20081106Staff 1-5 to IPC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 14
ISB NO. 6864
RECEIVED
2008 NOV -6 PH I: 55
IDAHO P
UTILiTIES C
ie
ISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
. IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR APPROVAL )
OF A SPECIAL CONTRACT TO SUPPLY )
POWER TO HOKU MATERIALS, INC. )
)
)
)
)
)
CASE NO. IPC-E-08-21
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Idaho Power Company (Company; Idaho
Power) provide the following documents and information as soon as possible, but no later than
FRIDAY, NOVEMBER 28, 2008.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementa responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
FIRST PRODUCTION REQUEST TO
IDAHO POWER i NOVEMBER 6, 2008
Please provide answers 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 preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please provide copies of all workpapers and electronic fies, with
formulas intact, that were used or relied on to develop the rates contained in the Hoku Materials,
Inc. electric service agreement (ESA).
REQUEST NO.2: Please provide hypothetical calculations showing computation of at
least three monthly bils for Hoku at different energy usage levels, and provide corresponding
PCA calculations and accounting entries.
REQUEST NO.3: Please explain why Idaho Power believes that Hoku is entitled to
transition from marginal cost-based rates for its 1 st block energy to embedded costs, over any
length of time. Please explain why Idaho Power believes that 4-year transition period from
marginal cost-based to embedded cost-based rates is reasonable, as opposed to a longer or
shorter transition period.
REQUEST NO.4: Did Idaho Power's 2006 IRP assume that the Company would be
providing service to Hoku? If so, what was Hoku's assumed load?
REQUEST NO.5: Please make a comparison of the 1st block (marginal) rates
contained in the ESA to the marginal rates computed using AURORA. For the AURORA
analysis, model the Hoku contract as represented in the ESA and make other input data
assumptions consistent with those used for AURORA analysis in Idaho Power's ongoing general
rate case.
FIRST PRODUCTION REQUEST TO
IDAHO POWER 2 NOVEMBER 6, 2008
DATED at Boise, Idaho, thisbt~ day of November 2008.
-g'1A/ ~~~' CoNeil Price
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce08.2 i nprps prod req i
FIRST PRODUCTION REQUEST TO
IDAHO POWER 3 NOVEMBER 6, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF NOVEMBER 2008,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-08-21, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: bkline(iidahopower.com
lnordstrom(iidahopower .com
JOHN R GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale(iidahopower.com
SCOTT PAUL
VP BUSINESS DEVELOPMENT &
GENERAL COUNSEL
HOKU SCIENTIFIC INC
1075 OPAKAPAKA STREET
KAPOLEI HI 96707-1887
E-MAIL: spaul(ihokusci.com
SECRE~~
CERTIFICATE OF SERVICE