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Home My WebLink About20090819IPC Objection to ICIP 42-46.pdfBARTON L. KLINE Lead Counsel eslDA~POR~ An IDACORP Company August 18, 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 filing are an original and three (3) copies of Idaho Power Company's Objection to the Third Production Request of the Industrial Customers of Idaho Power in the above matter. Barton L. Kline BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 BARTON L. KLINE, ISB No. 1526 LISA D. NORDSTROM, ISB No. 5733 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: 208-388-2682 Facsimile: 208-388-6936 bklinecæidahopower.com Inordstromcæidahopower.com RECEIVED 20M AUG i 8 PM~: 50 IDAHO PUBliC UTILITIES 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 ) OBJECTION TO THE THIRD ) PRODUCTION REQUEST OF THE ) INDUSTRIAL CUSTOMERS OF ) IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company") and, in accordance with RP 225, hereby objects to the Third Production Request of the Industrial Customers of Idaho Power dated August 6, 2009. This Objection is based on the following: IDAHO POWER COMPANY'S OBJECTION TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1 REQUEST FOR PRODUCTION NO. 42: Please provide, in electronic format if possible, all data input files used in constructing the forecast for each customer class, along with an explanation of each variable used. REQUEST FOR PRODUCTION NO. 43: Please provide the source of each input variable used in constructing the forecast. REQUEST FOR PRODUCTION NO. 44: Please provide, in electronic format if possible, all work papers used in deriving the input values used in the forecast for each customer class. REQUEST FOR PRODUCTION NO. 45: Please provide, in electronic format if possible, all formulas and algorithms used in constructing the forecast for each customer class, along with an explanation of each formula or algorithms used. REQUEST FOR PRODUCTION NO. 46: Please provide, in electronic format if possible, the output values found in the forecast for each customer class along with an explanation of each output value. OBJECTION TO REQUESTS FOR PRODUCTION NOS. 42-46: Idaho Power objects to the above-referenced four requests on the following grounds: 1. ICIP's production request is unreasonably late. It was made more than two months after the production request cutoff date of June 5, 2009, established in the Commission's Notice of Scheduling issued in this case on April 20, 2009. The Request was also made approximately three weeks after the conclusion of the technical hearing. 2. In its Request, the ICIP states, "The following questions are related to the updated economic forecast the Company wil be filing with the Commission in IDAHO POWER COMPANY'S OBJECTION TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2 August. Please provide your answers contemporaneously with that filng." Assuming that the "updated economic forecast" referred to in the Industrial Customers' requests is the annual load forecast the Company completes during the late summer or early fall each year, that load forecast is not typically filed with Commission for its review and approvaL. The 2009 annual load forecast wil be used in the preparation of the Company's Integrated Resource Plan ("IRP"), which wil be filed with the Commission by the end of the year. Idaho Power has typically distributed copies of the load forecast used to prepare the IRP to the members of its Integrated Resource Plan Advisory Council ("IRPAC") for their review and comment. Idaho Power expects it wil distribute the 2009 annual load forecast to the IRPAC participants in the 2009 IRP in the near future. As can be seen from the foregoing, in the normal course of business, the Company would not file the annual load forecast with the Commission outside of the IRP process and it is not the intention of the Company to deviate from its regular practice this year. The 2009 annual load forecast is not a part of the record in this case, is not needed for the Commission to render its decision in this case, and the Commission should not require the Company to respond to these production requests. The response to this Request was prepared by Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 18th day of August 2009. ~ BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S OBJECTION TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 18th day of August 2009 I served a true and correct copy of IDAHO POWER COMPANY'S OBJECTION TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Scott Woodbury Deputy Attorney General Idaho Public Utiities 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 Miller Snake River Alliance 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 -X Hand Delivered U.S. Mail _ Overnight Mail FAX -X Email Scott.Woodburvcæpuc.idaho.gov Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email petercærichardsonandolearv.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email dreadingcæmindspring.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email kmilercæsnakeriverallance.org Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email elocæracinelaw.net IDAHO POWER COMPANY'S OBJECTION TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Village, Ohio 44140 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email tonycæyankel.net Idaho Conservation League Betsy Bridge Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email bbridgecæwildidaho.org Northwest and Intermountain Power Producers Coalition Susan K. Ackerman 9883 NW Nottage Drive Portland, Oregon 97229 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email Susan.k.ackermancæcomcast.net Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email bmpurdy(ghotmail.com , Barton L. Kline IDAHO POWER COMPANY'S OBJECTION TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5