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Department of Energy
Washington , DC 20585
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January 26, 2006
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VIA FEDERAL EXPRESS
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
372 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-f-28
S. DOE First Set of
Data Requests to Idaho Power Company
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of the First Set
of Data Requests of the United States Department of Energy to Idaho Power Company in
the above-captioned proceeding.
I would appreciate it you would return a stamped copy of this transmittal
letter to me in the enclosed self-addressed envelope. Thank you for your assistance.
Jt::=Lawrence A
Assistant General Counsel
United States Department of Energy
Enclosures
. ( t. 'Department of Energy
Washington, DC 20585
VIA FEDERAL EXPRESS
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January 26 2006
Barton L. Kline, Esq.
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
Re: Docket No.IPC-05-
Dear Mr. Kline:
Enclosed please find the First Set of Data Requests of the United States Department of
Energy to Idaho Power Company. Please provide an original copy of your responses to:
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, Virginia 22310-1149
DGoinsPMG~aol.com
Tel: 703-313-6805
Any questions regarding these Data Requests should be directed to Mr. Goins. Thank
you.
twrence A. Gollomp
Assistant General Counsel
United States Department of Energy
Cc: To all parties by u.S. mail and electronic mail.
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LA WRENCE A. GOLLOMP
ASSISTANT GENERAL COUNSEL
UNITED STATES DEPARTMENT OF ENERGY
1000 INDEPENDENCE AVENUE, SW
WASHINGTON, DC 20585
PHONE: (202) 586-4219
FAX: 202.586.7479
LA WRENCE.GOLLOMP~HQ.DOE.GOV
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STREET ADDRESS FOR EXPRESS MAIL:
1000 INDEPENDENCE AVENUE, SW
WASHINGTON, DC 20585
Attorney for US DOE
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-O5-
FIRST PRODUCTION
REQUEST OF US DOE TO
IDAHO POWER COMPANY
The United States Department of Energy, by and through its attorney of record, Lawrence
A. Gollomp, Assistant General Counsel, requests that Idaho Power Company provide the
following documents and information as soon as possible.
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.
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.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
JANUARY 25 , 2006
DOE-
DOE-
DOE-
DOE-
DOE-
Please provide copies of all integrated resource plans prepared and filed by Idaho
Power since 2000.
Referring to the direct testimony of Maggie Brilz at 21 :9-21:
(a) Please explain the difference between months determined by firm generation
supply acquisition needs (2003 marginal cost analysis) and peak-hour
deficiency months (2004 IRP). That is, would not Idaho Power have a firm
generation acquisition need in a month in which it also had a peak-hour
deficiency?
(b) Please identify the peak-hour deficiency months identified in each IRP
prepared by Idaho Power since 2000.
(c) Please identify by month and amount the firm generation purchases that
Idaho Power has made since 2000.
(d) Please identify by month and amount the firm generation purchases that
Idaho Power expects to make from 2006-2010.
Referring to the direct testimony of Maggie Brilz at 21 :21-22: 11:
(a) Please provide the monthly maximum demand and kWh purchases for each
customer class and special contract customer from 2003-2005.
(b) Please identify the actual and projected system and Idaho retail jurisdictional
monthly peaks for 2001-2010.
(c) Please identify the actual and projected system and Idaho retail jurisdictional
monthly MWh sales for 2001-2010.
Referring to the direct testimony of Maggie Brilz at Exhibit No. 49:4, please
identify the rate of return for each rate schedule and special contract customer
shown under the final revenue allocation. Please provide all workpapers
supporting and/or underlying the estimated rates of return.
Referring to the direct testimony of Peter Pengilly at 32:22-, please provide any
analyses of billing impacts by customer load factor that Idaho Power conducted.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
JANUARY 25 , 2006
DATED at Washington, DC, this -.a k:. day of January 2006.
Lawrence . Gollomp
Assistant General Counsel
United States Department of Energy
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
JANUARY 25 , 2006
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of January, 2006, I caused to be served a true and
correct copy of the foregoing via overnight mail or U.S. mail, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ill 83720-0074
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise ill 83707
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, ill 83707
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ill 83720-0074 ,
Peter J. Richardson
Richardson and 0 'Leary
515 N. 27th Street
Boise, ill 83702
u.s. DOE's FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ill 83703
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ill 83701-2720
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge, Bailey
201 E. Center
O. Box 1391
Pocatello, ill 83204-1391
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
William M. Eddie
Advocates for the West
O. Box 1612
Boise, ill 83701
Ken Miller
NW Energy Coalition
5400 W. Franklin, Suite G
Boise, ill 83705
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
Boehm, Kurtz and Lowry
36 E Seventh Street, Suite 1510
Cincinnati, OH 45202
S. DOE's FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY
Dennis E. Pesau, Ph.
Utility Resources, Inc.
1500 Liberty Street SE, Suite 250
Salem, OR 97302
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awrence A. Go ump
S. DOE's FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY