20070904DOE to IPC 2-1, 2-2.pdf

The Secretary of Energy
Washington, DC 20585
RECEiVED
August 27,2007
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Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington St.
O. Box 83720
Boise, Idaho 83720-0074
RE: Case No. IPC-O7-
Dear Ms. Jewell:
Enclosed for fIling please find the original and three (3) copies of the United States
Department of Energy s second data request to Idaho Power Company.
Thank you for your assistance.
Sincerely,
~- ~-
Arthur Perry Bruder
Attorney for the
United States Department of Energy
1000 Independence Ave. SW
Washington, D.C. 20585
arthur. bruder~hq .doe.gov
[phone]
cc: service list
LOT COOKE
ARTHUR PERRY BRUDER
OFFICE OF THE GENERAL COUNSEL
UNITED STATES DEPARTMENT OF ENERGY
1000 INDEPENDENCE AVE. SW
WASHINGTON, DC 20585
[phone]
Attorneys for the United States Department of Energy
lot.cooke~hq .doe.gov
arthur. bruder~hq .doe.gov
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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 ID~O.
CASE NO. IPC-07-
SECOND 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 attorneys of
record, Lot Cooke and Arthur Perry Bruder, requests that Idaho Power Company
(Company; IPC) provide the following as soon as possible, but no later than September
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 therequested 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 portion(s) 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 areattached to documents that are responsive to that request, and constitute routingslips, transmittal memoranda, letters, comments, evaluations, or similar materials;
as part of each response, provide the name(s) and title(s) of the person(s) whoprepared 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.modelsanalyses, databases, formulas) which is stored in machine-readable form, inaddition to providing hard copy, furnish the machine-readable information, onCD-ROM for IBM compatible PC for large files, as:
(i)
(ii)
Excel worksheet files;
ASCII text files; or
(iii)other IBM PC compatible worksheet or database files.
11.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 2-Referring to test-year costs assigned to Account 555 - Purchased Power:
(a) Please explain in detail how Idaho Power classified Account 555.1costs.
(b) Please state and explain in detail the justification for Idaho Power
classification of Account 555.1 costs.
(c) Please explain in detail how Idaho Power classified Account 555.
costs.
(d) Please state and explain in detail the justification for Idaho Power
classification of Account 555.2 costs.
( e) Please identify and explain in detail all factors that Idaho Powerconsiders in making an Account 555.1 purchase.
(f) Please explain in detail how Idaho Power forecasts Account 555.purchases.
(g) Please explain in detail how Idaho Power incorporates and/or reflects
Account 555.1 purchases in its plans and procedures to serve its Idaho
retail load reliably.
DOE 2-Referring to test-year costs assigned to Account 555., please provide inExcel format a chart showing, for each purchase comprising the Account
555.1 costs, the following: transaction date, duration, type (for examplefirm energy), total capacity and/or energy purchased, total cost, applicablepricing mechanism ($/MW, $/MWh, or some combination), and specific
prIces.
DATED at Washington, D.
this twenty-seventh day of August, 2007.
Arthur Perry Bruder
Attorney for the
United States Department of Energy
CERTIFICATE OF SERVICE
I hereby certify that on this 27th 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 US. 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 S. Mail and email
ID~O POWER COMPANY
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID 83707
email: bklineClVJdahopower.com
via Us. Mail and email
John R. Gale
Vice President Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, ID 83707
email: rgale~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 US. 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
20 I E. Center
Pocatello, Idaho 83204-1391
email: elo~racinelaw.net
via us. mail and email
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
email: tony~yanke1.net
via email
KROGER
Kurt 1. Boehm
Michael L. Kurtz
Boehm, Kurtz & Lowry
36 East Seventh Street, Suite 510
Cincinnati, OHIO 45202
mkurtz~bklla wfirm. com
kboehm~bkllawfirm.com
via US. Mail and email
The Kroger Company
Att': Corporate Energy Manager (G09)
1014 Vine Street
Cincinnati, OHIO 45202
via US. 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 us. mail and email
Dennis E. Peseau, Ph.
Utility R4esources Inc.
1500 Liberty St. SE Suite 250
Salem, OR 97302
dpeseau~excite.com
via email
Arthur Perry ruder
Attorney for the
United States Department of Energy
arth ur bruder~hq.doe.gov
office: (202 586-3409fax: [phone]