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Home My WebLink About20110718DOE-2-1 through DOE-2-25 to IPC.pdfIN THE MATTER OF THE APPLICATION OF ) IDAHO POWER COMPANY FOR AUTHORITY ) TO INCREASE ITS RATES AND CHARGES ) FOR ELECTRIC SERVICE TO ITS ) CUSTOMERS IN THE STATE OF IDAHO. ) ) BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION ltlliJÚ( /1 if'. 10 .... Îìi /0;4'i .... 4ftCASE NO. IPC-E-11-0811ì6::'~~/)/", 9"0"( .."ej"", Ir.. (i."; L.,-' .''.'.,"-'.//5,,;:;',;;;;/ ~"" U.S. DOE's Second Interrogatories'!Ö;;VO'~/vand Production Requests : to Idaho Power Company The United States Deparment of Energy, by and through its attorney of record, Arhur Perr Bruder, hereby requests that Idaho Power Company ("the Company" or "Idaho Power") provide the following documents and information as soon as possible, but no later than THURSDAY, AUGUST 2, 2011. As per the Commission's Rules of Procedure, responses must include the name(s) and phone number of the person(s) who prepared the document, and the name(s),job title(s), location(s) and phone number(s) of the record holder(s) and, if different, the witness( es) who can sponsor the answer at hearing if need be. These Interrogatories and Production Requests are to be considered as continuing, and the 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 constitute relevant augmentation of the documents 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 provide all Excel and electronic files on CD with formulas activated. DOE 2-1 Provide copies of all Idaho Power credit rating reports since Januar 1, 2010. DOE 2-3 Provide copies of all presentations to securities analysts by management for Idaho Power or IdaCorp since January 1,2010. Please identify the specific weights given to the various cost of equity studies in Dr. Avera's testimony. In particular, please indicate the relative weight given to his electric utilty DCF study as opposed to his other cost of equity studies, in formulating his recommended range. DOE 2-2 IDAHO POWER COMPANY CASE No. IPC-E-11-08 DOE's SECOND REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS DOE 2-4 DOE 2-5 DOE 2-6 DOE 2-7 DOE 2-8 DOE 2-9 DOE 2-10 DOE 2-11 DOE 2-12 DOE 2-13 DOE 2-14 DOE 2.15 DOE 2-16 Does Dr. Avera intend to submit a cost of equity update in this case? If so, please state when. Has Dr. Avera previously submitted cost of equity testimony for Idaho Power using a West Region electric utilty proxy group? If so: (a) Please state the last case (year, docket number) when he did so; (b) The companies comprising that Proxy Group; and (c) The reason for changing his practice to a national proxy group. Please specify the exact criteria used by Dr. Avera for eliminating proxy company DCF cost of equity results as being either too high or too low. Please specify all reasons why Dr. Avera selected Value Line as the source of the "beta" instead of using other public ally-available sources of beta. Please list all public common stock issues during the last three years by IdaCorp. In each case, please include: (a) Date of issuace; (b) Net proceeds; and (c) Expenses associated with issuance (including underwiting fees). Please describe any plans for a public stock issuance within the next three years for IdaCorp. Provide all securities research analyst reports concerning Idaho Power or IdaCorp in the Company's possession (and not already provided in this case) issued since Januar 1,2010. Per Mr. Keen, page 7, please provide copies of the information Mr. Keen relied upon when formulating his testimony that "the initial reaction by the financial community was that it seemed very low and could signal a move toward a less favorable regulatory climate in Idaho." Provide copies of all Rocky Mountain Power credit rating reports since Januar 1,2010 that Mr. Keen has reviewed. Please provide a copy of the Standard and Poor's research update of Januar 31,2008. (S. Keen, p. 13.) Please provide a copy of the Moody's publication(s) of July 8, 2009. (S. Keen, pp. 13-14.) Please provide a copy of the Moody's publication(s) of March 30, 2010. (S. Keen, pp. 14-15.) Please provide a copy of the Moody's publication(s) of March 31, 2010. (S. Keen, pp. 15-16.) 2 IDAHO POWER COMPANY CASE No. IPC-E-11-08 DOE's SECOND REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS DOE 2-17 DOE 2-18 DOE 2-19 DOE 2-20 DOE 2-21 DOE 2-22 DOE 2-23 DOE 2-24 DOE 2-25 Please provide a copy of the Standard and Poor's publication(s) of May 20,2011. (S. Keen, pp. 16-17.) Please provide examples of three "unforeseen events" that Mr. Keen is most concerned about, and explain how each of these events could adversely affect Idaho Power's credit ratings. (S. Keen, p. 17.) Please provide a copy of the Standard and Poor's publication(s) of May 9, 2011. (S. Keen, pp. 27-28.) Please provide a copy of the Standard and Poor's publication(s) of Januar 28,2008. (S. Keen, pp. 31-32.) Please explain in detail what Mr. Keen means when he states that "(i)f the Company canot generate when it is most advantageous for the system, then some of the economic value of the generation wil be lost even if the amount of total generation does not change." (S. Keen, p. 34.) Specifically, to which generation does Mr. Keen refer? Based upon Mr. Keen's understading of the Idaho Power system, when is it likely that it wil be most advantageous for the system to use the generation to which Mr. Keen refers? Likewise, when does Mr. Keen feel that it will be least advantageous for the system to use the generation to which Mr. Keen refers? What is the earliest date that Mr. Keen believes FERC may issue its decision regarding the relicensing of the Company's Hells Canyon generating facilities, and why does Mr. Keen feel that is the earliest date a decision can be expected? (S. Keen, p. 35.) Please provide a copy of the Standard and Poor's publication(s) of May 2003. (S. Keen, pp. 41-42.) Please identify the dollar amounts of debt obligation S&P and Moody's presently impute to Idaho Power for credit rating puroses for its long- term purchase power contracts. (S. Keen, pp. 40-42.) Please provide the capital investments planed by the Company for each of the years 2011 through 2013 disaggregated into production, transmission, distribution, and other plant. (S. Keen, p. 44.) 3 IDAHO POWER COMPANY CASE No. IPC-E-11-08 DOE's SECOND REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS At Washington, D.C., this 12th day of July, 2011. Arthur Perry Bruder Attorney for the United States Deparment of Energy Phone: (202) 586-3409 Fax: (202) 586-7479 Arhur.Bruder(Ðhq.doe.gov CERTIFICATE OF SERVICE i hereby certify that, this 12th day of July, 2011, I served the foregoing second production request of the United States Departent of Energy to Idaho Power Company, in Case No. IPC- 11- 08, as an attachment to an email which I transmitted to the following: Commission Staff Weldon Stutzman, DAG Randy Lobb Neil Price Idaho Public Utilties Commission 472 W. Washington St. Boise, ID 83702 Weldon.Stutzman(Ðpuc.idaho.gov Randylobb(Ðpuc.Idaho.gov Neil.Price (Ðpuc.Idaho.gov Idaho Power Company Lisa D. Nordstrom Jason B. Wiliams Donovan E. Walker Greg Said John R. Gale Idaho Power Company P.O. Box 70 Boise, Idaho 83707-0070 lnordstrom(Ðidahopower.com jwillams(Ðidahopower .com dwalker(Ðidahopower.com gsaid(Ðidahopower.com rgale(Ðidahopower .com 4 IDAHO POWER COMPANY CASE No. IPC-E-11-08 DOE's SECOND REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Community Action Partnership Association BradM. Pudy Attorney at Law 2019 N. 17th St. Boise, ID. 83702 bmpurdy(Ðhotmail.com Idaho Conservation League Benjamin 1. Otto 710 N. 6th St. Boise, ID 83701 botto(Ðidahoconservation.org Idaho Irrigation Pumpers Association Eric L. Olsen Racine, Olson, Nye, Bud & Bailey, Chartered P.O. Box 1391 201 East Center Street Pocatello, Idaho 83204-1391 elO(Ðracinelaw.net Anthony Yanel 29814 Lake Road Bay Vilage, Ohio 44140 tony(Ðyanel.net Industrial Consumers of Idaho Power Peter J. Richardson Gregory M. Adams Richardson & O'Leary PLLC 515 N. 27th St P.O. Box 7218 Boise, Idaho 83702 peter(Ðrichardsonandoleary .com greg(Ðrichardsonandoleary .com Dr. Don Reading 6070 Hil Road Boise, Idaho 83703 dreading(Ðmindspring.com 5 IDAHO POWER COMPANY CASE No. IPC-E-11-08 DOE's SECOND REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Kroger John R Hammond, Jr. Batt Fisher Pusch & Alderman, LLP U.S. Ban Plaza, 5th Floor 101 S. Capitol Boulevard, Suite 500 P.O. Box 1308 Bois, ID 83701 jrh(Ðbattfisher.com Kur J. Boehm Boehm, Kurz & Lower 36 E. Seventh St., Suite 1510 Cincinnati, OH 45202 KBohm(ÐPBKLlawfrn.com Micron Mary V. York, ISB No. 5020, Holland & Har LLP Suite 1400, U.S. Ban Plaza 101 South Capitol Boulevard P.O. Box 2527 Boise, Idaho 83701-2527 myork(Ðhollandhar.com Thorvald A. Nelson Mark A. Davidson Holland & Har LL 6800 South Fiddlers Green Circle, Ste. 500 Greenwood Vilage, CO 80111 tnelson(Ðhollandhar.com madavidson(Ðhollandhar.com Richard E. Malmgren Sr. Asst. General Counsel Micron Technology, Inc. 800 South Federal Way Boise, ID 83716 remalmgren(Ðmicron.com 6 IDAHO POWER COMPANY CASE No. IPC-E-11-08 DOE's SECOND REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Snake River Allance Ken Miler Clean Energy Program Director Boise,ID kmiler(Ðsnakeriverallance.org Arhur Perry Bruder Attorney for the United States Deparment of Energy 7