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Home My WebLink About20060804Staff to IPC 1-5.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BARNO. 1895 RECEIVED ZOOb AUG -4 AM \\: IDAHO PUB.LIQ UTILITIES COMr.lISSION 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 PETITION OF IDAHO POWER COMPANY FOR MODIFICATION OF THE LOAD GROWTH ADJUSTMENT FACTOR WITHIN THE POWER COST ADJUSTMENT (PCA) )METHODOLOGY. CASE NO. IPC-06- FIRST 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 Scott Woodbury, 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, AUGUST 25, 2006. 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. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY AUGUSTN 4, 2006 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.1: Please provide the calculation of the $6.81/MWh contained in Mr. Said's testimony on page 3 , line 21. Include workpapers that show the development of the numerator and denominator used in the calculation. If the power supply model run that produces these numbers has been previously presented to the Commission identify the run. If it has not been previously presented to the Commission, please provide the electronic input files in Aurora readable format and the electronic output files for all years along with a summary of the results in excel format. REQUEST NO.2: Please provide the same information for the $7 .30/MWh number presented in Mr. Said's direct testimony in Case No. IPC-03-, on page 26, line 4. REQUEST NO.3: Were the two numbers referenced in requests 1 and 2 (6.81 and 30) calculated using the same methodology? If they were not, what is the difference in methodology and why is the methodology different? REQUEST NO.4: Please provide the output summary for an Aurora power supply model run that is identical to the Aurora power supply model run presented in the Company most recent general rate case, Case No. IPC-05-, except that the normalized load is increased by 10 MWa in each hour of the test year. Please provide the output summary in the format of page 1 of Exhibit No. 20 in the referenced case. REQUEST NO.5: Please provide the same information for a 10 MWa increment in load of the power supply model run presented by the Company in the IPC- E-03-13 general rate case. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY AUGUSTN 4, 2006 DATED at Boise, Idaho, this ~day of August 2006. Scott Woodbury Deputy Attorney General Technical Staff: Keith Hessing i :umisc :prodreq/ipceO6. 8dhkh FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY AUGUSTN 4, 2006 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF AUGUST 2006 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: BARTON L KLINE MONICA MOEN IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 GREGORY W SAID DIRECTOR, REVENUE REQUIREMENT IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 PETER J RICHARDSON RICHARDSON & O'LEARY 515 N 27TH ST PO BOX 7218 BOISE ID 83702 DR DON READING 6070 HILL ROAD BOISE ID 83703 WILLIAM MEDDlE ADVOCATES FOR THE WEST PO BOX 1612 BOISE ID 83701 NANCY HIRSH NW ENERGY COALITION 219 FIRST AVENUE SOUTH SUITE 100 SEATTLE WA 98104 LAWRENCE A GOLLOMP ASSIST ANT GENERAL COUNSEL S. DEPARTMENT OF ENERGY 1000 INDEPENDENCE AVE SW ASINGTON DC 20585 DALE SWAN EXETER ASSOCIATES INC 5565 STERRET PLACE SUITE 310 COLUMBIA MD 21044 ~~. SECRETARY CERTIFICATE OF SERVICE