20080710ICIP to IPC 1-10.pdf

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Peter Richardson
Tel: [phone] Fax: [phone]
p eter~ richardson andoleary. co m
P.O. Box 7218 Boise, lD 83707 - 515 N. 27th St. Boise, lD 83702
9 July 2008
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, 1083702
RE: IPC-E-08-10
Dear Ms. Jewell:
We are enclosing an three copies of the FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, in the above case.
The original has been served on Idaho Power Company.
Sincerely,~
Richardson & O'Leary PLLC
.,
.,"
Peter J. Richardson ISB # 3195
RICHASON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~chardsonandolear.com
Attorneys for the Industral Customers of Idao Power
01
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE
, APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AN CHAGES
FOR ELECTRC SERVICE.
) CASE NO. IPC-E-oS-IO
)
) FIRST PRODUCTION REQUEST OF
) THE INUSTIAL CUSTOMERS OF
) IDAHO POWER
)
Pursuat to Rule 225 of the Rules of Procedure of the Idaho Public Utilties Commssion
(the "Commssion"), The Industral Customers of Idaho Power ("ICIP") by and though their
attrney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Compay") provide the following documents.
This production request is to be considered as contiuing, and the Company is requested
to provide by way of supplementa responses additional documents tht it or any person acting
on its behalf may later obta that will augment the documents produced.
Pleas provide one physical copy and one electonic copy, if available, of your anwer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unvailable a physical copy, to Dr. Don Readig, at:
6070 Hil Road
Boise, Idaho 83703
[phone] Tel
FIRST PRODUCTION REQUEST OF ICIP - IPC-E-QS-l 0
-,,"
[phone] Fax
dreadig(gindspring.com
For each item, pleae indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearg who can sponsor the answer.
REOUEST FOR PRODUCTION NO.1:
Please provide a copy for each of the thee (3) cost of servce studies presented in Mr.
Tatu's'Direct Testimony in electronic format, CD-ROM with instrctions on how to use them.
REQUEST FQR PRODUCTION NO.2:
Please provide Mr. Tatu's Exhbits No. 59 and Exhbits No. 68 in electronic format
with instctions on how to use each.
REQUEST FOR PRODUCTION NO.3
The Company's April 22, 2008 Marginal Cost Analysis, provided in Mr. Tatu's
workpapers states, "The 2008 test year gas prices were used, adjusted for each of the year using
the Utility Natual Gas Index from the Global Insight 30-year US Economic Outlook, Febru
2008." Pleae provide the 2008 test year gas prices used in the 2008 Marginal Cost Analysis and
show the adjustment used for each year.
REQUEST FOR PRODUCTION NO.4
Ms. Nemnch on page 3 of her direct testimony detaling the proposed rate design for
industral and commercial customers states: "I gathered customer input on proposed rate design
chages durg a meeting held on May 8, 2008, that included several of the Company's Large
General Servce customers. A sumar of ths meeting is included later in my testimony."
Please provide the full details of ths meeting includig: paricipants, maters discussed,
FIRT PRODUCTION REQUEST OF ICIP - IPC-E-OS-IO
2
.,
documents distrbuted or received, a ful description of the topics discussed, and a detaled
explanation of how any information gained though ths meeting inuenced the proposed rate
design.
REQUEST FOR PRODUCTION NO.5
Please detal the allocation to schedule 19 customers of the transmission and distrbution
costs associated with the company's combustion tubine generation facilties.
REQUEST FOR PRODUCTION NO.6.
Mr. Lamont Keen, on page 6, lines 11-13 of his direct testimony states "we have
experienced an increase in average anual energy usage by residential customers in four or the
last five years". Please provide the average anua usage of electrcity for each customer class for
the previous five years.
REQUEST FOR PRODUCTION NO.7.
Ms. Smith's direct testimony includes Exhbit 33 which detals the varous methodologies
used to convert the 2007 actual date to the 2008 test year data. Please provide a detailed
accounting which compares the 2008 test year data with the actu 2008 data collected though
Julyl, 2008 for any line item identified in Exhbit 33 which utilizes the 3 year compounded, 5
year compounded, or normalized methodologies.
REQUEST FOR PRODUCTION NO.8.
In argug for the use of the 2008 test year Mr. Gale refers to the Company's experence
with the forecast component of the PCA mechansm on page 15, lines 1-6 of his diect testimony.
Please provide a detaled analysis that compares the forecasted component of the PCA with the
actul data found for the years 2000-2007
REQUEST FOR PRODUCTION NO.9.
FIRST PRODUCTION REQUEST OF ICIP ~ IPC-E-OS-l 0
3
..,
Ms. Drake, on page 4, lines 2-7 refers to the Company's Demand-Side Management 2007
Anua Report which covers all demand response programs. Please provide ths report along
with any and alI documents, reports, studies, data, or analysis used in developing this report.
REQUEST FOR PRODUCITON NO 10.
Please provide any and all documents, reports, studies, data, or analysis used in the all
aspects of the Company's investigation of the Virt Peaker Program.
DATED ths 1 th day of July 2008.
RICHASON & O'LEARY PLLC
..
By: fJ¿/ft
Peter J. Richardson, ISB #3195
Attorneys THE INDUSTRL
CUSTOMERS OF IDAHO POWER
FIRST PRODUCTION REQUEST OF ICIP - IPC-E-08.10
4
1
CERTIFICATE OF SERVICE
I HEREBY CERTIFY tht on the 9th day of July, 2008, a tre and correct copy of the
with and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRAL CUSTOMERS
OF IDAHO POWER, was served in the maner shown to:
Ms. Jean Jewell
Comnsion Seceta
Idao Public Utilities Comnsion
POBox83720
Boise ID 83720-0074
_ Hand Delivery
.A U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
JohnR. Gale
Vice President, Regulatory Affairs
Idao Power Company
PO Box 70
Boise, Idao 83707-0070 .
_ Hand Delivery
XU.S. Mail, postae pre-paid
Facsimle
Electronic Mail
Baron L. Kline
Senior Reguatory Attorney
Idaho Power Company
PO Box 70
Boise, Idao 83707.0070
_ Hand Delivery
X U.S. Mail, postae pre-paid
Facsimle
Electronic Mail
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chrd.
PO Box 1391
Pocatello, Idao 83204-1391
_ Hand Delivery
-XU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
_ Hand Delivery
X U.S. Mail, postae pre-paid
Facsimle
Electronic Mail
Qj~w-T
Nina Curis
Admstrative Assistat