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Home My WebLink About20071219IPC to ICIP 1-12.pdf15 IDA~POR(I An IDACORP Company 2ûUl DEC 18 BARTON L. KLINE Senior Attorney December 18, 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-E-07-8 General Rate Case Filing Dear Ms. Jewell: Please find enclosed an original and two (2) copies of Idaho Power Company's First Production Request to the Industrial Customers of Idaho Power 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. ve~.. uIIYY.~YOursn,¡~6 Barton L. Kline , BLK:sh Enclosure P.O. Box 70 (83707) 1221 W. Idaho St. Boise. ID 83702 I BARTON L. KLINE ISB #1526 LISA D. NORDSTROM ISB #5733 Idaho Power Company P. O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 FAX Telephone: (208) 388-6936 RECE zain DEC '8 PMli:lt 8 IDAJIO PUBLIC UT¡UllES COMMISSIOi' 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-E-07-08 ) ) IDAHO POWER COMPANY'S FIRST ) PRODUCTION REQUEST TO THE ) INDUSTRIAL CUSTOMERS OF ) IDAHO POWER ) ) COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), by and through their attorneys, and hereby requests that the Industrial Customers of Idaho Power answer the following interrogatories and provide the following information and documents in accordance with the Commission's Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. To allow the Company to utilze these responses in preparing its rebuttal testimony, it is necessary that the responses to these production requests be provided as soon as possible, but no later than December 31,2007. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - Page 1 This production request is to be deemed continuing in nature and the Industrial Customers of Idaho Power are requested to provide, through supplementation, additional documents or information that is responsive to this request that it, or any person acting on its behalf, may later come into possession or become aware of. REQUEST NO.1: Please identify the corporations, individuals and other business entities that are the members of the Industrial Customers of Idaho Power. REQUEST NO.2: From the list of the members of the ICIP provided in response to Request NO.1, please identify the members that have reviewed and approved the testimony Dr, Reading has filed in this case. REQUEST NO.3: Please provide copies of any testimony or comments Dr. Reading has prepared or submitted in the last five years in any utility regulatory proceeding which address forecasted test years, utilty cost of service computation or utility rate design including generation and transmission allocation factors. Testimony and comments on the above-referenced issues presented in proceeding in which Idaho Power Company was a party do not need to be provided. REQUEST NO.4: Please provide copies of all documents including copies of e- mail correspondence produced since December 1, 2004 in which members of the Industrial Customers of Idaho Power discuss their support or opposition to Idaho Power's industrial time-of-use rates. REQUEST NO.5: Please provide any studies, analyses, reports or other sources Dr. Reading relies upon to support his recommendation that the Company's hydro resources should be allocated 75% to capacity and 25% to energy. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - Page 2 REQUEST NO.6: Please provide all documentation and analyses that Dr. Reading relies on to support his conclusion that a 75%/25% split between capacity and energy for hydro resources is more in line with standard cost allocations as stated on page 15 of his direct testimony. REQUEST NO.7: Please describe the similarities and differences between PacifiCorp's and Idaho Power's generation resources and system operations that Dr. Reading relied upon to support his conclusion that using PacifiCorp's class cost of service allocation methodology for hydro resources is appropriate in Idaho Power's cost-of-service studies. (Reading Testimony p. 15). REQUEST NO.8: Please explain Dr. Reading's rationale for recommending a 75%/25% split between capacity and energy for hydro resources and his recommendation that the system load factor split (41.47% to capacity and 58.53% to energy) be applied to PURPA resources. REQUEST NO.9: Please clarify the rationale supporting the capacity/energy split recommended by Dr. Reading for coal-fired thermal plants and gas-fired peaking plants. REQUEST NO. 10: Please provide the spreadsheet or spreadsheets used to determine the demand and energy allocation factors used to produce the results shown on Dr. Reading's Exhibits 206, 209, 210 and 211. Please provide the spreadsheet(s) in electronic format with all formulas intact. REQUEST NO. 11: Please provide Exhibits 206, 209, 210 and 211 in electronic format with all formulas intact. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - Page 3 REQUEST NO. 12: Please provide a list by name and location of the large natural gas-consuming food processing plants located in southern Idaho that Dr. Reading represents are ideal for siting combined heat and power generation plants \Ir DATED at Boise, Idaho, this K day of December, 2007. ~1tI~ BART N L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - Page 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this JÍ day of December, 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) P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson, Esq. Richardson & O'Leary 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Don Reading Ben Johnson Associates 6070 Hil Road Boise, Idaho 83702 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen Racine, Olson, Nye, Budge & Bailey P.O. Box 1391 201 E. Center Pocatello, Idaho 83204 Anthony Yankel 29814 Lake Road Bay Vilage, OH 444140 -lHand Delivered U.S. Mail _ Overnight Mail FAX -X Email Weldon.stutzman(§puc.idaho.gov Hand Delivered -LU.S.Mail _ Overnight Mail FAX L Email peter(§richardsonandoleary.com Hand Delivered -LU.S.Mail _ Overnight Mail FAX L Email dreading(§mindspring.com Hand Delivered -LU.S.Mail _ Overnight Mail FAX L Email elo(§racinelaw.net Hand Delivered -LU.S. Mail _ Overnight Mail FAX L Email tony(§yankel.net IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - Page 5 Kroger Co. I Fred Meyer and Smiths Michael L. Kurtz 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 P.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 Routing Symbol GC-76 Dennis Goins Potomac Management Group 5801 Westchester Street P.O. Box 30225 Alexandria, VA 22310-8225 Hand Delivered -LU.S.Mail _ Overnight Mail FAX X Email mkurtz(§bkllawfirm.com kboehm (§ bkllawfirm.com Hand Delivered -LU.S. Mail _ Overnight Mail FAX Email Hand Delivered -LU.S. Mail _ Overnight Mail FAX i Email cew(§givenspursley.com mcc (§ givenspursley.com Hand Delivered -LU.S.Mail _ Overnight Mail FAX -X Email dpeseau(§excite.com Hand Delivered U.S. Mail -l Overnight Mail FAX -X Email lot.cooke(§hg.doe.gov arthur.bruder(§ hg.doe.gov Hand Delivered -LU.S.Mail _ Overnight Mail FAX X Email DGoinsPMG(§cox.net IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - Page 6 Dale Swan Exeter Associates 5565 Sterrett Place, Suite 310 Columbia, MD 20904 Hand Delivered l-U.S.Mail _ Overnight Mail FAX X Email dswan(gexeterassociates.com aansari (g exeterassociates.com Barto~~ IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - Page 7