20070814DOE to IPC 1-1 to 1-21.pdf

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Department of Energy
Washington, DC 20585 F(EC;E i"
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August 10, 2007
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington St.
O. Box 83720
Boise, Idaho 83720-0074
RE: Case No. IPC-07-
Dear Ms. Jewell:
Enclosed for fIling please find the original and three (3) copies of the United StatesDepartment of Energy s first data request to Idaho Power Company.
Thank you for your assistance.
Arthur Perry Bruder
Attorney for the
United States Department of Energy
1000 Independence Ave. SW
Washington, D.C. 20585
arth ur. ruder~hq doe.gov
[phone]
cc: service list
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ARTHUR PERRY BRUDER
OFFICE OF THE GENERAL COUNSEL
UNITED STATES DEPARTMENT OF ENERGY
1000 INDEPENDENCE AVE. SW
WASHINGTON, DC 20585
[phone]
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arthur. bruder~hq.doe.gov
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Attorneys for the United States Department of Energy
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-O7-
FIRST INTERROGATORIES
AND PRODUCTION REQUESTS
OF THE UNITED STATES
DEPARTMENT OF ENERGY
TO IDAHO POWER COMPANY
The United States Department of Energy ("DOE") by and through its attorney of
record, Arthur Perry Bruder, requests that Idaho Power Company (Company; IPC)
provide the following as soon as possible, but no later than September 7, 2007. DOE
further requests that the Company, in its responses hereto:
set out the text of each request prior to the text of response;
place the text of each request and the response to that request on a separate page
and, where there are subparts to a request, place each subpart and the response to
it on a separate page.
regard each request as continuing, so that if the Company acquires or discovers
additional or different information with respect to a request after it has initially
answered the request, immediately provide such additional or different
information in the form of supplemental responses, and provide the additional or
different information to the same extent as originally requested;
set out, as part of each response, all of the assumptions which underlie the
response;
if it asserts that any requested information is not available in the form requested:
(a)describe the form in which the requested information currently exists
(identifying documents by title);
(b)state whether it is possible under any circumstances for Idaho Power to
provide the data in the form requested;
(c)describe the procedures or calculations necessary to provide the data in the
form requested;
(d)provide an estimate of the length of time (in hours or days) necessary for
Idaho Power to prepare the data in the form requested; and
(e)provide the earliest dates, time period, and location where DOE rep-
resentatives may inspect the files; records or documents in which the
requested information currently exists;
to the extent it cannot provide any requested document in full, provide it to the
extent possible, together with a statement of what document(s) or portiones) of
those document(s) are being withheld, and the reasons for withholding each;
provide all documents in the same order as they are kept or maintained by Idaho
Power. If they are attached to one another, do not separate them;
provide documents that are not otherwise responsive to the request if they are
attached to documents that are responsive to that request, and constitute routing
slips, transmittal memoranda, letters, comments, evaluations, or similar materials;
as part of each response, provide the name(s) and title(s) of the person(s) who
prepared the response, and the name( s) of the witness( es) who will be prepared to
testify concerning the matters contained in each response or document provided;
10.where the request seeks quantitative or computational information (e.models
analyses, databases, formulas) which is stored in machine-readable form, in
addition to providing hard copy, furnish the machine-readable information, on
CD-ROM for IBM compatible PC for large files, as:
(i)Excel worksheet files;
(ii)ASCII text files; or
11.
(iii)other IBM PC compatible worksheet or database files.
provide responsive information and documents as they become available, rather
than withhold them until a complete response to all of DOE's requests is available.
DOE-
DOE-
DOE-
DOE-
DOE-
Please provide copies of all of the Company s responses to requests for
information which were submitted to it by other parties in this docket.
This is an ongoing request.
Referring to the direct testimony of Timothy Tatum at 10:15 -11:2:
(a) Please identify the specific generation resources referenced at 10: 16-
17.
(b) For each generation resource identified in response (a) above, please
specify the resource type, and its installed cost, in-service date, and
nameplate or rated capacity.
For each generation resource identified in response (a) above, please
provide by month, from January 2006 to the present, the resource
total hours of operation, total kWh output, and total operating cost.
( d) Please quantify the .. .increased investment in generation resources
necessary to meet the summer peak load.. ." and state the time period
over which this increased investment has occurred.
Referring to the direct testimony of Timothy Tatum at 11:7-20:
(a) Please provide all workpapers, studies, analyses, and documents
supporting and/or underlying the statement that "
.. .
Idaho Power has
three distinct time-based production costing periods that are driven by
customer loads.
(b) For the intermediate production costing period, please specify by
month the daily hours that define the costing period.
(c) For the peak production costing period, please specify by month the
daily hours that define the costing period.
Referring to the direct testimony of Timothy Tatum at 11 :20-, please
provide all workpapers, studies, analyses, and documents supporting
and/or underlying the statement that"... the same generation resources are
typically utilized to serve both the base and intermediate loads.. ..
Please provide the marginal cost study(ies) used to develop Exhibit No. 39
DOE-
DOE 1-
DOE 1-
DOE 1-
DOE 1-10.
DOE 1-11.
DOE-12.
Please provide in electronic format all workpapers for the direct testimony
of Idaho Power witnesses Gregory Said, Maggie Brilz, and Timothy
Tatum.
Please provide Exhibit Nos. 20-37 and 58-60 in Excel format with all
formulas and links intact.
Referring to Exhibit No. 47, please explain in detail why transmission
capacity marginal costs are significantly greater than generation capacity
marginal costs in the months of May-September and December?
Referring to the direct testimony of Timothy Tatum at 39:1-
(a) Please identify the 3 combustion turbines and state the in-service date
and nameplate capacity for each CT.
(b) For each CT identified in response (a) above, please provide by
month for each CT its kWh output since its in-service date.
Referring to Exhibit No. 41 at 36:258:
(a) Please define and explain in detail "Adjustment to Revenue/Refunds.
(b) Please provide the justification for IPC'functionalization and
classification of these revenues.
Referring to Exhibit No. 41 at 36:260:
(a) Please provide the justification for IPC's classification of Account
447 revenues.
(b) Please provide in Excel format Account 447 Opportunity Sales by
month from January 2002 through the present showing for each
transaction the total kWh sold, total revenue received, and whether
the transaction was priced using a one- or multi-part rate.
Referring to IPUC Tariff No. 29:
(a) Please provide all workpapers, studies, analyses, and documents
supporting and/or underlying the proposed voltage-differentiated
demand charges in Schedules 9 and 19.
(b) Please provide all studies and/or analyses of system losses by service
voltage prepared by or for Idaho Power in the past five years.
DOE-13. Please provide copies of Mr. Avera s direct and rebuttal testimony (and
supporting exhibits) on cost of capital in IPC Docket No. E-03-13.
DOE-14. Please provide copies of all credit rating reports pertaining to IPC that have
been issued since January 1 2006.
DOE-15. Please provide a copy oflPC's most recent presentation to credit rating
agencIes.
DOE-16. Please provide copies of all presentations by IPC and/or IdaCorp
management to securities analysts since January 1 2007.
DOE-17. Please provide Dr. Avera s opinion regarding IPC's business risk today as
compared to its business risk at the time of its 2003 rate case.
DOE-18. Please provide any supporting calculations (including an identification of key
assumptions) concerning IPC's projections of its year-end common equity
balance.
DOE-19. Please provide the following concerning any public issuance of common
stock by IdaCorp parent company, 2004 2005 2006 and 2007 (to date):
(a) date of issuance;
(b) net proceeds; and
(c) expenses associated with issuance, including underwriting fees.
DOE-20. Please provide any plans for a public common stock issuance by IdaCorp
during 2007-2009, indicating approximate amount of issuance.
DOE-21. Please indicate Standard & Poor s current Business Profile rating for IPC.
DATED at Washington, D., this tenth day of August, 2007.
Arthur Perry Bruder
Attorney for the United States Department of Energy
CERTIFICATE OF SERVICE
I hereby certify that on this 10th day of August, 2007, I served a true and correct copy of
the foregoing document upon the following named parties, at the addresses, and by the
methods, which are set out below.
SECRETARY OF THE COMMISSION
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ID 83720-0074
via U.S. Mail
COMMISSION STAFF
Donovan Walker
Deputy Attorney General
Weldon Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
O. Box 83720
Boise, ID 83720-0074
Donovan. W alker~puc.idaho.gov
W eldon.Stutzman~puc.idaho.gov
via U.S. Mail and email
IDAHO POWER COMPANY
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID 83707
email: bklinecmidahopower.com
via U.S. Mail and email
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, ID 83707
email: rgale(ip,idahopower.com
via email
INDUSTRIAL CUSTOMERS OF IDAHO POWER
Peter 1. Richardson
Richardson & O'Leary
515 N. 27th Street
Boise, ID 83702
email: peter~richardsonandoleary.com
via U.S. Mail and email
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise Idaho 83702
email: dreading~mindspring.com
via email
IDAHO IRRIGATION PUMPERS ASSOCIATION
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey Chartered
O. Box 1391
201 E. Center
Pocatello, Idaho 83204-1391
email: elo~racinelaw.net
via U.S. mail and email
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
email: tony~yankel.net
via email
KROGER
Kurt 1. Boehm
Michael L. Kurtz
Boehm, Kurtz & Lowry
36 East Seventh Street, Suite 510
Cincinnati, OHIO 45202
mkurtz~bkllawfirm.com
kboehm~bkllawfirm.com
via u.s. Mail and email
The Kroger Company
Att': Corporate Energy Manager (G09)
1014 Vine Street
Cincinnati, OHIO 45202
via U.S. Mail
MICRON
Conley Ward
Michael Creamer
Givens Pursley
601 W. Bannock St.
O. Box 2720
Boise, ID 83701
cew~givenspursley .com
mcc~givenspursley.com
via U.S. mail and email
Dennis E. Peseau, Ph.
Utility R4esources Inc.
1500 Liberty St. SE Suite 250
Salem, OR 97302
dpeseau~excite.com
via email
n~,.
Arthur Perry B
Attorney for the
United States Department of Energy
arth ur. bruder~hq.doe. gov
office: (202 586-3409fax: [phone]