20070823Kroger to IPC 1-15.pdf

BOEHM, KURTZ & LOWRY
ATIORNEYS AT LAW
36 EAST SEVENTH STREET
SUITE 1510
CINCINNATI. OHIO 45202
TELEPHONE [phone]
TELECOPIER [phone] RECEIVED
ZilUl AUG 23 \ A 10: Ob
UT \i!rt;g;j:;d~ji;~\~SION
VIA OVERNIGHT MAIL
August 22, 2007
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720
In re: Case No. IPC-O7-
Dear Ms. Jewell:
Enclosed please find the original and seven (7) copies of the FIRST SET OF DATA
REQUESTS OF THE KROGER CO. dba FRED MEYER AND SMITH'S TO IDAHO POWER
COMPANY to be filed in the above referenced matter.
Copies have been served on all parties on the attached certificate of service. Please place
this document of file.
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
BOEHM, KURTZ & LOWRY
MLKkew
Ene!.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION RE GE IVED
In The Matter Of The Application Of Idaho Power
Company For AuthorityTo Increase Its Rates And
Charges For Electric Service To Electric Customers In
The State Of Idaho
ZOQl AUG 23 'J.10: Db
Case No. IPC-07-
j iJ/,,:.C) PLJ3LiC
UTILITIES COMI\/jjSSiON
FIRST SET OF DATA REQUESTS FROM KROGER
TO IDAHO POWER CO.
Federal Income Tax - Please identify the actual amount of Domestic Production Activities
DPA") deduction, introduced as part of the American Jobs Creation Act of 2004 and effective
for taxable years beginning in 2005 , attributable to Idaho Power in 2006 for both the Total
Electric System and Idaho jurisdiction, and the amount by which this deduction reduced IPC'
actual Federal income tax liability of Idaho Power for that year.
Federal Income Tax - Does the 2006 Actual Federal Income Tax entry of $36 271 487 shown in
Column 1 , Line 13 on page 2 of2 of Exhibit No. 20 include the effects of the DPA deduction? If
not, please explain why not. If so, please provide a workpaper detailing the derivation and
incorporation of this deduction in the determination of the federal income tax expense as shown
on Exhibit 28.
Federal Income Tax - Does the 2007 Forecast Federal Income Tax entry of $31 386 045 shown
in Column 2, Line 13 on page 2 of2 of Exhibit No. 20 include the effects of the DPA deduction?
If not, please explain why not. If so, please provide a workpaper detailing the derivation and
incorporation of this deduction in the determination of the federal income tax expense as shown
on Exhibit 28.
Federal Income Tax - Does the 2007 Test Year Federal Income Tax entry of $46 055 852
shown in Column 6, Line 13 on page 2 of 2 of Exhibit No. 20 include the effects of the DP
deduction? If not, please explain why not. If so, please provide a workpaper detailing the
derivation and incorporation of this deduction in the determination of the federal income tax
expense as shown on Exhibit 28.
Federal Income Tax - Does the 2007 Idaho Test Year Federal Income Tax entry of$46 753 611
shown in Line 21 on page 1 of 36 of Exhibit No. 29 include the effects of the DP A deduction? If
not, please explain why not. If so, please provide a workpaper detailing the derivation and
G:\WORKIMLK\KROGER\IDAHOIIPC-O7-08\lst Data Requests.doc
10.
incorporation of this deduction in the determination of the federal income tax expense as shown
in Table 10 on page 21 of36 of Exhibit 29.
Federal Income Tax - Does the 2007 Idaho Test Year Net-to-Gross Tax Multiplier of 1.642
shown in Line 35 on page 1 of 36 of Exhibit No. 29 include the effects ofthe DP A deduction? If
not, please explain why not. If so, please provide a workpaperdetailing the derivation and
incorporation of this deduction in the determination of the net-to-gross tax multiplier.
Federal Income Tax - Has Idaho Power reflected the effects of the DP A deduction anywhere in
its Idaho jurisdictional revenue requirement calculation? If not, please explain why not. If so
please identify the exhibit(s) including this deduction and its supporting derivation.
Federal Income Tax - If not included in Idaho Power s direct filing, please estimate the amount
of Domestic Production Activities ("DP A") deduction attributable to Idaho Power s Idaho
jurisdiction for the 2006 Actual, 2007 Forecast, and 2007 Test Year periods (including the test
year revenue deficiency determination), and the amount by which this deduction would reduce
the Federal income tax liability determined by Idaho Power for each period. Please provide
workpapers with formulas intact supporting the derivation of these amounts.
Federal Income Tax - For ratemaking purposes, please confirm that in its revenue requirement
calculation Idaho Power determines its Federal Income Tax expense ($46 753 611 shown on
page 1 of36, Line 21 of Exhibit 29 and the 1.642 Net-to-Gross tax Multiplier on page 1 of36
Line 35 of Exhibit 29) using a hypothetical 35% federal tax rate for the Idaho jurisdiction on a
stand-alone basis.
Please provide the class average load factor for Schedules 9-, 9-, 19-, 19-, and 19-T for the
2007 test year period.
Rate design - Assume Idaho Power s proposed rate design for Rates 9-P/T and 19-P/T were
adopted and further assume that multiple account customers with total load on Rate 9-P/T in
excess of 1 MW were given the option to change their individual9-PIT accounts to Rate 19-P/T
(to enable them to participate in TOU rates): (a) What is Idaho Power s estimate ofthe number
of accounts that would migrate? (b) What is Idaho Power s estimate ofthe kWh and kW billing
demand (by season and TOU) that would migrate? (c) What is Idaho Power s estimate ofthe
revenue impact from the migration?
11.
12.Rate design - Assume Idaho Power s proposed rate design for Rates 9-PIT and 19-P/T were
adopted and further assume that multiple account customers with total load on Rate 9-P/T in
excess of 5 MW were given the option to change their individual9-P/T accounts to Rate 19-P/T
(to enable them to participate in TOU rates): (a) What is Idaho Power s estimate of the number
of accounts that would migrate? (b) What is Idaho Power s estimate of the kWh and kW billing
demand (by season and TOU) that would migrate? (c) What is Idaho Power s estimate of the
revenue impact from the migration?
Rate design - Assume Idaho Power s proposed overall revenue requirement for Rates 9-P/T and
19-P/T were adopted and Rates 9-P/T and 19-P/T were merged using Rate 19-P/T's TOU rate
design. What is Idaho Power s estimate of the kWh and kW billing demand (by season and
TOU) that would result from the new merged rate?
Rate design - Assume Idaho Power s proposed overall revenue requirement for Rates 9-P/T and
19-P/T were adopted and Rates 9-P/T and 19-P/T were merged using 19-P/T's TOU rate design
for Rate 9-P/T customers with billings demands greater than 500 kW. (a) What is Idaho Power
13.
14.
- 2-
15.
estimate of the number of Rate 9-P/T accounts that would move to Rate 19-P/T? (b) What is
Idaho Power s estimate of the kWh and kW billing demand (by season and TOU) that would
move from Rate 9-P/T to Rate 19-PIT?
Rate design - What is Idaho Power s opinion of the reasonableness of each of the rate design
options presented in 2.11 through 2., if the Idaho Power Company was held harmless from the
revenue impact from migration?
JZJ;~
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Ph: 513-421-2255 Fax: [phone]
E-mail: mkurtz~BKLlawfirm.com
kboehm~BKLlawfirm.com
- 3 -
CERTIFICATE OF SERVICE
I hereby certify that true copy of the foregoing was served by electronic mail, unless otherwise noted, this
ND Day of August, 2007 to the following:
Barton L. Kline
Lisa D. Nordstrom
Idaho Power Company
1221 W. Idaho St. (83702)
PO Box 70
Boise, ID 83707-0070
Email: bkline~idahopower.com
N ordstrom~idahopower .com
Eric L. Olsen
Racine, Olson, Nye, Budge
& Bailey, Chartered
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
Email: elo~racinelaw.net
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
1221 W. Idaho St. (83702)
PO Box 70
Boise, ID 83707-0070
Email: rgale~.idahopower.com
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Email: tonv0)vankel.net
Weldon Stutzman
Donovan Walker
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ill 83720-0074
Email: weldon.stutzman~puc.idaho.gov
donovan. walker~puc.idaho. gov
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
601 W. Bannock Street
PO Box 2720
Boise, ID 83701-2720
Email: cew~,givenspurslev.com
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street, Suite 250
Salem, OR 97302
Email: dpeseau~excite.com
Peter J. Richardson, Esq.
Richardson & O'Leary
515 N. 27th Street
PO Box 7218
Boise, ID 83702
Email: peter~richardsonandoleary.com
Lot H. Cooke
Acting Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW Washington
DC 20585 Telephone: [phone]
Email: lot.cooke~hq.doe.gov
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
Email: dreading~mindspring.com
Dale Swan
Exeter Associates, Inc.
5565 Sterrett Place
Suite 310
Columbia, MD 21044
Email: dswan~exeterassociates.com
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Electronic Couies Onlv:
Dennis Goins
Email: dgoinspmg~cox.net
Arthur Perry Bruder
Email: arthur.bruder~hq.doe.gov
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
G:\WORKIMLK\KROGER\IDAHOIIPC-O7-08\Commission Itr (ldaho).doc