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Home My WebLink About20090612IPC to IIPA 9-11.pdfeslDA~POR~ An IDACORP Company BARTON L. KLINE Lead Counsel June 11, 2009 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-09-03 LANGLEY GULCH POWER PLANT Dear Ms. Jewell: Enclosed for filng are an original and three (3) copies of Idaho Power Company's Responses to the Idaho Irrigation Pumpers Association, Inc.'s Third Data Requests in the above matter. Also enclosed are four (4) copies of a disk containing information responsive to the Requests. If you have any questions about the enclosed information, please let me know.Vl1~ 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 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: 208-388-2682 Facsimile: 208-388-6936 bklineCWidahopower.com InordstromCWidahopower.com RECEIVED ZOO, JUH I , PH It= 52 lDAHO PUSUC UTIUTIES COMMISSION 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 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 ) ) IDAHO POWER COMPANY'S ) RESPONSES TO THE IDAHO ) IRRIGATION PUMPERS ) ASSOCIATIONS, INC.'S THIRD DATA ) REQUESTS TO IDAHO POWER ) COMPANY COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the Idaho Irrigation Pumpers Association, Inc.'s Third Data Requests to Idaho Power Company dated June 4, 2009, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST NO.9: In a manner similar to the Company's response to Staff Interrogatory 39 in Case No. IPC-E08-10, please provide bil frequency data for residential customers for each month from January 2006 through the most recent month available. RESPONSE TO REQUEST NO.9: Idaho Power objects to this Request for the following reasons: 1. Under the Commission's Rules of Practice and Procedure and the Idaho Rules of Civil Procedure, discovery may be used to obtain copies of documents in the Company's possession. This production request goes beyond the scope of the Rules and asks Idaho Power to perform a new analysis. Idaho Power has not performed this analysis. 2. Providing the information as requested would be extremely burdensome. It would require the expenditure of many man-hours in order to provide the information in the form requested. These objections notwithstanding, Idaho Power has performed the residential bil frequency analysis for 2007 as provided in response to Staffs Production Request No. 39 in case No. IPC-E-08-10. The Excel file containing this analysis is provided on the enclosed CD. The response to this Request was prepared by Michael Youngblood, Manager of Rate Design, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 2 REQUEST NO. 10: In a manner similar to the Company's response to Staff Interrogatory 39 in Case No. IPC-E08-10, please provide bill frequency data for each rate schedule for which data is available for each month from January 2006 through the most recent month available. RESPONSE TO REQUEST NO.1 0: Idaho Power objects to this Request for the following reasons: 1. Under the Commission's Rules of Practice and Procedure and the Idaho Rules of Civil Procedure, discovery may be used to obtain copies of documents in the Company's possession. This production request goes beyond the scope of the Rules and asks Idaho Power to perform a new analysis. Idaho Power has not performed this analysis. 2. Providing the information as requested would be extremely burdensome. It would require the expenditure of many man-hours in order to provide the information in the form requested. These objections notwithstanding, Idaho Power has performed the 2007 monthly bil frequency analysis for the Company's Schedule 07, Small General Service, customers as provided in response to Staffs Production Request No. 42 in case No. IPC-E-08-10. The Excel file containing this analysis is provided on the enclosed CD. This data was used to evaluate the current summer block rate and to evaluate data supporting the proposed non-summer block rate. This is the only bil frequency analysis completed for the commercial schedules. IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 3 The response to this Request was prepared by Michael Youngblood, Manager of Rate Design, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 4 REQUEST NO. 11: Is the data provided in response to interrogatories "3" and "4" above on a total Company basis or an Idaho Jurisdictional basis? RESPONSE TO REQUEST NO. 11: The data provided in response to interrogatories "3" and "4" were on an Idaho jurisdictional basis. The response to this Request was prepared by Michael Youngblood, Manager of Rate Design, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 11th day of June 2009. úN~BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of June 2009 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power and Northwest and Intermountain Power Producers Coalition 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 Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 201 East Center Pocatello, Idaho 83204-1391 -2 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Scott.WoodburyCWpuc.idaho.gov Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email peterCWrichardsonandoleary.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email dreadingCWmindspring.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email kmillerCWsnakeriveralliance.org Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email eloCWracinelaw.net IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 6 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Village, Ohio 44140 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email tonyCWyankel.net Idaho Conservation League Betsy Bridge Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email bbridgeCWwildidaho.org Northwest and Intermountain Power Producers Coalition Susan K. Ackerman 9883 NW Nottage Drive Portland, Oregon 97229 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email Susan.k.ackerman(âcomcast.net Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email bmpurdyCWhotmail.com C1r~ Barton L. Kline IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 7