20080911DOE to IPC 1-1 through 1-28.pdf

Department of Energy
Washington, DC 20585 RECE1VEO
.SE -8 1118;26
IDAHO. PUBLiC
UTILlTlES CPMMISSlON
September 3, 2008
RE: Idaho Public Utilities Commission Case No. IPC-E-08-10
United States Department of Energy's First Interrogatories
and Production Requests to Idaho Power Company
TO THE PARTIES:
Enclosed are the United States Department of Energy's First Interrogatories and
Production Requests to Idaho Power Company.
Thank you for your kind attention.
Very truly yours,~GL~_LArthur Perry BtJder
Attorney for the
United States Department of Energy
phone: [phone]
fax: [phone]
arthur.bruder~hq.doe.gov
"
I) Printed with soy ink on recycled paper
IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
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. )
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BEFORE THE IDAHO PUBLIC UTILITIES COMMI~~M .'1 '9 ~b
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~04'CASE NO. IPC-E-08-10
U.S DOE's First Interrogatories
and Production Requests
to Idaho Power Company
The United States Departent of Energy, by and through its attorney of record,
Arhur Perr Bruder, hereby requests that Idaho Power Company ("the Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, SEPTEMBER 24, 2008.
As per the Commission's Rules of Procedure, responses must include the name(s)
and phone number of the person(s) who prepared the document, and the name(s), job
title(s), location(s) and phone number(s) of the recordholder(s) and, if different, the
witness( es) who can sponsor the answer at hearng if need be.
These Interrogatories and Production Requests are to be considered as continuing,
and the Company is requested to provide, by way of supplementar responses, additional
documents that it or any person acting on its behalf may later obtain that constitute
relevant augmentation of the documents produced.
Please provide ariswers 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 preparng the documents.
Please provide all Excel and electronic fies on CD with formulas activated. .
1
IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-I-I.
DOE-I-2.
DOE-I-3.
DOE-I-4.
DOE-I-5.
Please provide copies of all responses to requests for information
submitted by other paries to Idaho Power in this docket. This is an
ongoing request.
Please provide Exhibit Nos. 36-80 in native format (e.g., Excel, Word)
with all link and formulas intact (if applicable).
Please provide all workpapers in native format (e.g., Excel, Word) with all
link and formulas intact (if applicable) that underlie and/or support
Exhibit Nos. 36-80.
Referrng to the direct testimony of Timothy Tatu at 21:24 - 22:9:
(a) Does Idaho Power have three distinct time-based production costing
periods that are drven by customer loads? If the answer is yes, please
provide all workpapersi studies, analyses, and documents supporting
and/or underlying the identification and delineation of the costing
periods.
(b) For the base production costing period, please specify by month the
daily hours that define the costing period.
(c) For the intermediate production costing period, please specify by
month the daily hours that define the costing period.
(c) For the peak production costing period, please specify by month the
daily hours that define the costig period.
For each of IPC's production resources assigned to Accounts 340-346,
please provide in Excel format with all formulas and links intact the
following by month for the past 36 months:
(a) Name, in-service date, and nameplate or rated capacity.
(b) Total hours of operation durng each of IPC's base, intermediate, and
peak production costing periods.
. (c) MWh of energy supplied durng each of IPC' s base, intermediate, and
peak production costing periods.
(d) Total operating costs durng each of IPC's base, intermediate, and
peak production costing periods.
(e) All workpapers underlying and/or supporting these responses.
2
IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-I-6.
DOE-I-7.
DOE-I-8.
For each of IPC's production resources assigned to Accounts 310-316,
please provide in Excel format with all formulas and links intact the
following by month for the past 36 months:
(a) Name, in-service date, and nameplate or rated capacity.
(b) Total hours of operation during each ofIPC's base, intermediate, and
peak production costing periods.
(c) MWh of energy supplied durng each of IPC' s base, intermediate, and
peak production costing periods.
(d) Total operating costs durng each of IPC's base, intermediate, and
peak production costing periods.
(e) All workpapers underlying and/or supporting these responses.
For each of IPC's production resources assigned to Accounts 330-336,
please provide in Excel format with all formulas and links intact the
following by month for the past 36 months:
(a) Name, in-service date, and nameplate or rated capacity.
(b) Total hours of operation durng each ofIPC's base, intermediate, and
peak production costing periods.
(c) MWh of energy supplied durng each ofIPC's basei intermediate, and
peak production costing periods.
(d) Total operating costs durng each of IPC's base, intermediate, and
peak production costing periods.
(e) All workpapers underlying and/or supportng these responses.
For each purchase whose cost is booked to Account 555.1, please provide
in Excel format with all formulas and links intact the following by month
for the past 36 months:
(a) Transaction date, duration, tye (for example, firm energy), total
capacity and/or energy purchased, total cost, applicable pricing
mechanism ($/M, $/MWh, or some combination), and specific
pnces.
(b) Total hours of purchase durng each of IPC's base, intermediate, and
peak production costing periods.
3
IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMTION AND PRODUCTION OF DOCUMENTS
(c) MWh of energy purchased (if applicable) durng each of IPC's base,
intermediate, and peak production costing periods.
(d) Total purchase costs durng each of IPC's base, intermediate, and
peak production costing periods.
(e) All workpapers underlying and/or supporting these responses.
DOE-I-9.For each purchase whose cost is booked to Account 555.2, please provide
in Excel format with all formulas and links intact the following by month
for the past 36 months:
(a) Transaction date, duration, tye (for example, fi energy), total
capacity and/or energy purchased, total cost, applicable pricing
mechanism ($/MW, $/MWh, or some combination), and specific
pnces.
(b) Total hours of purchase durng each of IPC's base, intermediate, and
peak production costing periods.
(c) MWh of energy purchased (if applicable) durng each of IPC's base,
intermediate, and peak production costing periods.
(d) Total purchase costs durg each of IPC's base, intermediate, and
peak production costing periods.
(e) All workpapers underlying and/or supporting these responses.
DOE-I-I0. Referrng to the direct testimony of Timothy Tatum at 40:10-11:
(a) Please provide in Excel format with all formulas and link intact the
2008 marginal cost analysis.
(b) Please provide all workpapers underlying and/or supporting the
marginal cost analysis.
DOE-l- i 1. Please provide in native format (e.g., Word) the direct testimony of all
Idaho Power witnesses.
DOE 1-12. Referrng to Exhibit No. 53 at 36:258:
(a) Please define and explain in detail "Adjustment to Revenue/Refuds."
(b) Please provide the justification for IPC' s functionalization and
classification of these revenues.
4
IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMTION AN PRODUCTION OF DOCUMENTS
DOE 1-13. Referrng to Exhibit No. 53 at 36:260:
(a) Please provide the justification for IPC's classification of Account
447 revenues.
(b) Please provide in Excel format Account 447 Opportnity Sales by
month for the past 36 months showing for each transaction the total
kWh sold, total revenue received, and whether the transaction was
priced using a one- or multi-par rate.
DOE 1-14. Referrng to the direct testimony of Timothy Tatum at 55:5-7 and the
adverb currently used to introduce this sentence, does IPC plan to expand
the coverage of the FCA to classes other than Residential and Small
General Service? If the response to this question is other than an
unqualified yes, please describe in detail IPC's plans to expand the FCA
and any discussions that IPC has had in the past 12 months with any par
in this case regarding the possible expansion of the FCA.
DOE 1-15. Provide copies of all Idaho Power credit rating reports since Januar 1,
2007.
DOE 1-16. Providè copies of all presentations to securties analysts by management
for Idaho Power or IdaCorp since Januar 1, 2008.
DOE 1-17. Please identify the specific weights given to the varous cost of equity
studies in Dr. Avera's testimony. In particular, please indicate the relative
weight given to his electrc utility DCF study as opposed to his other cost
of equity studies, in formulating his recommended range.
DOE I -18. Does Dr. Avera intend to submit a cost of equity update in this case? If so,
please state when.
DOE 1-19. Has Dr. Avera previously submitted cost of equity testimony for Idaho
Power using a West Region electrc utility proxy group? If so:
(a) Please state the last case (year, docket number) when he did so;
(b) The companies comprising that Proxy Group; and
.
(c) The reason for changing his practice to a national proxy group.
DOE 1-20. Please specify the exact criteria used by Dr. Avera for eliminating proxy
company DCF cost of equity results as being either too high or too low.
DOE 1-21. Please specify all reasons why Dr. Avera selected Value Line as the source
of the "beta" instead of using other publically-available sources. of beta.
5
IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE 1-22. Please list all public common stock issues durng the last three years by
IdaCorp. In each case, please include:
(a) Date of issuance;
(b) Net proceeds; and
(c) Expenses associated with issuance (including underwting fees).
DOE 1-23. Please describe any plans for a public stock issuance within the next three
years for IdaCorp.
DOE 1-24. Provide all securties research analyst reports concerning Idaho Power or
IdaCorp in the Company's possession (and not already provided in this
case) issued since January 1,2008.
DOE 1-25. Per Mr. Keen, pages 28-29, please identify the dollar amounts of debt
obligation S&P and Moody's presently impute to Idaho Power for its 10ng-
term purchase power contracts for credit rating puroses.
DOE 1-26. Please provide the American Falls and Milner debt balances at June 30,
2008. (S. Keen, page 38).
DOE 1-27. Please identify any plans by Mr. Keen to update the year-end 2008
projected capital strctue and cost of debt. As par of the response please
indicate when the issuance of the $125 milion debt issuance and the
refinancings of the Sweetwater and Humboldt auction bonds are likely to
take place.
DOE 1-28. Please provide the Company's actual capital strctue (excluding
American Falls and Milner debt) at June 30, 2006.
At Washington, D.C., this 3d day of September, 2008.
Arhur Perr Bruder
Attorney for the United States
Deparent of Energy
Phone: [phone]
Fax: [phone]
Arhur.Bruder~hq.doe.gov
(motion for pro hac vice admission to the
Idaho Bar for this proceeding is pending)
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IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMTION AND PRODUCTION OF DOCUMENTS
CERTIFICATE OF SERVICE
i hereby certify that, this 3d day of September, 2008, I served the foregoing first
production request of the United States Departent of Energy to Idaho Power Company"
in case No. IPC-. 08- 10, by emailingit.andbymailingacopyofit.(postageprepaid).to
the following:
Baron L Kline
Lisa D Nordstrom
Donovan E Walker
Idaho Power Company
PO Box 70
Boise, Id 83707-0070
email: bkline(!idahopower.com
Inordstrom(!idahopower.com
dwalker(!idahopower.com
John R. Gale
VP ~ Regulatory Affairs
Idaho Power Company
POBox 70
Boise, il 83707-0070
email:rgale(!idahopower.com
Weldon B. Stutzman
Neil Price
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington St.
PO Box 83720
Boise, Idaho 83720-0074
Peter J Richardson
Richardson & O'Lear
PO Box 7218
Boise, il 83702
email: peter(!richardsonandolear.com
Randall C Budge
Eric L Olsen
Racine Olson Nye
PO Box 1391
Pocatello, il 83204- 1391
email: rcb(!racinelaw.net
elo(!racinelaw.net
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IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
Michael L Kurtz, Esq.
Kur J Boehm, Esq.
Boehm Kurz & Lowry
36 E Seventh St. Ste 1510
Cincinnati, OH 45202
email: rnz~BKLlawfirm.com
kboehm~BKLlawfirm.com
Brad M. Purdy, Esq.
2019 N. 17th St.
Boise, il 83702
email: bmpurdy~hotmaii.com
Dr. Don Reading
6070 Hill Rd.
Boise, il 83703
email:dreading~mindspring.com
Anthony Y. Anel
29814 Lake Road
Bay Vilage OH 44140
email:yanel~attbi.com
Kevin Higgins
Energy Strategies LLC
Parks ide Towers
215 S. State St. Ste. 200
Salt Lake City, UT 84111
email:khiggins~energystrat.com
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
601 W. Banock St.
PO Box 2720
Boise, il 83701-2720
email:cew~givenspursley.com
Dennis E. Peseau, Ph.D
Utility Resources Inc.
1500 Libert Street SE, Suite 250
Salem, OR 97302
email:Dpeseau~Excite.Com
8
IDAHO POWER COMPANY CASE No. IPC-E-08-10
DOE's FIRT REQUEST FOR INFORMTION AN PRODUCTION OF DOCUMNTS
Ken Miler
Clean Energy Program Director
Snake River Alliance
PO Box 1731
Boise il 83701
email : Kmiler(ÐSnakeriveralliance. Org
Arhur Perr Bruder
Attorney for the
United States Deparent of Energy
9