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Home My WebLink About20060720ICIP to IPC 1-10.pdfPeter Richardson RECEIVED 2006 JUL 20 AM 8: '2 IDAHO PUBLIC UTILITIES COMMISSION BIi'(f;~:QJNr &: (i)JATTORNEYS AT LAW Tel: 208-938-7901 Fax: 208-938-7904 peter&' richardsonandoleary. co O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702 July 18, 2006 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise 10 83720-0074 RE: Case No.lPC-O6- Dear Ms. Jewell: Enclosed please find three (3) copies of the FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY in the above case. The original has been for- warded to Idaho Power Company. I have also enclosed an extra copy to be service-dated and retumed to us for our files. Thank you. Sincerely,~WAfu Nina Curtis Administrative Assistant encl. Peter 1. Richardson RICHARDSON & O'LEARY PLLC 515 N. 27tl1 Street Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~richardsonandoleary. com Attorneys for the Industrial Customers of Idaho Power RECEIVED 2006 JUL 20 AM 8: 12 IDAHO PUBliC UTILITIES COMMISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF IDAHO POWER COMPANY FOR MODIFICATION OF THE LOAD GROWTH ADmSTMENT RATE WITHIN THE POWER COST ADmSTMENT METHODOLOGY CASE NO. IPC-O6- FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission ), the Industrial Customers of Idaho Power (ICIP) , by and through their attorney of record, Peter J. Richardson, hereby requests 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. 1- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER 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. Please provide Dr. Reading s copy in electronic format, if available. 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. REQUEST FOR PRODUCTION NO. On page 11 of Mr. Said's direct testimony, Mr. Said is asked: "In the original PCA case, did the Company state a position regarding the appropriateness of the Staff- proposed load growth adjustment rate?" Mr. Said responds No. At the time the PCA was created, the Staff's proposed marginal load growth adjustment rate seemed like a small detail compared to the larger goal establishing a PCA mechanism. Please provide all documentation and communications related to, and an explanation of the company s contention that "at the time the PCA was created, the Staffs proposed marginal load growth adjustment rate seemed like a small detail compared to the larger goal of establishing a PCA mechanism. REQUEST FOR PRODUCTION NO. As compared to a load growth adjustment methodology that uses predicted marginal costs of serving load, does Idaho Power believe that a load growth adjustment rate equal to the current embedded PCA-related cost of serving load operates as a disincentive to Idaho Power for achieving conservation? Please explain why or why not. 2- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER REQUEST FOR PRODUCTION NO. On page 4 of Mr. Said's testimony, he states The Company should be afforded a reasonable opportunity to recover its PCA-related expenses associated with serving new customer loads in a timely manner. The best way to do this is to match the load growth adjustment rate to the Company actual ability to recover its costs by using embedded costs to determine the load growth adjustment rate. Although Idaho Power believes that matching the load growth adjustment rate to the embedded costs is, as explained above, the "best way" of affording the company to recover its PCA-related expense associated with serving new customer loads, please describe what lesser preferred methods the company could employ to try to recover its PCA-related expenses associated with serving new customer loads. REQUEST FOR PRODUCTION NO. On page 11 of Mr. Said's testimony, he states It was only after some time had passed that the Company came to realize the impacts of the penalty introduced by setting the load growth adjustment at a marginal level rather than an embedded level. Please provide all documentation or communications on which the Company relied in determining that a penalty was introduced by setting the load growth adjustment at a marginal level rather than an embedded level. REQUEST FOR PRODUCTION NO. On page 12 of Mr. Said's testimony, he describes the penalty that the Company believes is produced by using a predicted marginal cost load growth adjustment as 3- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER opposed to an embedded cost load growth adjustment. In his description, he states " the same time, the Company incurs additional costs associated with serving the additional load. . ." Please describe the additional costs the Company incurs "associated with serving the additional load. REQUEST FOR PRODUCTION NO. On page 12 of Mr. Said's testimony, he states "At the same time, the Company incurs additional costs associated with serving the additional load. . ." Does the Company believe there are any economies of scale associated with the "additional costs" incurred in serving additional load? Please explain fully your answer. REQUEST FOR PRODUCTION NO. On page 10 of Mr. Said's testimony, he states that "The Company believes that a primary intent of the PCA is to allow rates to change annually to replace the normalized PCA component of base rates with a PCA component reflective of current (actual) PCA expenses." Please identify source ofthe company s belief described by Mr. Said, and provide any documentation on which the Company bases this belief. REQUEST FOR PRODUCTION NO. On page 10 of Mr. Said's testimony, he states that "The Company believes that a primary intent of the PCA is to allow rates to change annually to replace the normalized PCA component of base rates with a PCA component reflective of current (actual) PCA expenses." Does the company believe that there are lesser intents of the PCA (i.e. that 4- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER there are intents of the PCA that are secondary to the "primary" intent described by Mr. Said)? If so, please explain fully. REQUEST FOR PRODUCTION NO. On page 15 of Mr. Said's testimony, he states that "Non-QF expenses have increased by $7 319,370. Non-QF generation has increased by 504 538 MWh. The incremental rate for non-QF served load growth has been $14.51 per MWh." Please provide the sources for all of the numbers set forth in this quotation from Mr. Said' testimony, and provide all relevant documentation, calculations, and contracts. Also please identify all plants that are included in the calculation of the increase in Non-QF generation. REQUEST FOR PRODUCTION NO.1 0: On page 14 of Mr. Said's testimony, he states that "QF expenses have increased by $20 517 997. QF generation has increased by 382 331 MWh. The incremental rate for QF growth has been $53.67/MWh." Please provide the sources for all of the numbers set forth in this quotation from Mr. Said's testimony, and provide all relevant documentation, calculations, and contracts. Also, please identify all plants that are included in the calculation of the increase in QF generation. III III 5- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER DATED this 18th day of July 2006. RICHARDSON & O'LEARY PLLC 6- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 18tl1 day of July, a true and correct copy of the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY, was served as noted to: Jean Jewell Idaho Public Utilities Commission 472 West Washington Street Post Office Box 83720 Boise, Idaho 83720-0074 (X) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ( ) Electronic Mail Barton L. Kline Monica B. Moen Idaho Power Company PO Box 70 Boise, Idaho 83707 bk1ine~idahopower.com mmoen~idahopower. com (X) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail Gregory W. Said Director, Revenue Requirement Idaho Power Company PO Box 70 Boise, ID 83707-0070 gsaid~idahopower.com (X) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 Scott. woodburv~puc.idaho. gov (X) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail William M. Eddie Advocates for the West PO Box 1612 Boise, ID 83701 billeddie~rmci.net (X) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail 7- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER Nancy Hirsh NW Energy Coalition 219 First Ave South, Suite 100 Seattle, W A 98104 X) u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ( ) Electronic Mail Lawrence A. Gollomp Assistant General Counsel United States Department of Energy 1000 Independence Ave., SW Washington, DC 20585 Lawrence. gollomp~hq .doe.gov ex) u.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ex) Electronic Mail Dale Swan Exeter Associates, Inc. 5565 Sterret Place, Suite 310 Columbia, MD 21044 dswan~exeterasso dates. com ex) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail Signe C1v\ 1\ Nina M. Curtis 8- FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER