The URL can be used to link to this page

Home My WebLink About20081103IPC 1-21 to Staff.pdfBARTON L. KLINE Lead Counsel eslDA~POR(I An IDACORP Company r ,'~O,¡I.. October 31, 2008 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilties Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-08-10 General Rate Case Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's First Production Request to the Commission Staff. Upon receipt of this filing, I would appreciate it if you would return a stamped copy of this letter for my file in the enclosed stamped, self-addressed envelope. , Barton L. Kline BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise. ID 83702 BARTON L. KLINE, ISB #1526 LISA D. NORDSTROM, ISB #5733 DONOVAN E. WALKER, ISB #5921 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 Facsimile: (208) 388-6936 bkline~idahopower.com Inordstrom~idahopower.com dwalker~idahopower.com RECEIVED 211.8 OCT 31 PH~: 56 U IDAHO PUBl íCTlUTlES COMi\llSSION Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 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. ) ) CASE NO. IPC-E-08-10 ) ) IDAHO POWER COMPANY'S ) FIRST PRODUCTION REQUEST ) TO THE COMMISSION STAFF ) COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), by and through its attorneys, and hereby requests that the Idaho Public Utilities Commission Staff ("Staff') answer the following production requests and provide the following information and documents in accordance with the Commission's Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 1 To allow the Company to utilize these responses in preparing its rebuttal testimony, it is necessary that the responses to these production requests be provided as soon as possible, but no later than November 10, 2008. This production request is to be deemed continuing in nature and Staff is requested to provide, through supplementation, additional documents or information that is responsive to this request that it, or any person acting on its behalf, may later come into possession or become aware of. REQUEST NO.1: Please provide copies of all electronic files, with formulas intact, that were used or relied on to develop the analyses and/or schedules supporting Staffs testimony. REQUEST NO.2: Please provide copies of all workpapers and supporting documents Staff relied on to support their testimony, exhibits, and any analysis contained therein. REQUEST NO.3 TO STAFF WITNESS LECKIE: Referring to Exhibit 118, please provide workpapers or other documentation identifying the source of the data included in Exhibit 118. REQUEST NO.4 TO STAFF WITNESS LECKIE: On page nine of Mr. Leckie's testimony, he recommends a reduction of 0.5% to be applied to the combined 2.5% associated with the Customer Satisfaction and Network Reliabilty incentive payments proposed by the Company. Please provide copies of any workpapers, studies, or analysis that support the selection of the 0.5% reduction. REQUEST NO.5 TO STAFF WITNESS LECKIE: In Staff witness J. Leckie's testimony, page 14, lines 5 and 7, he states that the directors of Idaho Power earned IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 2 $337,676 in interest on deferred fees. Please provide a detailed calculation, including any workpapers and/or supporting documentation, showing how the $337,676 amount was computed. REQUEST NO.6 TO STAFF WITNESS LECKIE: In Staff witness J. Leckie's Exhibit 113, he lists Miscellaneous Service Revenues for 2005 in the amount of $6,012,639. Please provide a detailed calculation, including any workpapers and/or supporting documentation, showing how the $6,012,639 amount was calculated. REQUEST NO.7 TO STAFF WITNESS ANDERSON: On page 2, line 19, of Staffs testimony, Mr. Anderson states: "Since 1999 I have served the Commission as a policy strategist for electricity. . .." Is Mr. Anderson currently serving as a policy strategist for the Idaho Public Utilities Commission? REQUEST NO.8 TO STAFF WITNESS ANDERSON: Is Mr. Anderson acting in his capacity as a policy strategist in this proceeding (Case No. IPC-E-08-10)? REQUEST NO.9 TO STAFF WITNESS ANDERSON: On page 2, line 10-18, Mr. Anderson refers to being a Staff representative on Idaho Powets Energy Effciency Advisory Group ("EEAG"). Is Mr. Anderson currently a member of Idaho Power EEAG? If so, for how long has he been a member? REQUEST NO. 10 TO STAFF WITNESS ANDERSON: On page 8, lines 5-7, Mr. Anderson states ". . . it is increasingly important that the utilities, other parties, and the Commission have clear concepts of what constitutes DSM prudency." When has Mr. Anderson or any other member of Commission Staff conducted a DSM prudency review on a utility? Please provide the name of the company, date, order number, and IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 3 a copy of any order/reportdocumentation produced by Staff describing the DSM prudency review and its outcome for each review conducted in the last 5 years. REQUEST NO. 11 TO STAFF WITNESS ANDERSON: Throughout Mr. Anderson's testimony he states that he has not received from the Company adequate information to determine prudency of the Company's DSM programs. Please specifically identify which Idaho Power DSM programs for which Mr. Anderson claims he does not have enough information to form a recommendation regarding prudency. REQUEST NO. 12 TO STAFF WITNESS ANDERSON: On page 9, line 17-18, Mr. Anderson states: "Although the Company provided some, but not all, minutes of EEAG meetings .. " Please specifically identify which EEAG minutes were not provided. REQUEST NO. 13 TO STAFF WITNESS VAUGHN: Please provide the detailed calculation and any workpapers and/or supporting documentation for the A&G accounting entries included in Staff witness C. Vaughn's Exhibit No. 122, columns 3 though 7, line 5. REQUEST NO. 14 TO STAFF WITNESS VAUGHN: Please provide the detailed calculation and any workpapers and/or supporting documentation for the P-Card adjustments included in Staff witness C. Vaughn's Exhibit No. 125, pages 1 and 2. REQUEST NO. 15 TO STAFF WITNESS VAUGHN: In Staff witness C. Vaughn's testimony on page 3, lines 18 through 20, she states the Company requested an increase to O&M of $15,985,407. Please provide a detailed calculation, including any workpapers and/or supporting documentation, showing how the $15,985,407 amount was calculated. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 4 REQUEST NO. 16 TO STAFF WITNESS STERLING: Please provide the Excel spreadsheet that created the basis differential of $0.13 from Henry Hub to Sumas. REQUEST NO. 17 TO STAFF WITNESS STERLING: Please provide the Excel spreadsheet for the "monthly shape factors" that were used in your analysis for gas prices. REQUEST NO. 18 TO STAFF WITNESS LANSPERY: On page 10 of Staff witness Lanspery's testimony, he states that an increase in the customer charge for residential customers is not justified because Staff witness Hessing's Cost of Service results did not warrant a rate increase to the residential customers. Assuming hypothetically that Staff witness Hessing's Cost of Service results warranted a rate increase for the residential customers, would an increase to the service charge be justified? If so, how much? REQUEST NO. 19 TO STAFF WITNESS LANSPERY: On page nine of Staff witness Lanspery's testimony, he states that, ". . . heating and cooling should also be considered basic end uses, as well as a point at which residential customers begin to differ from one another." Please explain why heating and cooling should be considered basic household electric end use, and why - if it is a point at which usage begins to differ greatly- does it follow that it should then be considered a basic end use? REQUEST NO. 20 TO STAFF WITNESS LANSPERY: On pages 11 through 13 of Staff witness Lanspery's testimony, he uses the "60 percent method" of the August and January usages to determine that "the first block level should be set closer to 800 kWh." Further he "deduced" that the proper cut-off point for a first block should be IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 5 between 600 kWh and 1000 kWh. Why was the high end of 1000 kWh chosen for the first block? REQUEST NO. 21 TO STAFF WITNESS ELAM: On page 7 of Mr. Elam's testimony he states: "i utilized the Schedule 19 historical time-of-use data implemented in Order No. 29547 to determine how the demand for energy shifted to different times given the price structure movement from a traditional rate design to a TOU rate design." Please provide the workpapers used in this analysis. DATED at Boise, Idaho, this 31st day of October 2008. QW'- BARTON L. KLINE Attorney for Idaho Power Company LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 31st day of October 2008 I served a true and correct copy of IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Weldon B. Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 -2 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Weldon.stutzman~puc.idaho.gov Neil Price Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 -2 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Neil.priæ~puc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 2th Street P.O. Box 7218 Boise, Idaho 83702 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email peter~richardsonandoleary.com Dr. Don Reading Ben Johnson Associates 6070 Hil Road Boise, Idaho 83703 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email dreading~mindspring.com Idaho Irrigation Pumpers Association, Inc. Randall C. Budge Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 201 East Center Pocatello, Idaho 83204-1391 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email rcb~racinelaw.net elo~racinelaw. net IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 7 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Kroger Co. I Fred Meyer and Smiths Michael L. Kurt Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 The Kroger Co. Attn: Corporate Energy Manager (G09) 1014 Vine Street Cincinnati, Ohio 45202 Kevin Higgins Energy Strategies, LLC Parkside Towers 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Micron Technology Conley Ward Michael C. Creamer GIVENS PURSLEY, LLP 601 West Bannock Street P.O. Box 2720 Boise, Idaho 83701-2720 Dennis E. Peseau, Ph.D. Utility Resources, Inc. 1500 Liberty Street SE, Suite 250 Salem, Oregon 97302 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email tony~yankel.net Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email mkurtz~BKLlawfirm.com kboehm~BKLlawfrm.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX Email Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email khiggins~energystrat.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email cew~givenspursley.com mcc~givenspursley.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email dennytemp~yahoo.com IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 8 Department of Energy Lot R. Cooke Arthur Perry Bruder Offce of the General Counsel United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Routing Symbol GC-76 Hand Delivered U.S. Mail -2 Overnight Mail FAX -2 Email Lot.Cooke~hg.doe.gov Arthur. Bruder~hg.doe.gov Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Plaæ, Suite 310 Columbia, MD 21044 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email detheridge~exeterassociates.com Community Action Partnership Association Of Idaho Brad M. Purdy Attomey at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email bmpurdy~hotmail.com Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email kmiler~snakeriverallance.org ~Barto L. Kline .. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE COMMISSION STAFF - 9