20110707Staff 1-5 to IPC.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECEIVED
23 n JUL - ì PM 2: I 3
KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE IN IDAHO. )
)
)
)
CASE NO. IPC-E-11-8
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorneys of
record, Donald L. Howell, II and Karl T. Klein, Deputies Attorney General, requests that Idaho
Power Company (Company; IPC) provide the following documents and information as soon as
possible, but no later than THURSDAY, JULY 28, 2011.
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
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JULY 7, 2011
person acting on its behalf may later obtain that wil augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO.1: Darel Anderson references a Moody Analytics aricle for April
2011 (see Anderson Di, pg 8, line 6). Please provide a copy of the complete aricle referenced.
REQUEST NO.2: Please provide copies of all salary surveys used by Idaho Power in
determining the general wage adjustments for 2010 and 2011, including but not limited to those
produced by the independent consulting firms of Towers Watson, Mercer, Hewitt and World at
Work.
REQUEST NO.3: Darel Anderson's direct testimony states that "A further evaluation
is conducted that compares the company's general wage adjusted compensation to compensation
provided by a specific group of peer companies comprised of similar-sized, investor-owned
utilties and other intermountain utilties. The Company also considers the salary provided by
other companies local to the State of Idaho when evaluating wages and salaries." Pg 24, lines
13-19. Please provide the list of peer companies used by the Company, including those
companies local to the State of Idaho. Please provide all information provided to Idaho Power
by any pary that pertains to wages and salaries of any company used by Idaho Power in its
evaluation.
REQUEST NO.4: Please provide a schedule in Excel format listing each employee's
title/position and employee number.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JULY 7, 2011
REQUEST NO.5: Please provide the percentage amount of the general wage increases
given to employees for each year from 2007 -2011.
DATED at Boise, Idaho, thisr~ day of July 201 1.
Technical Staff: Donn English
i:umisc:prodreq/ipcel 1.8dhkk prod req l.doc
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
,fj -¿:J(
Karl T. Klein
Deputy Attorney General
3 JULY 7, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF JULY 2011, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER, IN CASE NO. IPC-E-11-08, BY MAILING A COpy THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
DONOV AN E WALKER
JASON B WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom(iidahopower.com
dwalker(iidahopower .com
jwiliams(iidahopower .com
CBearry(iidahopower .com
myoungblood(iidahopower. com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(irichardsonandoleary.com
gre g(irichardsonandoleary. com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(iracinelaw.net
ARTHUR PERRY BRUDER
ATTORNEY -ADVISOR
US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: Arthur.bruder(ihg.doe.gov
E-MAIL ONLY:
STEVE A PORTER
US DEPT OF ENERGY
E-MAIL: steven.porter(ihg.doe.gov
GREGORYWSAID
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: gsaid(iidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(imindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(iyankeL.net
DWIGHT ETHERIDGE
EXETER ASSOCIATES
5565 STERRTT PL STE 310
COLUMBIA MD 20144
E-MAIL: detheridge(iexeterassociates.com
JOHN R HAMMOND JR
BATT FISHER PUSCH
& ALDERMAN LLP
PO BOX 1308
BOISE ID 83701
E-MAIL: jrh(ibattfisher.com
CERTIFICATE OF SERVICE
RICHARD E MALMGREN
SR ASST GENERAL COUNSEL
MICRON TECHNOLOGY INC
800 S FEDERAL WAY
BOISE ID 83716
E-MAIL: remalmgren(fmicron.com
MARY V YORK
THORV ALD A NELSON
MARK A DAVIDSON
HOLLAND & HART LLP
6800 S FIDDLERS GREEN CIR
STE 500
GREENWOOD VILLAGE CO 80111
E-MAIL: myork(fhollandhar.com
tnelson(ihollandhart.com
mdavidson(ihollandhar.com
BRADMPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmaiL.com
\~k~
SECRETARY
CERTIFICATE OF SERVICE