20081110IPC 22-40 to Staff.pdf

LISA D. NORDSTROM
Senior Counsel
esIDA~PORQ9
E f V E D An IDACORP Company
PUBUG
November 7, 2008
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities 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 Second Production Request to the Commission Staff.
Upon receipt ofthis 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.
Very truly yours,
;f~¡Q.If~
Lisa D. Nordstrom
LDN: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: [phone]
Facsimile: [phone]
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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
) SECOND 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 SECOND 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 17, 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. 22 TO STAFF WITNESS CARLOCK: Reference Carlock Direct
at page7, lines 21-25. Did Ms. Carlock evaluate trends in public utilty bond yields from
Idaho Power's last case until the present? If the answer is "yes," please explain these
trends and her conclusions.
REQUEST NO. 23 TO STAFF WITNESS CARLOCK: Does Ms. Carlock agree
that the risk differential between Idaho Power and other electric utilties is reflected in
corporate credit ratings, such as those published by Standard & Poor's Corporation? If
the answer is "no," please provide a complete explanation for Ms. Carlock's opinion, as
well as copies of all supporting documents.
REQUEST NO. 24 TO STAFF WITNESS CARLOCK: Reference Carlock Direct
at page 11, lines 8-14. Please provide complete copies of the source documents for the
authorized returns cited in Ms. Carlock'stestimony.
REQUEST NO. 25 TO STAFF WITNESS CARLOCK: Reference Carlock Direct
at page 11, lines 15-17. Please provide copies of all the specific data points for the
returns on book equity and identify the utilty, company, or industry to which those
returns apply that served as supports for Ms. Carlock's conclusion that application of the
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF - 2
comparable earnings method implies a return on equity in the 9.5% to 10.5% range. If
Ms. Carlock did not conduct an independent analysis of historical or projected earned
rates of return on equity to support her opinion, please so state.
REQUEST NO. 26 TO STAFF WITNESS CARLOCK: Reference Carlock Direct
at page 11, lines 15-17. Please provide copies of any source documents or other
analyses, materials, or evidence not specifically discussed in Ms. Carlock's testimony
that supports her conclusion that application of the comparable earnings method implies
a return on equity in the 9.5% to 10.5% range.
REQUEST NO. 27 TO STAFF WITNESS CARLOCK: Reference Carlock Direct
at page 13, lines 15-17. Please confirm that Ms. Carlock's DCF range of 8.9% to 9.8%
was based solely on the results of applying the DCF model to IDACORP. If Ms. Carlock
applied the DCF model to estimate the cost of equity for other utilities, please explain
and provide copies of the analyses and all underlying data.
REQUEST NO. 28 TO STAFF WITNESS CARLOCK: Reference Carlock Direct
at page 14, lines 11-15. Please provide copies of the analysis of growth indicators cited
by Ms. Carlock as support for her growth rate range of 4% to 6%, including copies of all
underling source documents.
REQUEST NO. 29 TO STAFF WITNESS VAUGHN: Ms Vaughn states in her
testimony page 10, lines 16-20, "The two cost elements that showed consistent growth
were Power Generation Other Expense and Distribution Other Expense. In each case, I
believe a modest 5% growth escalation is reasonable because the Company has some
discretion over Other Expense spending."
a. How was the escalation factor of 5 % determined?
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF - 3
b. Please explain what is meant by "the Company has some
discretion over 'Other Expense Spending.'"
REQUEST NO. 30 TO STAFF WITNESS VAUGHN: On page 8, lines 3-9, Staff
witness C. Vaughn concludes that the increase in 2007 G&A expense is related to the
divestiture of IDACORP subsidiaries. Please explain witness Vaughn's rationale and
provide any supporting documentation that supports her testimony that divestiture was
the sole cause of the increase and resulting recommended disallowance.
REQUEST NO. 31 TO STAFF WITNESS VAUGHN: Staff witness C. Vaughn's
workpapers contain an Excel spreadsheet entitled: "HC AFUDC Adjustment
Workpapers'l with a tab for "AFUDC Summary." Please describe the purpose of this
worksheet and its results.
REQUEST NO. 32 TO STAFF WITNESS VAUGHN: In her testimony and
workpapers ("IPC Pcard Exclusion Workpaper"), Staff witness C. Vaughn refers to a
Pcard classification within tabs labeled SB IPC, column B, and Coffee Water, column C,
as "ok" but then recommends disallowance of the amounts contained in that
classification. Please explain the purpose and definition of the "ok" classification as
Staff witness Vaughn has used it.
REQUEST NO. 33 TO STAFF WITNESS VAUGHN: In her testimony on page
16, lines 23-24, Staff witness C. Vaughn states that the FERC license may be issued as
soon as January of 2009. Please provide copies of documents or other evidence that
support this statement.
REQUEST NO. 34 TO STAFF WITNESS VAUGHN: In her testimony on page
17, lines 15-16, Staff witness C. Vaughn states that with the inclusion of AFUDC in base
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF - 4
rates, the Company has less of an incentive to push for completion of the relicensing.
Please explain witness,Vaughn's rationale for that conclusion and provide any analysis
performed to support this conclusion.
REQUEST NO. 35 TO STAFF WITNESS VAUGHN: In her testimony on pages
24-25, lines 24-25 and 1 respectively, Staff witness C. Vaughn states that certain
employees expenditures are traditional business expenses but do not benefit the
customers. Please provide witness Vaughn's underlying and rationale and any
analyses supporting the decision to remove specific expenditures because they do not
benefit customers.
REQUEST NO. 36 TO STAFF WITNESS VAUGHN: In her testimony on page
26, lines 24-25, Staff witness C. Vaughn stated "I removed 50% of all expenditures
classified as "Restaurant" below the line to eliminate expenditures that are believed to
be excessive." Please provide witness Vaughn's underlying rationale and any analyses
for the use of 50% as a measure of "excessive" restaurant expenditures.
REQUEST NO. 37 TO STAFF WITNESS VAUGHN: In her testimony on page
27, lines 5-6, Staff witness C. Vaughn states that the Company is "overly permissive"
regarding expenditures for restaurant meals and other food provided for its
employees. Please provide witness Vaughn's rationale that supports this conclusion
and any analyses showing the standards she applied to support her conclusion that the
Company is "overly permissive" regarding its meals policy.
REQUEST NO. 38 TO STAFF WITNESS VAUGHN: In her testimony on page
28, lines 5-23, Staff witness C. Vaughn has estimated that the Company has 1,300 cells
phones by taking the total expenditure of $793,855 and dividing it by $50.00. Please
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF - 5
provide the analyses and documentation she relied on to support the $50.00 used in
this calculation.
REQUEST NO. 39 TO STAFF WITNESS VAUGHN: In her testimony on page
28, lines 15-16, Staff witness C. Vaughn states that she believes that it is excessive for
the Company to provide cell phones to what she has estimated to be 66% of
employees. Please provide witness Vaughn's rationale supporting this conclusion and
any analyses showing the standards she applied to support her claim of excessive cell
phone use.
REQUEST NO. 40 TO STAFF WITNESS VAUGHN: In her testimony on page
28, lines 22-23, Staff witness C. Vaughn states that she removed 75% of the cell phone
expense charge to A&G and 50% of all remaining cell phone expense. Please provide
witness Vaughn's rationale for her decision to use 75% and 50% as an adjustment for
excessive cell phone expense and any analyses that support the use of 75% and 50%
as an adjustment.
DATED at Boise, Idaho, this ¡th day of November 2008.
cel2~LISA D. NORD~~
Attorney for Idaho Power Company
BARTON L. KLINE
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this ¡th day of November 2008 I served a true and
correct copy of IDAHO POWER COMPANY'S SECOND 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 83720-007 4
Neil Price
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hil Road
Boise, Idaho 83703
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
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IDAHO POWER COMPANY'S SECOND 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
Parks ide 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 Libert Street SE, Suite 250
Salem, Oregon 97302
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IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF - 8
Departent of Energy
Lot R. Cooke
Arthur Perry Bruder
Office of the General Counsel
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
Routing Symbol GC-76
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Dwight D. Etheridge
Exeter Associates, Inc.
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1 ¡th Street
Boise, Idaho 83702
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Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
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~~l/r¿~
Lisa D. Nordstrom ,
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE COMMISSION STAFF - 9