20080820Staff to IPC 1-15.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
II: 39
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 ITS )
CUSTOMERS IN THE STATE OF IDAHO. )
)
)
)
CASE NO. IPC-E-08-10
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, SEPTEMBER 10, 2008.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 AUGUST 20, 2008
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number ofthe record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.1: Please provide actual service levels for the Customer Service Center
attined by month beginning with July 2007 through July 2008. Please provide the service levels
separately for ACD and IVRU calls.
REQUEST NO.2: Please provide by month beginning with July of 2007 and through
July of2008, the number of incoming calls handled by the Company's Customer Service Center.
Please separately identify the total numbers of calls routed through the ACD, and the self-help
calls handled through the IVRU.
REQUEST NO.3: Please provide the total number of e-mails received by the Customer
Webmail group by month from July of 2007 and through July of 2008. Include the average
response time to e-mails for each of those months.
REQUEST NO.4: Please provide electric and natural gas forward prices for 2009
contract months as reported daily for all settlement dates beginning Januar 1,2007, through the
present for each of the trading hubs for which Idaho Power regularly trades or considers in its
analysis. Please provide the data in an electronic Excel format on CD with formulas activated.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 AUGUST 20, 2008
REQUEST NO.5: Please provide, in an electronic executable Excel format, the natual
gas price data used by Idaho Power in the AURORA modeL. Cite the source of the data and the
date on which it was released or prepared. Provide any fies used by Idaho Power to prepare,
analyze, adjust, shape, or modify the data for use in the AURORA modeL. Please provide a brief
description of any analysis, adjustment, shaping or modification of the data.
REQUEST NO.6: Please provide all data and analysis used to derive the natural gas
basis differentials used by Idaho Power in its AURORA modeling.
REQUEST NO.7: Please compare the 2009 normalized system load forecast for Idaho
Power as used in the AURORA model to the 2008 and the 2007 weather-normalized load
forecasts. Please provide the forecasts and comparisons in an electronic executable Excel format.
Please provide the forecasts in whatever time increments were used originally in preparing the
forecasts, e.g., monthly, daily or hourly.
REQUEST NO.8: Please provide a brief summary of all specific changes made to the
input data and assumptions used in AURORA since Idaho Power's last general rate case (Case
No. IPC-E-07-8).
REQUEST NO.9: On page 9, lines 4-8 of Greg Said's testimony in Case No. IPC-E-07-
8 (Idaho Power's previous general rate case), he states "Once the Commission makes a
determination as to the appropriate quantification of wind integration costs, the Company wil
include a wind integration cost adjustment to variable power supply expense determinations in
future rate cases." Please identify and describe any wind integration cost adjustments made in the
curent general rate case.
REQUEST NO. 10: On page 9, line 9 through page 10, line 15 of Greg Said's testimony,
he discusses the range of modeled market prices for both purchased power and surlus sales for
the curent case and for the Company's previous rate case. What is the range of prices actually
paid and received by Idaho Power during 2007 and 2008 for purchased power and surplus sales?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 AUGUST 20, 2008
REQUEST NO. 11: Please provide documentation and/or workpapers showing the basis
for the coal prices used in power supply modeling for Bridger, Valmy and Boardman (e.g., copy
of contracts, sources for price inflators, etc.).
REQUEST NO. 12: Please provide a list ofPURPA projects with signed contracts with
Idaho Power that have yet to come online. Please provide an estimated online date for each
project.
REQUEST NO. 13: Please provide documentation (e.g., copy of the contract showing
cost and fixed capacity by month) of the fixed gas transportation capacity charge assumed in the
AURORA analysis. Greg Said's Exhibit 47, pages 1-81 show fixed gas transporttion capacity
charges for Danskin but not for Bennett Mountain. Are the gas transportation charges for both
plants incorporated in the line entry for Danskin?
REQUEST NO. 14: What gas transportation capacity is necessary in order to operate
each of the Danskin plants and the Bennett Mountain plant at full capacity? Is enough gas
transportation capacity purchased to run all of the plants at full capacity in every month of the
year? In months when none or not all of the gas transporttion capacity is expected to be needed,
is any capacity sold? Can it be sold? Can gas transportation capacity be purchased on a spot
market? Can it be purchased for only specific months or must it be purchased for a full year?
REQUEST NO. 15: Please provide an analysis of fire damage repair costs for 1998,
1999,2000,2001, and 2002. For each year provide a list of the major fires, and for each fire
provide total expense incured, labor costs, number of poles repaired/replaced including cost, and
wire-feet replaced including cost. Include schedules showing the dates, amounts, vendors,
explanations and accounts used.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 AUGUST 20, 2008
DATED at Boise, Idaho, this ~~ay of August 2008.
Technical Staff: Marilyn Parker/I-3
Rick Sterling/4 - 14
Cecily VaughnIS
i:umisc:prodreq/ipceOS.l Owsnpmprpscv prod req 1
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
¡0'Nce
Deputy Attorney General
5
..
AUGUST 20, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DA Y OF AUGUST 2008,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-10, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bklineCfidahopower.com
lnordstromCfidahopower .com
dwalkerCfidahopower .com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peterCfrichardsonandoleary.com
RANDALL C BUDGE
ERICLOLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(iracinelaw.net
eloCfracinelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurz(iBKLlawfrm.com
kboehmCfBKLlawfirm.com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(ihotmail.com
JOHNRGALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale(iidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(imindspring.com
ANTHONY YANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E-MAIL: yanel(iattbi.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT 84111
E-MAIL: khigginsCfenergystrat.com
LOTH COOKE
ARTHUR PERRY BRUDER
UNITED STATE DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: lot.cooke(ihq.doe.gov
arhur. bruderCfhq .doe. gov
CERTIFICATE OF SERVICE
DWIGHT ETHERIDGE
EXETER ASSOCIATES INC
5565 STERRTT PLACE, SUITE 310
COLUMBIA MD 21044
E-MAIL: detheridge(iexeterassociates.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
1500 LIBERTY STREET SE, SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(iexcite.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANOCK ST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cewCfgivenspursley.com
KEN MILLER
CLEAN ENERGY PROGRA DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmilerCfsnakeriverallance.org
~~.Koc
SECRETARY
CERTIFICATE OF SERVICE