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Home My WebLink About20090630ICIP to IPC 6-7.pdfPeter J. Richardon ISB # 3195 RICHARDSON & O'LEARY PLlC 515 N. 2th Street Boise, Idaho 83702 Telephone; (208) 938-7901 Fax: (208) 938-7904~naio.ry.com RECEIVED 200' JUN 30 PH 12: 25 IDAH!O Cl lEI It".l f U ~_IV UTILITIES COMMISSlCk Attrneys for the Industrial Customers of Idaho Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MA TIER OF THE APPLICATION OF IDAHO POWER COMPANY FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE LANGLEY GULCH POWER PLANT ) CASE NO.IPC-E-09-03 ) ) INDUSTIAl CUST ) IDAHO POWER'S ) THE THIRD PRODUCTION ) REQUEST OF IDAHO POWER COMES NOW, The Industrial Customers of Idaho Power and in response to the First Production Request of Idaho Power Company, dated June 24, 2009, herewith submits the following information: REQUEST NO.6: On page 20 of ICIP witness Mitchell's testimony, she presents Figure 8, entitle "Idaho Per Capita Peronal Income IPC August 2007 and DFMApril ICIP'S RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST - 1 2009 Foreqasts." On line 4 below the chart, Ms. Mitchell identifies the source Of the data used to prepare Figure 8 as the "IPC IRP 2008 Update and Idaho Economic Forecast Quarterly Detail, April 2009." Please provide a specific reference to the location in the Company's 2008 Integrated Resource Plan Update frömwhichthedata used to prepare Figure 8 was taken. Please provide either a specific reference to the location(s) in the 2008 Integrated Resource Plan Update, copies of the specific pages from the document that is cited as the source of the "IPC August 2007" data, or specifc directions to electronically accss the data used. The information provided in response to this Request should specifically identif the location of the source data used to plot the "diamond" (lPC) line on Figure 8. RESPONSE TO REQUEST NO.6: The data in Figure 8, page 20, came from the 2006 IRP Appendix C and notfrom the 2008 Update as indicated in the line 4 below the chart. The reference is: Appendix C - Economic Forecast for the 2006 Integrated Resource Plan, pages 11 and12,available at: httg:IIw..idahopower.com/gdfs/AboutUslPlanningForFuturellrg/2006/2006 IRP Appe ndixC.pdf. The data were adjusted to 2000 $ using the data on "Personal Income (millions) for the year 2000, on page 11. The reference to "I PC August 2007" data came from page 9 of the 2008 Integrated Resource Plan Update, available at: http://ww.idahopower.com/pdfs/AboutUs/PlanningForF utu re/irp/2008/20081RP Update. Q9 This document states: "The projections were updated in August 2007 and are the basis for the sales and load forecast forth.e2008lRP Update."(2008IRP Update, page 9) ICIP'S RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST - 2 The 2008 Update did not include data for the variables used to update the load forecast (i.e. it did not incluQe a section similar to Appendix C of the 2006 IRP). The 2008 Update doe include a discussion of the signifcant factors that influenced the 2008 IRP Update lead forest. It states: "Signifcant factors influenciAg the 2008 IRP Update sales and load forecast include: · The sale and load forecast developed for the 20081RP Update reflects the addition of one new "Specill Contract" customer. This customer plans to begin operaticm in January 2009 and reach full capacit by August 2009. The 2008 IRP Update sales and load fQr~t includes 38 aMW wih a peak demand of 43 MW for this customer. Although this additional load was included in the updated forecast, Idaho Power and the customer are stll iA discussions and the final load could eventually be more than doublethese amounts. . · Demaflsie maAagement (OSM) program performance has exceed the 2006 lRPprojectns. . · The effec of coe changes for resiçlential building practices, including increased insulation requirements and air conditioning unit effciency for new construction and replacement units, has lowered energy consumption projections. · New DSM programs proposed in the 2006 IRP were initially categorized as supply- side resources. As proposed programs are implemented, the program effcts are integrated iAto existing DSM and considered to be part of the load forecast base which lowers the energy and peak forecast. The 2008 IRP Update sales and. load forecst reflec the full integration of DSM program effects as a reduction to the forecast time sees as well as the effects of new building codes and air conditioning effciency standards. " (2008 Update, page 9) The 2008 Update also includes a discussion of customer growth (2008 Update, page 9). The 2008 Update does not discuss changes in personal income and employment projectioAs between th 2006 IRP and 2008 IRP Update as being significant factors. Ms. Mitchellinterpreted this to mean that there was no signifcant diffrence betwn the 2006 IRP and the 2008 IRP Update in terms of per capita personal income and employment projections to 2012. The 2006 fRP figures were therefore used in Figure 8. REQUEST .NO. 7: On page 21 of ICIP witness Mitchells testimony, she presents Figure 10, entitled "Idaho Total Employment: IPC August 2007 and DFM April 2009 ICIP'S RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST - 3 Forecasts." Ms. Mitchell identifies the source of the data used to prepare the chart as the "IPC IRP 2008 Update and the Idaho Economic Forecast Quarterly Detail, April 2009", Please provide a specific reference to the location in the Compahys2008 Integrated Resource Plan Update from which the data used to prepâreFigurei10Was taken. Please provide either a specific reference to the location(s) in the 2008 Integrated Resource Plan Update, copies of the specific pages from the document that is cited as the source of the "IPC August 2007" data, or specifc directions to electronically access the data used. The information provided in response to this Requestshould specifically identify the location ofthe source data used töplotthé "diamond" (IPC) line on Figure 10. RESPONSE TO REQUEST NO.7: The data in Figure 10, page 21, came from the 2006 IRP Appendix C and not from the 2008 Update as indicated below the chart. The reference is: Appendix C - Economic Forecast for the 2006 Integrated Resource Plan, pages 2-3, available at: http://w.idahopower..com/pdfs/AbouìUs/PlanningForFuturelirp1200612006 IRP Appendix C.pdf. . The reference to "IPC August 2007" data came from page 9 of the 2008 Integrated Resource Plan Update, available at: http://ww.idahopower.com/pdfs/AboutUs/PlanningForFuture/iæ/2008/2008lRPUpdate. Q9 This document states: "The projections were updated in August 2007 and are the basis for the sales and load forecast for the 2008 IRP Update." (2008 IRP Update, page 9) ICIP'S RESPONSE TO IPCO'S THIRDPROÐUCTION REQUEST - 4 The 2008 Update did not include data for the variables used to update the load forecast (Le. it did not include a section similar to Appendix C of the 2006 IRP). The 2008 Update doe iiiclude a discussion of the signifcant factors that influenced the 2008 IRP Update load forest. The document states: "Significant factors influencing the 2008 IRP Update sales and load forecast include: · The sales and load forecast developed for the 2008 IRP Update reflects the addition of one new "Special Contract" customer. This customer plans to begin operation in January 2009 and reach full capacity by August 2009. The 2008 IRP Update sales and load forecast includes 38 aMW with a peak demand of 43 MW for this customer. Although thiS additional load was included in the updated forecast, Idaho Power and the customer are still in discussions and the final load could eventually be more than double these amounts. · Demand-side management (DSM) program performance has exceeded the 2006 IRP projectons. · The effec of code changes for residential building practices, including increased insulation requirements and air conditioning unit effciency for new construction and replacement units, has lowered energy consumption projections. · New DSM programs proposed in the 2006 IRP were initially categorized as supply- side resources. As proposed programs are implemented, the program effects are integrated into existing DSM and considered to be part of the load forecast base which lowers the energy and peak forecast. The 2008 IRP Update sales and load forecst reflect the full integration of DSM program effects as a reduction to the forecast time series as well as the effecs of new building codes and air conditioning effciency standards." (2008 Update, page 9) The 2008 Update also includes a discussion of customer growth (2008 Update, page 9). The 2008 Update does not discuss changes in personal income and employment pröjectioiis between the 20061RP and 2008lRP Update as being significant factors. Ms. Mitchell interpreted this to mean that there was no significant diference betwen the 2006 IRP and the 2008 IRP Update in terms of per capita personal incömeand employment projecons to 2012. The 2006 IRP data were therefore used in Figure 10. ICIP'S RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST - 5 Respectfully submited:6!':o( 0 r e-f~Peterd. Richardson Attörney for the Industrial ClJstomersofldahoPöwer ICIP'S RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 29th day of June, 2009, a true and correct copy of the within and foregoing of THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSITO THE THIRD PRODUCTION REQUEST OF lDAHOPOWER COMPANY was served in the manner shown to: Ms. Jean Jewell (C) Commission Secretary Idaho Public Utilties Commission 472 W. Washington (83702) POBox 83720 Boise, ID 83720-0074 2L Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Usa Nordstrom (C) Barton L. Kline Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 lnQrgstrom~idahopower.com Qkline(ÇidahQlQwer. com 2L Hand Delivery _U.S. Mail, postag pre-paid Facsimile Electronic Mail Scott Woodbury (C) Deput Attory General Idaho Public Utilites Commission 472 W. Washington Boise ID 83702 Sco.woodburypuc.idaho.gov X Hand Delivery U.S. Mail, postage pre-aid Facsimile Electronic Mail Dean J. Miller (C) McDevitt & Miler LLP 420 W. Bartnock St (83702) PO Box 2564 Boise ID 83701 ioe~mcdevitiller.com Willam Borders (C) _ Hand Delivery LU.S. Mail, postage preaid Facsimile Electronic Mail _ Hand Delivery ICIP'S RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST - 7 Assistant General Counsel Invenergy Thermal Development LLC One South Wacker Dr., Suite 1900 Chicago, IL 60606 wborders(§invenergyllc. com iu.S. Mail, postage pre-paid Facsimile Electronic Mail Eric L. Olsen RaciJ'e,...OlsoA, Nye,..Budge& Bailey, Chtd. 201 E. Center PO Box 1391 Pocatello, ID83204-1391 elo(§racinelaw. net _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile Electronic Mail Anthony Yankel 29814 lake Road Bay Vilage, OH 44140 tony(§yankel. net _ Hand Delivery iU.S. Mail, postagepre"'paid Facsimile Electronic Mail Ken MiUer Clean Energy Program Director Snake River Alliance PO Box 1731 Boise, ID 83701 kmiller(§snakeriveralliance.org _ Hand Delivery i U.S. Mail, postage pre..paid Facsimile Electronic Mail Betsy Bridge Idaho Conservation league 710 North Sixth Street (83702) PO Box 844 Boise, ID 83701 bbridge(§wildidaho.org _ Hand Delivery iU.S. Mail, postage pre-paid Facsimile Electronic Mail Susan K. Ackerman NIPPC 9883 NW Nottage Dr. Portland OR 97229 Susan .k.ackerman(§comcast. net Electronic Copies On.ly: _ Hand Delivery iU.S. Mail, pøstage pre..aid Facsimile Electronic MaU _ Hamd Delivery _U.S. Mail, postage pre-paid Facsimile ICIP'S RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST -8 Robert Kahn rkahnCnippc.org X Electronic Mall ~1J~hNina Curtis Administrative Assistant iaip's RESPONSE TO IPCO'S THIRD PRODUCTION REQUEST - 9