20080926ICIP to IPC 45-51.pdf

REceIVED
~Jf~~~ .A~~~~llE lUZDt.seP 26 PH 3: 35
Peter Richardson UTiL\W'lSOlrjJ~\~$lON
Tel: [phone] Fax: [phone]
peterli richardson andoleary. com
P.O. Box 7218 Boise.ID 83707 - 515 N. 27th St: Boise. ID 83702
26 September 2008
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: IPC-E-08-10
Dear Ms. Jewell:
We are enclosing three copies of the FOURTH PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, in the above case.
The original has been served on Idaho Power Company.
SinCewrely, . ~roV~Peter Richardson ISB 3195
Richardson & O'Leary PLLC
Peter J. Richardson ISB # 3195
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peterêrichardsonandoleary.com
RECEIVED
200e SEP 26 PH 3= 35
IDAHO PUBLIC
UTIUTIES COMMISSION
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHO~TY TO
INCREASE ITS RATES AND CHARGES
FOR ELECT~C SERVICE.
) CASE NO. IPC-E-08-10
)
) FOURTH PRODUCTION REQUEST
) OF THE INDUSTIAL CUSTOMERS
) OF IDAHO POWER
)
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers ofIdaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is 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 wil augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; dreadingêmindspring.com
1 - THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER ~ IPC-E-08- i 0
For each item, please indicate the name of the person(s) preparng the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed by Idaho Power to be
confidentiaL. Idaho Power, along with all other paries to this case, are reminded that the
Industral Customers of Idaho Power have entered into and filed with the Commission on July 16
and 23,2008 the Protective Agreement in connection with ths case IPC-E-08-10.
REQUEST FOR PRODUCTION NO. 45:
In Idaho Power Company's Response to the First Production Request to Commission Staff No. 9
the Company stated, "A wind integration cost cap of $6.50 was established in Case No. IPC-E-
07-03. If this cap were used, it is estimated that Idaho Power would incur nearly $3.5 Milion in
wind integration costs." Does Idaho Power believe it is in fact incurrng $3.5 Milion in costs
curently from both CSPP wind projects and its own Elkhorn Wind project that is not curently
being passed on to ratepayers? Please explain fully.
REQUEST FOR PRODUCTION NO. 46
In Idaho Power Company's Response to the First Production Request to Commission Sta No.
5, the Company provided a list ofPURPA projects (CONFIDENTIAL) signed but not yet
operating. Please, for this same list, provide the expected MW and MWh for each project.
2 ~ THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-08-1 0
REQUEST FOR PRODUCTION NO. 47
In Idaho Power Company's Response to the Third Production Request to ICIP No. 37 the
Company states, "Attached in a Fuel Cost Calculation workbook used to calculate the 20- Year
Levelized Dispatch Costs/MWh. Please provide the workbook and supporting workbooks in
electronic form.
REQUEST FOR PRODUCTION NO. 48
In Idaho Power Company's Response to the Third Production Request to ICIP No. 37 the
workbook provided uses "Max hours ru per year" in the analysis of 400 hours. Please explain
fully the answer to each of the following:
a. Does the Company assume the 400 hours is for each generator or is it for some
combination of generation sites?
b. What is the number of sites, and total MW expected by the Company should the
program be implemented?
c. Has the Company do any analysis as to the number of hours it would expect
emergency generators would actually be ru should the program be implemented?
d. In the analysis did the Company consider using emergency generators as reserves
that would be used to meet its reserve requirements?
e. Please provide a copy of any analysis referred to in responding.
3 - THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-08-1 0
REQUEST FOR PRODUCTION NO. 49
This Request is askingfor reconciling varous natural gas forecast used in the curent case.
a In Idaho Power Company's Response to the Third Production Request to ICIP
No. 37 the Company states it used the 2007 Nortwest Power and Conservation
Council's 2007 gas forecast in it Virtl Peaker Levelized Cost Analysis.
b In Idaho Power Company's Response to the First Production Request to
Commission Staff No. 5 provided natual gas data used in Idaho Power's AURORA
modeL.
c The 2008 Marginal Cost Analysis fied with witness Tatu's workpapers, page
47 states the Marginal Cost of Energy was found using power supply rus using Global
Insight 30-year Utility Natual Gas Index.
d The 2008 Marginal Cost Analysis filed with witness Tatum's workpapers, page
47 the loads and resources we from taen from the Company's 2006 IRPthat was based
on a different methodology.
Please compare each of the natual gas forecasts described in a through d above and provide an
explanation why a variety of natural gas forecasts were used in the analysis for a this single rate
case.
REQUEST FOR PRODUCTION NO. 50
In Company witness Nemnch's direct testimony, page 35, she states,
When time-of-use rates were implemented for Schedule 19 customers four years ago, the
differentials between On-Peak, Mid-Peak, and Off-Peak Energy Charges were set at an
4 - THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-08-1 0
"introductory" leveL. By increasing the rate differentials, a stronger price signal is sent
that wil provide a stronger incentive to conserve or to shift the time of energy usage to a
less costly time period. This stronger price signal provides higher benefits to those
customers who modify operations or purchase equipment that uses less energy.
a. Please provide any analysis and studies that the Company preformed that indicate
the price response and elasticity for Schedule 19 customers to increasing the
differentials in rates proposed for Schedule 19.
b. Please provide any analysis and studies that the Company preformed that indicate
the costs for Schedule 19 customers would incur in shifting their energy demand
to take advantage of the differentials in rates proposed for Schedule 19.
REQUEST FOR PRODUCTION NO. 51
The Company is proposing an increase of 70.5% in the Sumer On-Peak Demand Change for
Schedule 19 customers going from the current $0.44 to $0.75 (Exhibit 74, page 5 of 10). Please
provide any analysis or studies the Company has underten that would indicated the response it
expects from this rate increase.
DATED this 26th day of September, 2008.
RICHARDSON & O'LEARY PLLC
By: ££LL
Peter J. Richardson, ISB #3195
Attorneys THE INDUST~AL
CUSTOMERS OF IDAHO POWER
5 - THIRD PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-08- i 0
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of September, 2008, a true and correct copy of thewithn and foregoing FOURTH PRODUCTION REQUEST OF THE INDUST~AL CUSTOMERS
OF IDAHO POWER, was served in the maner shown to:
Ms. Jean Jewell
Commssion Secreta
Idao Public Utilities Commssion
POBox 83720
Boise, il 83720-0074
-- Hand Delivery
_ U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
JohnR. Gale
Vice President, Regulatory Affairs
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
i Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Baron L. Kline
Lisa D. Nordstrom
Donovan E. Walker
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
i Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chrd.
PO Box 1391
Pocatello, Idaho 83204-1391
_ Hand Delivery
-XU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
_ Hand Delivery
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Facsimile
Electronic Mail
Michael Kur, Esq.
Kur J. Boehm, Esq.
Boehm, Kurz & Lowr
36 E Seventh St, Suite 1510
Cincinnati OH 45202
_ Hand Delivery
X U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 S State Street, Suite 200
Salt Lake City UT 84111
Brad M Purdy
2019 N 17th Street
Boise ID 83702
LotH Cooke
Arur Perr Bruder
United States Deparent of Energy
1000 Independence Ave., SW
Washington DC 20585
Dwight Etheridge
Exeter Associates Inc
5565 Sterrett Place Ste 310
Columbia MD 21044
Conley E Ward
Michael C Creamer
Givens Pursley LLP
PO Box 2720
Boise in 83701-2720
Denns E. Peseau, Ph.D.
Utility Resources Inc
1500 Libert Street SE Ste 250
Salem OR 97302
6VrJ~
Peter Richardson
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