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Home My WebLink About20070717Micron to IPC 1-27.pdfGIVE PSLEY LLP LAW OFFICES 601 W. Bannock Street PO Box 2720, Boise, Idaho 83701 TELEPHONE: 208 388-1200 FACSIMILE: 208 388-1300 WEBSITE: www.givenspursley.com Gary G. Allen Peter G. Barton Christopher J. Beeson William C. Cole Michael C. Creamer Thomas E. Dvorak Jeffrey C. Fereday Martin C. Hendrickson Steven J. Hippler Debora K. Kristensen Anne C. Kunkel Jeremy G. Ladle Michael P. Lawrence Franklin G. Lee David R. Lombardi John M. Marshall Kenneth R. McClure Kelly Greene McConneil Cynthia A. Melitlo Christopher H. Meyer L Edward Miller Patrick J. Miller Judson B. Montgomery Angeia K. Nelson Deborah E. Nelson W. Hugh O'Riordan, LLM. Angela M. Reed Scott A. Tschirgi, LLM. J. Will Varin Conley E. Ward Robert B. White Terri R. Yost RETiRED Kenneth L. Pursley Raymond D. Givens James A. McClure ;--..)(~:;" cC' ::. July 17 2007 :~,-,.. Via Hand Delivery . ,, ';:!-..-.. ,. Jean Jewell Idaho Public Utilities Commission 472 W. Washington O. Box 83720 Boise, ill 83720-0074 C'") ,-."--'....,) Re: Our File: 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- 4489- Dear Jean: Enclosed for filing are an original and four (4) copies of Micron Technology, Inc.' s First Set of Discovery Requests to Idaho Power Company in connection with the above-captioned matter. If you have any questions, please call me. ~incerelY, (\ --J ~'0\ \ n .G ( cNVLu~ l\;L Tina M. Adometto Assistant to Conley Ward CEW /tmacc: Service List (w/enc1osures) S:\CLIENTS\4489\29\TA to Jean Jewel1 re 1st set of Discovery.DOC 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(fY gi venspursl ey. com . if ! i : ::, ; U' Attorneys for Micron Technology, Inc. S:\CLIENTS\4489\299\Micron First Disc Reg to 1Pc.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 TO ELECTRIC CUSTOMERS IN THE STATE OF IDAHO Case No. IPC-07- 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 ofIdaho 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 of Idaho 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 of the 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- 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 of Idaho 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- 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 With respect to page 6, lines 15-22 of Ms. Smith's testimony, provide the most recent 13 months adjusted actual plant in service data available. Please illustrate and explain the difference between the current 13-month average methodology and the simple average methodology. With respect to Ms. Smith's testimony at page 7 , lines 1-, provide the most recent 12 months of actual O&M expense data by business unit and cost element. With respect to Ms. Smith's testimony at page 7, lines 21-25 provide the approved 2007 forecast O&M data by month, business unit and cost element. With respect to Ms. Smith's testimony at page 8, lines 12-, provide budgeted O&M expense by cost center. With respect to Ms. Smith's testimony at page 8, lines 12-, show the actual allocation of O&M expense by cost center to FERC account and provide the 2006 actual O&M charges to those accounts. Provide forecast 2008 O&M budgets by business unit and cost element. With respect to Ms. Smith's testimony at page 9, lines 16-, provide construction expenditures by project, workpapers for the closings to plant and the actual historical average for closings to plant. MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 5 20. 21. With respect to Ms. Smith's testimony at page 11 , lines 18-, provide the five year historical averages and the data to compute the averages for the average percentage of monthly retirements to monthly additions. Provide data comparable to Exhibit 16, but using the latest available 12 months data rather than forecast 2007 forecast data. 10.Provide all data, workpapers and spreadsheets used to develop 2007 forecast sales revenues shown at Exhibit 2, page 2 , line 2. 11.With respect the testimony of Ms. Schwendiman, page 9, lines 14-, provide all data workpapers, spreadsheet and any other information used to develop the $370 387 revenue credit for 2007 investment. 12.Provide data comparable to Exhibit 24, but for the most recent 12 months actual, rather than 2007 forecast. 13.Provide data comparable to Exhibit 25 , but using unadjusted data for the most recent 12 months actual, rather than 2007 forecast. 14.Ms. Smith's testimony at page 3 , lines 11-, indicates that Ms. Schwendiman "addresses the normalizing adjustments to sales and revenues . Provide all data workpapers documents, spreadsheets and any other information used by Ms. Schwendiman to develop the normalizing adjustments to sales and revenues. 15.Provide the most recent marginal cost study prepared by the company. 16.Provide in electronic format the actual Excel workbooks used to prepare the cost of service studies, including all the input data and formulas. 17.Provide detailed workpapers for the "workshop methodology" for converting billing period data to calendar month data used in the current rate proceeding, including all input data, formulas and calculations. 18.Provide detailed workpapers for the "surrogate demand normalization methodology used in the current proceeding for determining class coincident peak demands, including all input data, formulas, and calculations. 19.Provide all cost of service studies prepared by the Company for rate proceedings since 2000. Provide the Company s complete 2006 Integrated Resource Plan. Provide the updated marginal energy costs for the five year period 2007-2011 referred to in the testimony of Mr. Tatum at page 29, lines 5- MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6 22. 23. 24. 25. 26. 27. Provide monthly load factors and production for each ofthe Company s hydro and thermal generating resources, including the three combustion turbines referenced in Mr. Tatum s testimony at page 39, linesl- 7, for the last five years. Provide all monthly energy and peak hour surplus/deficiency data in numeric format for the years 2007 -2011 from the 2006 IRP used to seasonalize marginal generation capacity costs and as discussed in Mr. Tatum s testimony at page 27, lines 13-25. Provide monthly system retail sales and coincident peak loads for the last 10 years. Provide all LOLP or other capacity risk or load loss studies performed by or for the Company during the last 3 years. Provide a copy of any draft Integrated Resource Plan for Idaho Power Company. 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 17th day of July 2007. 6Mv MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY- CERTIFICATE OF SERVICE '(\ I HEREBY CERTIFY that on this IT day of July, 2007, I caused to be served a true and correct copy of the foregoing by the method indicated below, and addressed to the following: Jean Jewell Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, ID 83720-0074 Eric L. Olsen Racine, Olson, Nye, Budge & Bailey Chartered O. Box 1391 201 E. Center Pocatello, Idaho 83204-1391 email: rcbcq~racinclaw.net elocq!racinelaw.net S. Mail Hand Delivered Overnight Mail Facsimile Mail "f.S. Mail Hand Delivered Overnight Mail Facsimile Mail US. Mail Hand Delivered Overnight Mail Facsimile Mail US. Mail Hand Delivered Overnight Mail Facsimile Mail US. Mail Hand Delivered Overnight Mail Facsimile Mail Barton L. Kline Monica B. Moen Idaho Power Company O. Box 70 Boise, ID 83707 email: bkline(ev,idahopowcr.com John R. Gale Vice President Regulatory Affairs Idaho Power Company O. Box 70 Boise, ID 83707 email: rgale(a~idahopower.com Peter J. Richardson Richardson & O'Leary 515 N. 2ih Street Boise, ID 83702 email: pcter(a~richardsonandolcary.com Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 email: vankel~attbi.com US. Mail Hand Delivered Overnight Mail Facsimile Mail MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8 Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 email: dreading((Vmindspring.com u.S. Mail Hand Delivered Overnight Mail Facsimile Mail MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 9