise, ID 83707 Peter J. Richardson Richardson & O'Leary 515 N. 2ih Street Boise, ID 83702 S. Mail Hand Delivered Overnight Mail Facsimile Mail Don Reading Ben Johnson Associates 6070 Hill Road Boise, ID 83703 S. Mail Hand Delivered Overnight Mail Facsimile Mail MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 7 Randall C. Budge S. Mail Eric L. Olsen Hand Delivered Racine, Olson, Nye, Budge, Bailey Overnight Mail 201 E. Center Facsimile P. O. Box 1391 Mail Pocatello, ID 83204-1391 Anthony Yankel u.S. Mail 29814 Lake Road Hand Delivered Bay Village, OH 44140 Overnight Mail Facsimile Mail Lawrence A. Gollomp S. Mail Assistant General Counsel Hand Delivered S. Department of Energy Overnight Mail 1000 Independence Ave. SW Facsimile Washington, DC 20585 Mail Dale Swan S. Mail Exeter Associates, Inc.Hand Delivered 5565 SterretPlace, Suite 310 Overnight Mail Columbia, MD 21044 Facsimile Mail William M. Eddie S. Mail Advocates for the West Hand Delivered P. O. Box 1612 Overnight Mail Boise, ID 83701 Facsimile Mail Ken Miller S. Mail NW Energy Coalition Hand Delivered 5400 W. Franklin, Suite G Overnight Mail Boise, ID 83705 Facsimile Mail Michael L. Kurtz, Esq.S. Mail Kurt J. Boehm, Esq.Hand Delivered Boehm, Kurtz & Lowry Overnight Mail 36 E. Seventh Street, Suite 1510 Facsimile Cincinnati, OH 45202 Mail MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8 Dennis E. Peseau, Ph. Utility Resources, Inc. 1500 Liberty Street SE, Ste. 250 Salem, OR 97302 S. Mail Hand Delivered Overnight Mail Facsimile Mail c. (tt7\- Conley E. Ward MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY-