20090520Staff 80-83 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
R~ECE: \/
ZIlû9 MAY 20 P~I ~: t 7
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 A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE LANGLEY
GULCH POWER PLANT.
)
) CASE NO. IPC-E-09-03
)
) SECOND 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,
Scott Woodbur, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JUNE 3, 2009.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 MAY 20, 2009
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 80: The Company provided a Langley Gulch power plant cash flow
and AFUDC calculation in response to Staff Production Request No. 64; please identify how the
cash flows per month were identified and/or forecasted and all documentation associated with
those amounts. Please include within your response the accounting extracts for amounts incured
to date and all electronic fies with formulas intact.
REQUEST NO. 81: The Company noted that a schedule showing the AFUDC
calculation associated with transmission was not available at the time in response to Staff
Production Request No. 64; please provide a copy of the AFUDC calculation associated with
transmission that includes how the cash flows per month were identified and/or forecasted and
all documentation associated with those amounts. Please include within your response the
accounting extracts for amounts incured to date and all electronic fies with formulas intact.
REQUEST NO. 82: Please provide the components and calculation of the 7% AFUDC
(in Excel format with formulas intact) rate estimate used by the Company in its response to Staff
Production Request No. 64. Please include withn your response the actual AFUDC calculations
for 2009 to date.
REQUEST NO. 83: Please provide all studies, life cycle analyses and other information
used to derive a depreciable life of 35 years for the production plant and 45 years for the
transmission plant. Please include within your response the commitment estimate dollars as it
relates to production and transmission plant by electric plant in service account number
(3XX.xx) and the related depreciable life. Reference Gale Supplemental testimony, page 4, lines
7-9.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 MAY 20, 2009
:Ø
DATED at Boise, Idaho, this :l day of May 2009.
*lâ.~Al
-ú Sc Woodbur
lI Deputy Attorney General
Technical Staff: Patricia Hars
i:umisc:prodreqlipce09.3swrps ipc2
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 MAY 20, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF MAY 2009,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-09-3,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bklineØ&idahopower.com
InordstromØ&idahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadingØ&mindspring.com
WILLIAM BORDERS
ASSISTANT GENERAL COUNSEL
INVENERGY THERMAL DEVELOPMENT
ONE SOUTH WACKER DR
SUITE 1900
CHICAGO IL 60606
E-MAIL: wbordersØ&invenergy.com
ANTHONY YANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E-MAIL: tonyØ&yanel.net
BETSY BRIDGE
IDAHO CONSERVATION LEAGUE
710 N SIXTH ST (83702)
POBOX 844
BOISE ID 83701
E-MAIL: bbridgeØ&wildidaho.org
PETER J RICHARDSON
RICHARDSON & O'LEARY
515 N 17TH STREET
PO BOX 7218
BOISE ID 83702
E-MAIL: peterØ&richardsonandolear.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joeØ&mcdevitt-miler.com
ERIC L. OLSEN
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloØ&racinelaw.net
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: krilerØ&snakeriverallance.org
SUSAN K. ACKERMAN
9883 NW NOTTAGE DR
PORTLAND OR 97229
E-MAIL: susan.k.ackermanØ&comcast.net
CERTIFICATE OF SERVICE
ELECTRONIC COPIES ONLY
ROBERT KAHN
E-MAIL: rkahØ&nippc.org
Jo~SECFU~y -
CERTIFICATE OF SERVICE