20090604Staff 97-103 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
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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
)
) SIXTH 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 Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
MONDAY, JUNE 15, 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 will 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
SIXTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 JUE 4, 2009
person preparng 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.
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. 97: Please provide documentation to support the amount included in
the Commitment Estimate for Air Permitting. Please provide copies of contracts as well as
documentation showing amounts spent to date.
REQUEST NO. 98: Idaho Power has included an amount in its Commitment Estimate
to cover the cost of "sta-up test fueL." Please provide documentation showing whether "sta-up
test fuel" was or was not included in the final bid price for each of the short listed bids.
REQUEST NO. 99: Reference Idaho Power's response to ICIP Production Request No.
23. Please state these percentage increases in curent 2009 dollars (or some other identified
comparable basis) so that the traditional ratemaking ilustrative example increase of7.88% is
comparable to the total ilustrative example of AFUDC increase of 6.9%. Please extend all
percentages to two decimal places in your response containing the Excel file with formulas
activated.
REQUEST NO. 100: Reference Idaho Power's response to ICIP Production Request
No. 23. If the preparer of this spreadsheet were calculating the relative results of traditional
ratemaking, AFUDC similar to Hells Canyon Relicensing in Order No. 30722, and "CWIP
(including AFUDC) in Rate Base" would anything on the spreadsheet change? If so, please
provide an Excel spreadsheet with formulas intact with all changed items identified (such as with
yellow fill in the cell) and the final result of those changes.
REQUEST NO. 101: Reference Idaho Power's response to ICIP Production Request
No. 23. What would be the relative results of traditional ratemaking, AFUDC similar to Order
No. 30722, and CWIP in rate base when income taxes, deferred federal income taxes associated
SIXTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JUE 4, 2009
with depreciation differences, and using a ~-year convention to recognize accumulated
. depreciation in traditional ratemaking were incorporated into the spreadsheets? Please include
within your response an Excel spreadsheet with formulas intact that include these components
and the final result of incorporating those components. If any other elements should be
incorporated. into the spreadsheet, please do so and state why.
REQUEST NO. 102: Reference Idaho Power's response to ICIP Production Request
No. 23. Please identify and provide the analysis from which it was determined that revenues
would grow 1 % each year.
REQUEST NO. 103: Reference Idaho Power's response to ICIP Production Request
No. 23 and its response to Staffs Production Request Nos. 99 through 102. Please make the
preparer of the I CIP Production Request responses avaîlable no later than June 17th for
discussing all components of the spreadsheet and in order to provide all/any related
documentation (memos, e-mails, other spreadsheets, correspondence, and so forth) not
previously provided associated with this issue.
A ju~-L
DATED at Boise, Idaho, this 'I day of Ma 2009.
~a~šC o~bur .. 7
Deputy Attorney General
Technical Staff: Rick Sterling (97-98)
Patricia Hars (99-103)
i:umisc:prodreq/ipce09.3swrpsph ipc6
SIXTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 JUE 4, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HA VE THIS 4TH DAY OF JUE 2009, SERVED
THE FOREGOING SIXTH 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: bkline(fidahopower.com
Inordstrom(fidahopower .com
PETER J RICHARDSON
RICHARDSON & O'LEARY
515 N 17TH STREET
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(frichardsonandolear.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(fmindspring.com
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmil ler(fsnakeriveralliance.org
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyankeLnet
ERIC L. OLSEN
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo(fracinelaw.net
BETSY BRIDGE
IDAHO CONSERVATION LEAGUE
710N SIXTH ST (83702)
POBOX 844
BOISE ID 83701
E-MAIL: bbridge(fwildidaho.org
SUSAN K. ACKERMAN
9883 NW NOTTAGE DR
PORTLAND OR 97229
E-MAIL: susan.k.ackerman(fcomcast.net
BRAD M. PURDY
ATTORNEY AT LAW
2019 N. i 7TH STREET
BOISE, ID 83702
E-MAIL: bmpurdy(fhotmaiLcom
1 CERTIFICATE OF SERVICE
ELECTRONIC COPIES ONLY
ROBERT KAHN
E-MAIL: rkah(fnippc.org
~.~
SECRETARY
2 CERTIFICATE OF SERVICE