20070629Staff to IPC 1-9.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 3283
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DONOV AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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 RATES AND
CHARGES FOR ELECTRIC SERVICE TO
ELECTRIC CUSTOMERS IN THE STATE OF IDAHO.
CASE NO. IPC-07-
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
Donovan E. Walker, 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, JULY 27, 2007.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JUNE 29 , 2007
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 produced.
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 electronic, executable copies of all AURORA input
output and any other files used to produce the variable power supply expense results presented in
the Company's case. Along with the files, please provide detailed instruction for making the
AURORA runs.
REQUEST NO.2: Please provide electronic, executable copies of all AURORA input
output and any other files used to produce the marginal costs shown in Exhibit No. 37.
REQUEST NO.3: What gas prices have been assumed for the AURORA simulations?
Please cite the source for these gas prices and discuss any adjustments or assumptions made by
Idaho Power with regard to the gas prices used.
REQUEST NO.4: Pages 13-14 of the workpapers of Greg Said show PURPA generation
by project for 2005 and for 2007. Do the generation amounts shown for 2005 represent actuals or
estimates? Please provide actual generation amounts for each project for 2006. Please reconcile the
amounts shown in the workpapers with comparable amounts on Said's Exhibit No. 34 and explain
any differences or adjustments. Do the generation amounts shown on Exhibit 34 for 2006 represent
actuals or estimates? If the amounts are estimates, please explain how they have been derived.
REQUEST NO.5: Page 5, line14-16 of Greg Said's direct testimony states that the
Horizon Wind project is scheduled to be on-line on January 1 2008. However, Idaho Power
contract with Horizon states that the Scheduled Operation Date for the project is December 1 2007
and the Guaranteed Operation Date is March 31 , 2008. Please reconcile these dates.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JUNE 29, 2007
REQUEST NO.6: Please identify any specific changes made to transmission capacities
assumed in AURORA since Idaho Power s last general rate case.
REQUEST NO.7: On page 10, line 9 through page 11 , line 12 of Greg Said's testimony,
he discusses the range of modeled market prices for both purchased power and surplus sales for the
current case and for the Company s previous rate case. What is the range of prices actually
experienced by Idaho Power during 2006 for purchased power and surplus sales?
REQUEST NO.8: On page 11 , line 13 through page 12, line 4 of Greg Said's testimony,
he discusses increases in coal prices since the Company s last general rate case. Are coal prices for
Bridger, Valmy and Boardman established for each year based on contracts or on some other
method? Please provide documentation showing the basis for the coal prices used in power supply
modeling for each ofthe three coal plants (e., partial contracts, sources for price inflators, etc.
REQUEST NO.9: Please provide the budgets for 2005-2007 by cost center, the allocation
method used to allocate those amounts to FERC accounts as used in the Company s filing, along
with a comparison of actual FERC account values to those budgeted and allocated.
DATED at Boise, Idaho, thiCJlAay of July 2007.
Donovan E. Walker
Deputy Attorney General
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Technical Staff: Rick Sterling
Keith Hessing
Donn English
i:umise:prodreqlipeeO7.8dwrpskh staff to ipe 1
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JUNE 29, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE T,HIS 29TH DAY OF JUNE 2007
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER IN CASE NO. IPC-07-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
JOHN R GALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
DR DON READING
6070 HILL ROAD
BOISE ID 83703
CERTIFICATE OF SERVICE