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Home My WebLink About20080917Micron to IPC 1-23.pdfSl?--0-i,.m:iØo ()-o -J°c3:0c~r- ã5õ(Jo IN THE MATTER OF THE APPLICATION OF IDAHO PO~R 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 4489-34 GIVE SLEY LLP LAW OFFICES 601 W. Bannock Street PO Box 2720, Boise, Idaho 83701 TELEPHONE: 208 388-1200 FACSIMILE: 208 388-1300 WEBSITE: ww.givenspursley.com GaryG. Allen Peter G. Barton Christopher J. Beeson Clint R. Bolinder Erik J. Bolinder Jeremy C. Chou William C. Cole Michael C. Creamer Amber N. Dina Kristin Bjorkman Dunn Thomas E. Dvorak Jeffrey C. Fereday Justin M. Fredin 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 Kenneth R. McClure Kelly Greene McConnell Cynthiá A. Melilo Christopher H. Meyer L. Edward Miller Patrick J. Miller Judson B. Montgomery Deborah E. Nelson September 17, 2008 Via Hand Delivery Jean Jewell Idaho Public Utilties Commission 472 W. Washington P.O. Box 83720 Boise, ID 83720-0074 Re: Our File: Dear Jean: Kelsey J. Nunez W. Hugh O'Riordan, LL.M. G. Andrew Page Angela M. Reed Scott A. Tschirgi, LL.M. J. Will Varin Conley E. Ward Robert B. White Terri R. Yost RETIRED Kenneth L. Pursley Raymond D. Givens James A. McClure sg gg ~;0rn("rn;:m'0 i'' -0 .::~ PoW Enclosed for filing are an original and nine (9) copies of Micron Technology, Inc. ' s First Set of Discovery Requests to Idaho Power Company in connection with the above-captioned matter. If you have any questions, please call me. J::e~Qà~ Tina M. Adometto Assistant to Conley Ward CEW/tma cc: Service List (w/enclosures) S:\CLIENTS\4489\34\TA to JJewell re 1st set of discovery,DOC a' Conley E. Ward (ISB No. 1683) GIVENS PURSLEY LLP 601 W. Banock Street P. O. Box 2720 Boise, ID 83701-2720 Telephone No. (208) 388-1200 Fax No. (208) 388-1300 cewêgivenspursley.com RECEIVED 2008 SEP 11 PH 2: 21+ IDAHO PUBLIC UTILITIES COMMISSION Attorneys for Micron Technology, Inc. S:\clients\4489\34\Micron 1st Set of Discovery Requests.DOC BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MA TIER 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 MICRON TECHNOLOGY, INC.'S FIRST 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 Utilties Commission's Rules of Procedure. Definitions and Instructions The interrogatories and document requests are governed by the following definitions and instructions: Definitions 1. "You," "your" or "Idaho Power" means or pertains to the named respondent in this matter and includes, without limitation, Idaho Power, its offcers, directors, employees, agents, attorneys, corporate subsidiaries and affliates. MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - i .. 2. "Persons" means any and all natural persons, corporations, businesses, firms, companies, parnerships, unincorporated associations, governental or public agencies, joint ventures and all other entities, including, without limitation, all employees, representatives, consultants and agents of any of the foregoing. 3. "Documents" means any and all wrtten, 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, summares, opinions, studies, analyses, evaluations, work sheets, contracts, agreements, jourals, 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. 4. "Relating to" or "Relate(s) to" means directly or indirectly mentioning, consisting of, evidencing, describing, referring to, pertaining to, being connected with, or reflecting upon the stated subject matter. 5. The words "any" and "all" shall be considered to include each and every. 6. The singular of any word shall include the plural and the plural of any word shall include the singular. MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 2 7. 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 of Idaho Power in this matter. Instructions In answering these interrogatories and document requests, you are required to fuish 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: A. 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; B. 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; C. Identify each person who assisted or paricipated in preparng and/or supplying any of the information given in response to or relied upon in preparing responses to these discovery requests; D. Where a discovery request calls for a response in multiple pars, each par should be separated in the response so that the response is clearly understandable and complete; MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY-3 E. Where the name or identity of a person is requested, state the full name, business address, and any telephone numbers of each person; F. If any of your responses require the production of documents, label the documents to indicate the discovery request to which you are responding. G. If you object to the production of any document called for in these document requests, for each such document state the following: (l) 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 fuished, 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. H. If any document is withheld under claim of privilege or work product, fuish 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 fuished, 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. 1. If any document requested was, but is no longer in the possession or subject to the control of Idaho Power, or is no longer in existence, state whether it: (l) is missing or lost; (2) has been destroyed; (3) has been transferred voluntarly or involuntarly to others and state the identity of the persons to whom it has been transferred; (4) has otherwise been disposed of, or in MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 4 each instance explain the circumstances surounding such disposition, state the date or approximate date thereof and the identity of the persons with knowledge of such circumstaces; (5) identify the documents that are missing, lost, destroyed, transferred or otherwse disposed of, by author, date, subject matter, addressee(s), and the number of pages. J. If you do not clearly understad, or have any questions about, these definitions, instructions interrogatories or requests, contact counsel for Micron promptly for clarification. K. These discovery requests are continuing in natue and require supplemental responses upon the discovery or receipt of new or additional information. DISCOVERY REQUESTS REQUEST NO.1: Re: L. Keen pg. 10, L. 1-9. Please identify the degree to which the "...five negative actions by credit rating agency Standard & Poore's (sic) since 2000..." were caused by unregulated trading activities, other unegulated subsidiaries and Idaho Power itself. Please include the full text of the S&P reports describing the negative actions. REQUEST NO.2: Re: L. Keen, pg 7, L. 1 4-21. In addition to the Company's demand-side management efforts, has it considered seasonalizing capacity and energy costs, first to allocate costs to customer classes, and secondly to customer rate design, in order to better control growth in peak demand and energy usage? REQUEST NO.3: Please explain whether, and to what extent, the Company has used the seasonal cost variation in its actual capacity and energy costs (as shown in Company Exhibit 50) to spread capacity and energy costs to customer classes. REQUEST NO.4: Does the Company agree or disagree that the seasonal cost data shown in its marginal cost study is accurate? MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 5 REQUEST NO.5: If failure to use seasonal cost differences to spread cost of service to customer classes can be shown to cause an underpricing of both peak capacity and energy costs, would this contribute to, or exacerbate, Idaho Power's deteriorating system load factor? REQUEST NO.6: Has the Company studied whether or not spreading costs to customer classes based on seasonal cost differences is a cheaper or more effcient means of discouraging peak usage than certain DSM measures? If so, please provide all relevant studies. REQUEST NO.7: Re: J. Gale, pgs. 23-27, has Idaho Power or IDACORP had any independent or outside reviews of its new cost of service studies since the 2007 rate case? REQUEST NO.8: Re: 7 above. Please provide all wrtten materials and sumares of verbal reports relevant to the response to Request No.7, above. REQUEST NO.9: Please provide the most recent marginal cost study prepared by the company. REQUEST NO. 10: Please provide in electronic format the actual Excel workbooks used to prepare the cost of service studies, including all the input data and formulas. REQUEST NO. 11: Please provide all cost of service studies prepared by the Company for rate proceedings since 2005. REQUEST NO. 12: Please provide the Company's most recently completed Integrated Resource Plan, as well as any draft plans not yet completed. REQUEST NO. 13: Please provide the updated marginal energy costs for the five year period 2007-2011 referred to in the testimony of Mr. Tatu. REQUEST NO. 14: Please provide monthly load factors and production for each of the Company's hydro and thermal generating resources, including the three combustion turbines referenced in Mr. Tatum's testimony, for the last five years. MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6 REQUEST NO. 15: Please provide all monthly energy and peak hour surlus/deficiency data in numeric format for the years 2007-2011 from the 2006 IRP used to seasonalize marginal generation capacity costs, as discussed in Mr. Tatu's testimony at page 27, lines 13-25. REQUEST NO. 16: Please provide monthly system retail sales and coincident peak loads for the last 10 years. REQUEST NO. 17: Please provide all LOLP or other capacity risk or load loss studies performed by or for the Company durng the last 3 years. REQUEST NO. 18: Please provide Idaho Power's monthly firm purchased energy amounts during the last three years, identifying the supplier for each purchase. REQUEST NO. 19: Please provide the forecast of natural gas prices used to prepare the estimated normalized power supply costs for the test period. REQUEST NO. 20: Please provide the date the natural gas price forecast referenced immediately above was prepared. REQUEST NO. 21: Please provide the NYMEX closing monthly future natual gas prices monthly for the subsequent 12 months after Idaho Power's natural gas price forecasts were prepared. REQUEST NO. 22: Please provide the NYMEX closing future natural gas prices monthly for the 12 months beginning October 2008. REQUEST NO. 23: Please update the estimated normalized power supply costs for the test period using the updated future closing NYMEX prices provided in responses to Request Nos. 21 and 22 above. If it is not possible to update the normalized power supply costs for the MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY -7 test period, please estimate the impact of the change in NYMEX prices on normalized power supply costs for the test period. DATED this 1 ih day of September, 2008 MICRON TECHNOLOGY, INCo'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of September, 2008, 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 Utilties Commission 472 W. Washington Street P.O. Box 83720 Boise, ID 83720-0074 Barton L. Kline Idaho Power Company 1221 W. Idaho Street P.O. Box 70 Boise, ID 83707 John Gale Idaho Power 1221 W Idaho St Boise, ID 83702 Peter J. Richardson Richardson & O'Leary 515 North 27th Street Boise, ID 83702 Email: peter.irichardsonandolear.com Don C. Reading 6070 West Hil Road Boise, ID 83703 Email: dreading(fmindspring.com Weldon B. Stutzman Neil Price Deputy Attorneys General Idaho Public Utilties Commission 472 W. Washington Street P.O. Box 83720 Boise, ID 83720-0074 Email: Weldon.stutzmant$uc.idaho.gov N eil.price(fpuc.idaho. gov U.S. Mail X Hand Delivered Overnight Mail Facsimile E-Mail X U.S. Mail X Hand Delivered Overnight Mail Facsimile E-Mail X U.S. Mail X Hand Delivered Overnight Mail Facsimile E-Mail X U.S. Mail Hand Delivered Overnight Mail Facsimile E-Mail X U.S. Mail Hand Delivered Overnight Mail Facsimile E-Mail X U.S. Mail Hand Delivered Overnight Mail Facsimile E-Mail MICRON TECHNOLOGY, INCo'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 9 Randall C. Budge X U.S. Mail Erin L. Olsen Hand Delivered Racine, Olson, Nye, Budge & Bailey, Chtd.Overnight Mail 201 East Center, Suite A2 Facsimile P.O. Box 1391 E-Mail Pocatello, ID 83204-1391 Email: rcb~racinelaw.net elo~racinelaw.net Anthony 1. Yanel X U.S. Mail 29814 Lake Road Hand Delivered Bay Vilage, OH 44140 Overnight Mail Email: yanel~attbi.com Facsimile E-Mail Michael L. Kurz X U.S. Mail Kurt J. Boehm Hand Delivered Boehm, Kurz & Lowr Overnight Mail 36 E. Seventh Street, Ste. 2110 Facsimile Cincinnati, OH 45202 E-Mail Email: mkurz~BKLlawfrm.com kboehm~BKlawfrm.com Brad M. Purdy X U.S. Mail Attorney at Law Hand Delivered 2019 N. 17th Street Overnight Mail Boise, ID 83702 Facsimile Email: bmpurdy~hotmaii.com E-Mail Kevin Higgins X U.S. Mail Energy Strategies, LLC Hand Delivered Parks ide Towers Overnight Mail 215 S. State Street, Suite 200 Facsimile Salt Lake City, UT 84111 E-Mail Email: khiggins~energystrat.com LotH. Cooke X U.S. Mail Arhur Perr Bruder Hand Delivered United States Deparment of Energy Overnight Mail 1000 Independence Ave., SW Facsimile Washington, DC 20585 E-Mail Email: Lot.cooke~hq.doe.gov Arthur.Bruder~hq.doe.gov MICRON TECHNOLOGY, INCo'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 10 Dwight Etheridge Exeter Associates, Inc. 5565 Sterrett Place, Suite 310 Columbia, MD 21044 Email: dethendge(fexeterassociates.com Dennis E. Peseau, Ph.D. Utilty Resources, Inc. 1500 Liberty Street SE, Suite 250 Salem, OR 97302 Email: dpeseau(fexcite.com Ken Miler Clean Energy Program Director Snake River Allance P.O. Box 1731 Boise, ID 83701 Email: kmiler(fsnakeriverallance.org x U.S. Mail Hand Delivered Overnight Mail Facsimile E-Mail x U.S. Mail Hand Delivered Overnght Mail Facsimile E-Mail x U.S. Mail Hand Delivered Overnight Mail Facsimile E-Mail úJ~O MICRON TECHNOLOGY, INC.'S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 11