20070815IPC to Micron 1-27.pdf

BARTON L. KLINE
Attorney
August 14 , 2007
Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise , Idaho 83720-0074
Re:Case No. IPC-07-
General Rate Case Filing
Dear Ms. Jewell:
IDAHO~POWER~
An IDACORP Company
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Please find enclosed an original and two (2) copies of the Response of Idaho Power
to the First Production Request of Micron Technology, Inc. in the above-referenced matter.
I would appreciate it if you would return a stamped copy of this transmittal letter in
the enclosed self-addressed, stamped envelope.
BLK:sh
Enclosures
Very t uly yours
O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
BARTON L. KLINE ISB #1526
LISA D. NORDSTROM ISB #5733
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
RECEIVED
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Attorney for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
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-
RESPONSE OF IDAHO POWER TO
THE FIRST PRODUCTION REQUEST
OF MICRON TECHNOLOGY INC.
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company ) and , in
response to Micron Technology Inc.'s First Set of Discovery Requests to Idaho Power
Company dated July 17, 2007, herewith submits the following information:
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page
REQUEST FOR PRODUCTION NO.: 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 simple average methodology.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The thirteen month average method is an average of the Electric Plant in Service
balance over the last thirteen months. The Simple Average is an average of the first
and last month Electric Plant in Service balance for the thirteen month period.
The requested explanatory documents are enclosed.
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance , Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 2
REQUEST FOR PRODUCTION NO.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.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The requested information is enclosed.
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance , Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom, Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 3
REQUEST FOR PRODUCTION NO.With respect to Ms. Smith's testimony at
page 7 , line 21-25, provide the approved 2007 forecast O&M data by month , business
unit and cost element.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The requested information is enclosed.
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom , Attorney II, Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 4
REQUEST FOR PRODUCTION NO.With respect to Ms. Smith's testimony at
page 8 , lines 12-, provide budgeted O&M expense by cost center.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The requested information is enclosed.
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance , Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom , Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 5
REQUEST FOR PRODUCTION NO.: 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.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The enclosed Excel spreadsheets for the 2006 actual expenses by FERC
account and the 2007 forecast by FERC account provide the requested information.
For actual allocation by cost center to FERC account please refer to the excel formulas
within the individual cells.
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance , Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 6
REQUEST FOR PRODUCTION NO.Provide forecast 2008 O&M budgets by
business unit and cost element.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The 2007 forecast was based upon the 2007 budget approved by the Company
Board of Directors. The 2008 forecast is derived from the 2007 budget and was
escalated for inflation, therefore there is no 2008 O&M budget.
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance , Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom, Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 7
REQUEST FOR PRODUCTION NO.With respect to Ms. Smith's testimony at
page 9, lines 16-23, provide construction expenditures by project, workpapers for the
closings to plant and the actual historical average for closings to plant.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The closings to plant by project type and plant account were obtained for 1998
through 2002 from the Company s Asset Management system. The closings were then
totaled by plant account for the five-year period within each project type. The total five-
year closing percentage for each plant account was determined by dividing the
individual plant account closings for the five-year period by the total project type
closings for the five-year period. Estimated closings for 2007 by project types were
provided by each of the Business Units and allocated to the individual plant accounts
using these allocation percentages.
Project types 40 , 42, 43 , 44, 45, 46, 47 , 48, and 49 were allocated using a
slightly different methodology. For these project types , a two-year average was used as
the basis period instead of the five-year average. The change in methodology was a
result of determining that the use of the five-year average distorted the results. The
distortion was caused by the 2004 elimination of the inplant accounting methodology
that was used for capitalizing meters and transformers. As a result , it was determined
that the most recent two-year period was a more representative time period to
determine closings to plant for these Project types.
Explanatory documents and workpapers are enclosed.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 8
The response to this request was prepared by Lori Smith, Vice President and
Chief Risk Officer, Finance , Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom, Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 9
REQUEST FOR PRODUCTION NO.: 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.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The five year historical data for additions and retirements of Electric Plant in
Service (EPIS) was obtained from the Company s Asset Management system. The
additions and retirements recorded to EPIS for the five-year period 1998 through 2002
were totaled by plant account and grouped into categories based on the type of plant.
For example, plant accounts 350 through 359 are transmission station and line assets
and are grouped as "Transmission Plant"Next, the five-year retirement percentage
was calculated by dividing the total five-year retirements by category, by the total five-
year additions for each category. This percentage was then applied to the total 2007
estimated monthly additions in order to derive the estimated 2007 retirements by
category. Finally, in order to spread the total retirements by category back to the
individual plant accounts the percentage of five-year retirements by plant accounts to
the total of the five-year retirements by category was derived. These percentages were
then applied to the total estimated 2007 retirements by category to derive the forecasted
plant account retirement amounts within each category.
Actual retirements were determined for plant account 301 , 302 , 303 , 391 , 393
394, 395, 397 , and 398 because assets in these accounts are retired based on vintage
year.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 10
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 11
REQUEST FOR PRODUCTION NO.Provide data comparable to Exhibit 16
but using the latest available 12 months data, rather than forecast 2007 forecast data.
RESPONSE TO REQUEST FOR PRODUCTION NO.
Idaho Power objects to this Production Request on the grounds that it is vague
and does not provide the assumptions necessary to respond. Without waiving this
objection, the 12 months ended data, June 30 , 2007 actuals , are enclosed. Certain
schedules that require computation , that are not done on an interim basis, have not
been included.
The response to this request was prepared by Lori Smith , Vice President and
Chief Risk Officer, Finance , Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom , Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 12
REQUEST FOR PRODUCTION NO.1 0:Provide all data, workpapers and
spreadsheets used to develop 2007 forecast sales revenues shown at Exhibit 2 , page 2
line 2.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
The 2007 test year sales revenue amount of $797 776 922 listed on Exhibit 20
page 2 , line 2 is comprised of four revenue categories: Retail Sales, Adjustments to
Sales Revenues/Refunds , Firm Sales for Resale , and System Opportunity Sales. The
2007 test year revenue associated with each of the revenue categories is detailed on
Exhibit 24 , page 1 , lines 3-
The Retail Sales amount of $646,474 074 listed on Exhibit 24, page 1 , line 3 is
derived by applying current rates to the test year billing units for each customer class.
The billing units used in this process are contained in two Excel spreadsheets included
with this response.The New Usages tab the Excel file titled
BiliingUnits RetaiIRates" contains the billing units used to derive the test year revenue
for all retail customers excluding Special Contract customers. The billing units used to
derive the test year revenue for the Special Contract customers are contained in the
Excel file titled "BiliingUnits SpeciaIContractsandWholesaleCust."The revenue
calculations for each Idaho retail customer class are detailed on Exhibit 59, pages 2-23.
The revenue category "Adjustments to Sales Revenues/Refunds" is explained by
Mr. Said in his testimony, pages 30 and 31. The calculation of the amount $370 387
listed on Exhibit 24 , page 1 , line 4 is detailed on Exhibit 39. The calculation of the Firm
Sales for Resale amount of $1 622 084 included on Exhibit 24 , page 1 , line 5 is detailed
in the attached Excel file titled "RRC-PNF". The derivation of the System Opportunity
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 13
Sales amount of $149,310,377 found on Exhibit 24, page 1 , line 5 is equal to the sum of
the revenue subcategories Transmission Losses and Surplus Sales Revenue Excluding
Transmission Costs. In this context , the revenue subcategory Transmission Losses
represents revenues received for the provision of energy to serve third-party
transmission line losses , which is described in more detail in Ms. Smith's testimony,
pages 13 and 14. Transmission Losses for 2007 in the amount of $6 426 777 can be
found on page 53 of Ms. Schwendiman s workpapers and 2007 Surplus Sales Revenue
Excluding Transmission Costs in the amount of $142 883 600 can be found on page 63
of Ms. Schwendiman s workpapers.
The response to this request was prepared by Celeste Schwendiman , Senior
Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 14
REQUEST FOR PRODUCTION NO. With respect to 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
As stated in Ms. Schwendiman s testimony on page 9, line 19, the revenue credit
was provided by Mr. Said. Mr. Said provided the development of this number in Exhibit
No. 39 and describes that exhibit on page 30, lines 11 through 25 of his testimony.
The response to this request was prepared by Greg Said, Manager of Revenue
Requirement and Celeste Schwendiman , Senior Pricing Analyst, Pricing and Regulatory
Services Department, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 15
REQUEST FOR PRODUCTION NO. 12 Provide data comparable to Exhibit 24
but for the most recent 12 months actual , rather than 2007 forecast.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
Idaho Power objects to this Production Request on the grounds it is vague and
does not provide the assumptions necessary to calculate the requested adjustment
columns in the referenced exhibit. Without waiving this objection , Idaho Power has
enclosed a workpaper showing the necessary change from the specified starting point
(mid-year actuals) to the Company s filed test year.
The response to this request was prepared by Celeste Schwendiman, Senior
Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney and/or Lisa D. Nordstrom , Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 16
REQUEST FOR PRODUCTION NO. 13 Provide data comparable to Exhibit 25
but using unadjusted data for the most recent 12 months actual, rather than 2007
forecast.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
Idaho Power objects to this Production Request on the grounds that it is vague
and does not provide the assumptions necessary to calculate the requested adjustment
columns in the referenced exhibit. Without waiving this objection , Idaho Power has
enclosed a workpaper showing necessary change from the specified starting point (mid-
year actuals) to the Company s filed test year.
The response to this request was prepared by Celeste Schwendiman, Senior
Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney and/or Lisa D. Nordstrom, Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 17
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
At pages 3-15 of his direct testimony, Mr. Said states that for the 2007 test year
the analyses includes water conditions corresponding to years 1928 through 2006. The
average of the variable power supply expenses related to each of the 79 water
conditions represents the normalization of variable power supply expenses. Details for
the net power supply cost normalization can be found in Mr. Said's Exhibit Nos. 32-
and 36, and in Mr. Said's work papers.
The adjustment to the Company s system opportunity sales revenue of
negative $106 112 573 reflects the decreased level of opportunity sales associated with
the multiple historical water conditions provided.
Test year sales revenues were developed as described in the Response
to Request No.1 O.
The adjustments as applied to the jurisdictional separation study are detailed in
Ms. Schwendiman s work papers , pg. 56-, and 148-161.
The response to this request was prepared by Celeste Schwendiman , Senior
Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 18
REQUEST FOR PRODUCTION NO. 15 Provide the most recent marginal cost
study prepared by the Company.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
Company s most recent analysis of the generation and transmission marginal
costs is included in Mr. Tatum s workpapers , pages 48-55. Idaho Power has not
recently prepared a full marginal cost study that includes distribution marginal costs
along with generation and transmission marginal costs.
The response to this request was prepared by Timothy Tatum , Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 19
REQUEST FOR PRODUCTION NO. 16: Provide in electronic format the actual
Excel workbooks used to prepare the cost of service studies, including all the input data
and formulas.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
The requested information was provided with the Company s Response
Requests No.6 and No.7 of the Industrial Customer s Third Request for Production.
The response to this request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom , Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 20
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
The factors for converting billing period data into calendar month data used in
this rate case proceeding are contained in the file titled
CalendarMonthFactors20042006.xls which is enclosed with this response. Three years
of factors were determined using the workshop methodology, and then the median
factors were used for the forecast 2007 test year.
Customers are billed throughout each month, and billing periods (cycles) typically
include portions of more than one calendar month. Prior to adopting the workshop
methodology, billing period data was converted into calendar month data using a simple
linear interpolation. Daily consumption during the billing period was assumed to be flat
and weather effects were ignored.
As part of the current rate case proceeding, the billing month data have been
converted into calendar month data using the nonlinear method based on load research
data that utilizes actual daily usage patterns. Daily consumption is assumed to fluctuate
in proportion to the fluctuations in the daily consumption of the load research sample
customers. This methodology captures the effects of weather on energy consumption
and improves the process of determining coincident peak demand responsibility.
The daily consumption data for the average customer in each load research
sample for 2004 through 2006 are contained in the DailykWh20042006.xls workbook
which is enclosed. The meter reading schedules for those years are also included. Not
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 21
all meters were read on the scheduled read dates, however. Every month, for example
some customers turned off and others turned on.
The actual computations to arrive at the factors for converting billing period data
to calendar month data in this case were performed on a bill-by-bill basis using actual
read dates within a SAS program. The input included hundreds of thousands of bills for
each month , and therefore, is too voluminous to provide with this response. However
on request, the additional information and material used under the workshop
methodology will be made available for review at the Company s headquarters located
at 1221 West Idaho Street, Boise , Idaho 83702.
The response to this request was prepared by Timothy Tatum , Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 22
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
The surrogate demand normalization methodology agreed to by the parties as
part of the cost-of-service workshop process (Case No. IPC-04-23) uses the five-year
median demand ratios applied to the normalized monthly energy values for each
customer class to determine the coincident peak demands by class. This methodology
eliminates the effect of any atypical demand ratios that might exist in a given year due
to unusual weather conditions.
The detailed workpapers that support this process are included with this
response. The input data, formulas , and calculations are contained in the Excel
workbook Demands07RCMedianFactors.xls. The five years of demand ratios are
contained in MedianDemandFactors20022006.xls. Additional documentation of the
formulas and methodology are provided in LoReMethod2007.doc.
The response to this request was prepared by Timothy Tatum , Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 23
REQUEST FOR PRODUCTION NO. 19: Provide all cost of service studies
prepared by the Company for rate proceedings since 2000.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19:
The Company has prepared three cost-of-service studies since 2000. The study
prepared for Case No. IPC-07-08 using 2007 test year data was provided with the
Company s Response to Requests No.6 and No.7 of the Industrial Customer s Third
Request for Production. The cost-of-service study prepared for Case No. IPC-E- 03-
using 2003 test year data and the study prepared for Case No. IPC-E- 05-28 using 2005
test year data in Excel format are enclosed.
The response to this request was prepared by Timothy Tatum , Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 24
REQUEST FOR PRODUCTION NO. 20 Provide the Company s complete 2006
Integrated Resource Plan.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
The 2006 Integrated Resource Plan is provided on the enclosed CD. A hard
copy can be made available upon request.
The response to this request was prepared by Greg Said, Manager of Revenue
Requirement, Pricing and Regulatory Services Department , Idaho Power Company, in
consultation with Barton L. Kline, Senior Attorney and/or Lisa D. Nordstrom , Attorney
Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 25
REQUEST FOR PRODUCTION NO. 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-
RESPONSE TO REQUEST FOR PRODUCTION NO. 21 :
The marginal energy costs for the five year period 2007-2011 are included in Mr.
Tatum s workpapers, page 51.
The response to this request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney
and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 26
REQUEST FOR PRODUCTION NO. 22:Provide monthly load factors and
production for each of the Company s hydro and thermal generating resources
including the three combustion turbines referenced in Mr. Tatum s testimony at page 39,
lines 1-, for the last five years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22:
The Company does not calculate load factors for its generation resources.
However, enclosed with this response is an Excel file containing the monthly energy
output in megawatt-hours and the maximum generating capability for each of the
Company s generation resources for the years 2002 - 2006.
The response to this request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney
and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 27
REQUEST FOR PRODUCTION NO. 23 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23:
The 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 are included in Mr. Tatum s workpapers , page 57.
The response to this request was prepared by Timothy Tatum , Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 28
REQUEST FOR PRODUCTION NO. 24 Provide monthly system retail sales
and coincident peak loads for the last 10 years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
The monthly system retail sales for the last 10 years are included with this
response in electronic format on the enclosed CD. The coincident peak loads for the
last 10 years are enclosed.
The response to this request was prepared by Timothy Tatum, Senior Pricing
Analyst , Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom , Attorney Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 29
REQUEST FOR PRODUCTION NO. 25 Provide all LOLP or other capacity risk
or load loss studies performed by or for the Company during the last 3 years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25:
The Company has not performed any LOLP studies during the last 3 years.
The response to this request was prepared by Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 30
REQUEST FOR PRODUCTION NO. 26 Provide a copy of any draft Integrated
Resource Plan for the Idaho Power Company.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26:
The requested information is enclosed.
The response to this request was prepared by Greg Said , Manager of Revenue
Requirement , Pricing and Regulatory Services Department, Idaho Power Company, in
consultation with Barton L. Kline , Senior Attorney and/or Lisa D. Nordstrom, Attorney
Idaho Power Company.
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 31
REQUEST FOR PRODUCTION NO. 27: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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27:
On July 31 2007, Idaho Power filed an objection to this request.
Subsequently, counsel for Idaho Power and for Micron discussed the information
Micron was seeking and Idaho Power was able to confirm that Micron had previously
received most of the information it had requested and would receive the balance of the
requested information upon execution of the Protective Agreement in place for this
proceeding.
The response to this request was prepared by Barton L. Kline, Senior Attorney
and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company.
:tk
DATED at Boise , Idaho, this
/q.
day of August, 2007.
(2;
BARTON L. KLINE
Attorney for Idaho Power Company
LISA D. NORDSTROM
Attorney for Idaho Power Company
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
MICRON TECHNOLOGY INC., Page 32
CERTIFICATE OF SERVICE
t'A
I HEREBY CERTIFY that on this day of August, 2007, I served a true and
correct copy of the within and foregoing document upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff
Weldon Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise , Idaho 83720-0074
Donovan Walker
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power
Peter J. Richardson , Esq.
Richardson & O'Leary
515 N. 2ih Street
O. Box 7218
Boise, Idaho 83702
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83702
Idaho Irrigation Pumpers
Association, Inc.
Eric L. Olsen
Racine, Olson , Nye, Budge & Bailey
O. Box 1391
201 E. Center
Pocatello, Idaho 83204
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Anthony Yankel
29814 Lake Road
Bay Village, OH 444140
Kroger Co. Fred Meyer and Smiths
Michael L. Ku rtz
Kurt J. Boehm
Boehm , Kurtz & Lowry
36 East Seventh Street, Suite 1510
Cincinnati , Ohio 45202
The Kroger Co.
Attn: Corporate Energy Manager (G09)
1014 Vine Street
Cincinnati , Ohio 45202
Micron Technology
Conley Ward
Michael C. Creamer
Givens Pursley
601 W. Bannock Street
O. Box 2720
Boise, Idaho 83701
Dennis E. Peseau , Ph.D.
Utility Resources , Inc.
1500 Liberty Street SE, Suite 250
Salem , OR 97302
Department of Energy
Lot Cooke
Arthur Perry Bruder
Office of the Attorney General
United States Department of Energy
1000 Independence Ave., SW
Washington , DC 20585
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Dennis Goins
Potomac Management Group
5801 Westchester Street
O. Box 30225
Alexandria, VA 22310-8225
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Dale Swan
Ammar Ansari
Exeter Associates
5565 Sterrett Place , Suite 310
Columbia, MD 20904
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Barton L. Kline
RESPONSE OF IDAHO POWER TO THE FIRST PRODUCTION REQUEST OF
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