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Home My WebLink About20070906Micron to IPC 28-41.pdfGIVE SLEY 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 Kennelh R. McClure Kelly Greene McConnell Cynthia A. Melillo Christopher H. Meyer L. Edward Miller Patrick J. Miller Judson B. Montgomery Angela K. Nelson Deborah E. Nelson W. Hugh O'Riordan, lL.M. Angela M. Reed Scott A. Tschirgi, lL.M. c:. .-\ J. Will Varin Conley E. Ward Robert B. White Terri R. Yost RETIRED Kenneth L. Pursley Raymond D. Givens James A. McClure September 6, 2007 ;:::;:.....;-'; :S:,.,n"1":'" (f) .'(5o~w. ~;;(= 3;:E (j) f"'-.Jc;:, :::\(/) ""1J 0"" 7.;:) Via Hand Delivery -'i." Jean Jewell Idaho Public Utilities Commission 472 W. Washington O. Box 83720 Boise, ill 83720-0074 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 Second Set of Discovery Requests to Idaho Power Company in connection with the above-captioned matter. If you have any questi ous, please call j S \0 ' Q d Tina M. Adometto Assistant to Conley Ward CEW Itmacc: Service List (w/enclosures) S:\CLIENTS\4489\29\TA to Jewell re 2nd Discovery Request.DOC Conley E. Ward (ISB No. 1683) Michael C. Creamer (ISB No. 4030) 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 (ill, gi venspursl ey. com HEGEI' 2!Jl)7 SEP --6 PH 4: 18 IDf\HO j:)U;:;L. f!L!TiES COM;i!!SSiO, Attorneys for Micron Technology, Inc. S:\CLIENTS\4489\29\Micron Second Prod Req.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.' SECOND 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 SECOND 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 SECOND 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 of Idaho 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 ofIdaho 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 SECOND SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 3 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 ofIdaho Power, or is no longer in existence, state whether it: (1) is missing or lost; (2) MICRON TECHNOLOGY, INC'S SECOND SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 4 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 ofpages. 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. 28. 29. 30. 31. 32. 33. DISCOVERY REQUESTS Please provide copies of all course materials, handouts, slides, handwritten, and all other notes pertaining to the referenced course "Introduction to Rate Design and Cost of Service Concepts and Techniques" (Tatum direct, Page l , Lines 16-17). Please provide the same information requested in Request 28 above pertaining to Electric Rates Advanced Course" (Tatum, direct, Page 1 , Lines 19). Please list the names and course numbers of all college courses in microeconomics identified as undergraduate or graduate, taken by Mr. Tatum Please provide copies of the "complex financial studies" and all workpapers done by Mr. Tatum "to determine revenue recovery and pricing strategies (Tatum direct, Page 2 , Lines 20-21). Please provide copies of all utility cost of service studies or cost of service testimony, including supporting documents, workpapers and written testimony or written descriptions, performed by Mr. Tatum prior to the present case. Please identify the jurisdiction and include a case citation for each such study, as well as the regulatory body s final order in each such case. Please provide the edition and publication date of the Electric Utility Cost Allocation Manual referred to as the primary guide to Mr. Tatum s classification of costs (Tatum direct, Page 5 , Lines 10-11). MICRON TECHNOLOGY, INc.'S SECOND SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 5 34. 35. 36. 37. 38. Please provide the specific citation(s) or reference(s) in the Manual supporting Mr. Tatum s decisions regarding his classification of demand and energy costs. For each reference or citation, please explain why Mr. Tatum deems it supportive of his classification methodology. Please indicate whether the NARUC Manual referenced on Page 5 of Mr. Tatum testimony was his "primary guide" for his cost allocation method cited at Page 6, Lines 6- 10. If Request 35 above is answered in the affirmative, please provide specific cites to the Manual. If Request 35 above is answered in the negative, please provide the specific references and complete copies of all reference materials Mr. Tatum relied upon to justify his cost allocation method. Please explain how the allocators referred to as "Marginal Generation Cost Weighting" in the table on Page 16 Of Mr. Tatum s direct testimony in the column entitled "Base Case Study" are actually quantitatively estimated. Please provide actual calculations and backup materials. 39.Please indicate whether, in Mr. Tatum s opinion, the reason that" ... In recent years, the Company s system peak has grown at a much faster pace than average demand" (Page , Lines 8-9) is due, in whole or in part, to an underallocation of Idaho Power generation costs to its summer peak periods and underpricing of its peak demand usage. 40.Please explain the economic logic underlying Mr. Tatum s statement that" ... there is potential to disproportionately allocate fixed base and intermediate generation costs that do not vary greatly between the summer and non-summer seasons ..." (Tatum, direct Page 14, Lines 17-21). 41.What does Mr. Tatum s cost of service marginal costs identify as the incremental cost of meeting a megawattt of additional demand in the nOll-summer months as compared to the summer months. Please explain and refer to specific cost study cites. DATED this day of September, 2007. v1/JJ! Michael C. Creamer GIVENS PURSLEY LLP Attorneys for Micron Technology, Inc. MICRON TECHNOLOGY, INC'S SECOND SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this LJ'"day of September, 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 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(cDjdahopower.com S. Mail Hand Delivered Overnight Mail Facsimile Mail John R. Gale Vice President Regulatory Affairs Idaho Power Company O. Box 70 Boise, ID 83707 email: rgale(q;,idahopower.com US. Mail Hand Delivered Overnight Mail Facsimile Mail Peter J. Richardson Richardson & O'Leary 515 N. 2ih Street Boise, ID 83702 email: peter(d;richardsonandolearv.com US. Mail Hand Delivered Overnight Mail Facsimile Mail Eric L. Olsen Racine, Olson, Nye, Budge & Bailey Chartered O. Box 1391 201 E. Center Pocatello, Idaho 83204-1391 email: rcb(2i)racinelaw.net elo(c'p,racinelaw.net US. Mail Hand Delivered Overnight Mail Facsimile Mail Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 email: yankel(c'p,attbi.com US. Mail Hand Delivered Overnight Mail Facsimile Mail MICRON TECHNOLOGY, INC'S SECOND SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 7 Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 email: dreading(il:!mindspring.com .t-- US. Mail Hand Delivered Overnight Mail Facsimile~ E-Mail Michael C. Creamer MICRON TECHNOLOGY, INc.'S SECOND SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8