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HomeMy WebLinkAbout20110802IPC to DOE 1-1 thru 1-23(sic).pdf1'IDAr,~POR~L/ JASON B. WILLIAMS Corporate Counsel jwilliamstãidahopower.com August 2, 2011 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilties Commission 472 West Washington Street Boise, Idaho 83720 Re: Case No. IPC-E-11-08 General Rate Case Dear Ms. Jewell: An IDACORP company Enclosed for filng are an original and one (1) copy of Idaho Power Company's Response to the U.S. DOE's First Interrogatories and Production Requests to Idaho Power Company in the above matter. Also enclosed are three (3) copies of a non-confidential disk and three (3) copies of a confidential disk containing information being produced in response to the U.S. DOE's production request. The confidential disk should be handled in accordance with the Protective Agreement executed in this matter. Very truly yours,/,Jason B. Wiliams JBW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 CERTIFICATE OF ATTORNEY iOJ I AIlf; -? PM~' 23 ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURIN'G TRE .. COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCE£ÐlNG::(Hi ¡ ARE PROTECTED FROM PUBLIC INSPECTION UTIUTlt::S C:¡)fvfr;.~L~;S RECE r)~".~, Case No. IPC-E-11-08 The undersigned attorney, in accordance with RP 233, hereby certifies that the attachments being provided by the Company in response to the U.S. Department of Energy's Request No. 1-11 contain information that is a trade secret or privileged or confidential as described in Idaho Code § 9-340, et seq., and § 48-801, et seq., and as such are exempt from public inspection, examination, or copying. DATED this 2nd day of August 2011. \ LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) JASON B. WILLIAMS Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 InordstromCâidahopower.com dwalkerCâidahopower.com jwilliamsCëidahopower.com REC:E!'/ED 2ûli L,UC - 2 Pi'; L¡: 23 Attorneys for Idaho Power Company 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-11-08 IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the U.S. DOE's First Interrogatories and Production Requests to Idaho Power Company dated July 12, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST NO. 1-1: Please provide copies of all responses to requests for information submitted by other parties to Idaho Power in this docket. This is an ongoing request. RESPONSE TO REQUEST NO. 1-1: To date, Idaho Power has provided all responses to other parties' discovery requests to the U.S. Department of Energy ("DOE") and wil continue to do so. The response to this Request was prepared by Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 2 REQUEST NO. 1-2: Please provide Exhibit Nos. 28 and 29 in native format (e.g., Excel, Word) with all links and formulas intact (if applicable). (M. Larkin, p. 8.) RESPONSE TO REQUEST NO. 1-2: Please see Exhibit Nos. 28 and 29, with formulas intact, providea on the CD produced by the Company in response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Data Request No. 26. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST NO. 1-3: Please provide the workpapers referred to by Mr. Larkin on page 8, 15-16, in native format (e.g., Excel, Word) with all links and formulas intact (if applicable ). RESPONSE TO REQUEST NO. 1-3: Please see Excel file "Larkin Workpapers - Exhibits 28 and 29.xlsx" provided on the CD produced by the Company in response to the IIPA's Data Request No. 26. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 4 REQUEST NO. 1-4: Please explain what Mr. Larkin is referring to when he says "maximum demand imposed on the Company's system." (M. Larkin, pp. 10-11.) RESPONSE TO REQUEST NO. 1-4: "Maximum demand imposed on the Company's system" refers to the point at which instantaneous demand for electricity on the Company's system is at its highest. Within the context of Mr. Larkin's testimony, this refers to the highest demand placed on the various components of the Company's electrical system, from generation to the final service point. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 5 REQUEST NO. 1-5: Per Mr. Larkin, pages 10-11, "due to the hydro production capabilty of the Company, a portion of the hydro and thermal generating plant investment has historically been classified as energy-related." (a) Is it Mr. Larkin's testimony that a portion of Idaho Powets hydro and thermal generating plant investment has historically been classified as energy-related solely because of the fact that Idaho Power has hydro production capabilty? (b) How does control of hydro production capabilty support the conclusion that a portion of Idaho Power's hydro and thermal generating plant investment should be classified as energy-related? RESPONSE TO REQUEST NO. 1-5: (a) No. (b) When classifying the Company's hydro and thermal generating plant investment, "primary attention is given to whether the cost varies as a result of changes in the number of customers, changes in demand imposed by the customers, or changes in energy used by the customers." Larkin Direct Testimony, p. 10, II. 9-12. The methodology used to classify hydro and thermal generating plant investment is based on the premise that the need for hydro and thermal generating plant is driven by both customer demand and energy consumption. As stated on page 18 of Mr. Larkin's testimony, lines 21-24, Idaho Power utilized the Idaho jurisdictional load factor of 53.88 percent to determine the energy-related portion of steam and hydro production investment. This load factor indicates that, on average, the Company wil serve loads equal to 53.88 percent of the overall system peak. Within the context of cost classification, this load factor is used to determine how much of the Company's hydro IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 6 and thermal generating plant investment is driven by energy usage (average demand over time) relative to fluctuations in demand between average and maximum system loads. This methodology preferred by the Idaho Public Utilties Commission ("Commission") in previous cost-of-service studies, including the most recent approved class-of-service study (Case No. IPC-E-08-10, Order No. 30722), appropriately identifies costs as energy-related and demand-related by identifying the main drivers of investment and assigning them relative weights according to system load characteristics. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 7 REQUEST NO. 1-6: Per Mr. Larkin, page 18, "(t)he energy portion of the steam and hydro production investment has been determined by use of the Idaho jurisdictional load factor of 53.88 percent." (a) Please provide Mr. Larkin's workpapers that show the computation of the Idaho jurisdictional load factor. (b) In which Idaho Power general rate case was the Idaho jurisdictional load factor first used to classify a portion of Idaho Powets hydro and thermal generating plant investment as energy-related? (c) Please list each Idaho Power general rate case in the last twenty years where the Idaho jurisdictional load factor was used to classify a portion of Idaho Powets hydro and thermal generating plant investment as energy-related? Please also provide the Idaho jurisdictional load factor that was used in each of these cases. (d) Please provide Idaho Power's actual annual jurisdictional load factor for the last ten calendar years, 2001 through 2010, including the annual peak in megawatts, the time of the annual peak, and the annual energy in megawatt-hours. (e) Please provide Idaho Power's weather normalized annual jurisdictional load factor for the last ten calendar years, 2001 through 2010, including the weather normalized peak in megawatts and the weather normalized energy in megawatt-hours. (f) Please provide Idaho Powets annual jurisdictional load factor for the most recent 12 month period (e.g., July 2010 through June 2011), including the peak in megawatts, the time of the peak, and the energy in megawatt-hours. (g) Please provide Idaho Power's annual jurisdictional load factor for the 12 months ended July 2011, August 2011, and September 2011 when that information IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 8 becomes available, including the peak in megawatts, the time of the peak, and the energy in megawatt-hours. RESPONSE TO REQUEST NO. 1-6: (a) Please see page 49 of Mr. Larkin's workpapers provided with the Company's initial filing. (b) The Commission first supported the use of the jurisdictional load factor to classify a portion of Idaho Power's hydro and thermal generating plant as energy- related with Order No. 17856 dated February 4, 1983, in Case No. U-1006-185. (c) The below table lists each general rate case filed by the Company with the Commission in the last 20 years in which the Idaho jurisdictional load factor was used to classify a portion of Idaho Power's hydro and thermal generating plant investment as energy-related. Included in the table below is the Idaho jurisdictional load factor as filed in each case. Case Number Idaho Jurisdictional load Factor IPC-E-94-5 .6757 IPC-E-03-13 .5526 IPC-E-05-28 .5845 IPC-E-07-08 .5853 IPC-E-08-10 .5938 (d) Please see the tab labeled "Actuals" in the attached Excel workbook. Actual historical data used to calculate the jurisdictional load factor is unavailable prior to the 2003 calendar year. (e) Please see the tab labeled "Normalized" in the attached Excel workbook. Normalized historical data used to calculate the jurisdictional load factor is unavailable prior to the 2005 calendar year. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 9 (f and g)The requested information is unavailable. Jurisdictional coincident peak demand values are calculated on a historical basis following the completion of the full January through December calendar year. Therefore, jurisdictional values based on 2011 load research data will not be available until February 2012. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 10 REQUEST NO. 1-7: Per Exhibit No. 30, page 6, "(t)he base period is equivalent to a low load or off-peak time period where loads are at the lowest, normally during the nighttime hours." (a) For the summer months of June through August 2010, please list the hours Mr. Larkin typically considers to be base period hours. (b) For the non-summer months of December 2009 through February 2010, please list the hours Mr. Larkin typically considers to be base period hours. (c) For the non-summer months of September 2009 through November 2009, please list the hours Mr. Larkin typically considers to be base period hours. (d) For the non-summer months of March 2010 through May 2010, please list the hours Mr. Larkin typically considers to be base period hours. RESPONSE TO REQUEST NO. 1-7: The requested time-of-day information has not been prepared as part of the Company's 3CP/12CP class cost-of-service study. Nowhere within the study are costs functionalized, classified, or allocated on an hourly basis. The discussion of base, intermediate, and peak load time periods is included solely to ilustrate the economic dispatch of the Company's generation resources, justifying the subsequent allocation of investment in these resources. Generally speaking, hydro and coal-fired facilties are dispatched first due to their relatively low operating costs, while gas-fired facilties are operated during peak summer time periods when demand for electricity is at its highest. As a result of economic dispatch, coal and hydro facilities are typically operated on a year-round basis, while gas-fired facilties are typically operated only in the high load summer months. Consequently, demand-related hydro and coal generation investment is allocated according to a twelve coincident peak IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 11 methodology, while investment in gas-fired facilties is allocated over the sum of the three summer coincident peaks. Identifying specific hours as base, intermediate, or peak, is not utilzed in this process. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -12 REQUEST NO. 1-8: Per Exhibit No. 30, page 6, "(t)he intermediate time period represents the shoulder hours which are driven by the mid-peak loads that typically occur throughout the winter daytime and in the early morr;ing and late evening during the summer months." (a) For the summer months of June through August 2010, please list the hours Mr. Larkin typically considers to be intermediate period hours. (b) For the non-summer months of December 2009 through February 2010, please list the hours Mr. Larkin typically considers to be intermediate period hours. (c) For the non-summer months of September 2009 through November 2009, please list the hours Mr. Larkin typically considers to be intermediate period hours. (d) For the non-summer months of March 2010 through May 2010, please list the hours Mr. Larkin typically considers to be intermediate base period hours. RESPONSE TO REQUEST NO. 1-8: Please see the Company's response to the DOE's Request No. 1-7. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -13 REQUEST NO. 1-9: Per Exhibit No. 30, page 6, "(t)he peak category is driven by the peak loads that occur during summer afternoons and evenings." (a) For the summer months of June through August 2010, please list the hours Mr. Larkin typically considers to be peaking period hours. (b) Does Mr. Larkin typically consider peaking hours to exclude weekends and holidays? Please explain. RESPONSE TO REQUEST NO. 1-9: Please see the Company's response to the DOE's Request No. 1-7. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 14 REQUEST NO. 1-10: Per Exhibit No. 30, page 6, "(t)he base and intermediate loads on the Company's system are typically served by the same generation resources." (a) What does the Company mean by base loads on the Company's system? Are those loads in what the Company considers to be the base period? (b) What does the Company mean by intermediate loads on the Company's system? Are those loads in what the Company considers to be the intermediate period? Are those loads incremental to base loads? (c) To which generation resources is the Company referring? (d) Please explain how base loads on the Company's system were typically served by the same generation resources during the months of June 2010 through August 2010? (e) Please explain how intermediate loads on the Company's system were typically served by the same generation resources during the months of June 2010 through August 2010? (f) Please explain how base loads on the Company's system were actually served by the same generation resources, if they were served by the same generation resources, on each of the monthly system peak days for the months of June 2010 through August 2010, and for each hour on each of those three days? (g) Please explain how intermediate loads on the Company's system were actually served by the same generation resources, if they were served by the same generation resources, on each of the monthly system peak days for the months of June 2010 through August 2010, and for each hour on each of those three days? IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -15 (h) Please explain how base loads on the Company's system were actually served by the same generation resources, if they were served by the same generation resources, on each of the monthly system peak days for the months of December 2009 through February 2010, and for each hour on each of those three days? (i) Please explain how intermediate loads on the Company's system were actually served by the same generation resources, if they were served by the same generation resources, on each of the monthly system peak days for the months of December 2009 through February 2010, and for each hour on each of those three days? RESPONSE TO REQUEST NO. 1-10: (a) As stated on page 6 of Exhibit No. 30, "the base period is equivalent to a low load or off-peak time period where loads are at the lowest, normally during the nighttime hours." (b) As stated on page 6 of Exhibit No. 30, "the intermediate time period represents the shoulder hours which are driven by the mid-peak loads that typically occur throughout the winter daytime and in the early morning and late evening during the summer months." These loads are incremental to base loads. (c) In this context, the Company is referring to its coal and hydro generation resources. Please note that the referenced information in Exhibit No. 30 is provided to justify the Company's seasonal allocation basis for its generation resources according to the seasonal utilzation of coal, hydro, and gas-fired facilties. Hourly data is not considered when classifying, functionalizing, or allocating costs associated with generation investment. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 16 (d-i) Hourly system loads and hourly generation by resource are provided in the Company's response to the DOE's Request No. 1-11. Idaho Power has not performed the analysis requested in Request Nos. 1-10(d) through (i). The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 17 REQUEST NO. 1-11: Please provide in Excel format the following information on an hourly basis for the calendar years 2008 through 2010, for the months January 2011 through June 2011, and for the months of July 2011 through September 2011 as information becomes available: (a) Idaho Power's system loads. (b) Idaho Powets share of production from the Jim Bridger coal-fired plant. (c) Idaho Power's share of production from the Valmy coal-fired plant. (d) Idaho Power's share of production from the Boardman coal-fired plant. (e) Idaho Power's production from the Brownlee hydro plant. (f) Idaho Power's production from the Oxbow hydro plant. (g) Idaho Powets production from the Hells Canyon hydro plant. (h) Idaho Power's total hydro production from the Upper-Snake area, including the American Falls, Milner, and Shoshone Falls hydro plants. (i) Idaho Power's hydro production from the Mid-Snake area from the Swan Falls, Twin Falls, Upper Salmon A, and Upper Salmon B hydro plants. ü) Idaho Power's hydro production from the Mid-Snake area from the Bliss, C. J. Strike, and Lower Salmon hydro plants. (k) Idaho Power's total hydro production from the North Fork Payette and and (sic) South Central Idaho areas, including the Cascade, Clear Lake, Lower Malad, Thousand Springs, and Upper Malad hydro plants. (I) Idaho Power's production from the Danskin natural gas-fired combustion turbine plant. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 18 (m) Idaho Powets production from the Bennett Mountain natural gas-fired combustion turbine. (n) Idaho Power's production from the Salmon diesel-fired plant. (0) Idaho Power's wholesale market purchases booked to Account 555.1. (p) Idaho Power's purchases from qualifying facilties booked to Account 555.2. (q) Any other generation or purchases not listed above that were available to Idaho Power to meet its hourly system load for the requested time period. Please explain the source of any energy if Idaho Power responds to this request. RESPONSE TO REQUEST NO. 1-11: Please see the Excel files provided on the enclosed confidential CD. Because the Excel files are confidential and contain material, non-public information, Idaho Power is providing this information only to parties that have executed the Protective Agreement. The response to this Request was prepared under the direction of Dave Bean, Controller of Operations, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 19 REQUEST NO. 1-12: For each purchase whose cost is booked to Account 555.1, please provide in Excel format with all formulas and links intact the following by month for the calendar years 2008 through 2010, for the months January 2011 through June 2011, and for the months of July 2011 through September 2011 as information becomes available: (a) Transaction number, transaction date, duration, type (for example, firm energy), total capacity and/or energy purchased, total cost, applicable pricing mechanism ($/MW, $/MWh, or some combination), and specific prices. RESPONSE TO REQUEST NO. 1-12: Please see the attached Excel file. The response to this Request was prepared under the direction of Dave Bean, Controller of Operations, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 20 REQUEST NO. 1-13: For each purchase whose cost is booked to Account 555.2, please provide in Excel format with all formulas and links intact the following by month for the calendar years 2008 through 2010, for the months January 2011 through June 2011, and for the months of July 2011 through September 2011 as information becomes available: (a) Transaction number, transaction date, duration, type (for example, firm energy), total capacity and/or energy purchased, total cost, applicable pricing mechanism ($/MW, $/MWh, or some combination), and specific prices. RESPONSE TO REQUEST NO. 1-13: Please see the attached Excel file. The response to this Request was prepared under the direction of Dave Bean, Controller of Operations, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 21 REQUEST NO. 1-14: In Idaho Power's 2011 Integrated Resource Plan, page 28, Idaho Power states, "(w)ater storage in Brownlee Reservoir also enables the Hells Canyon projects to provide the major portion of Idaho Powets peaking and load following capability." (a) What was the output of each of the Hells Canyon projects (Brownlee, Oxbow, and Hells Canyon hydro plants) at the hour of Idaho Powets annual system peak for the years 2006 through 2010? Please also provide the date and time of the annual syste,m peaks. (b) What was the output of each of the Hells Canyon projects (Brownlee, Oxbow, and Hells Canyon hydro plants) at the hour of Idaho Power's minimum morning load on the day Idaho Power established its annual system peak for the years 2006 through 2010? Please also provide the time of the minimum morning load on those days. (c) What does Idaho Power consider to be its next most important source of peaking capabilty after the Brownlee, Oxbow, and Hells Canyon hydro plants, and why? (d) Please explain what the Company means by load following capability. (e) Please explain how Idaho Power typically utilizes its Hells Canyon projects for load following purposes during the summer months of June through August. (f) Please explain how Idaho Power typically utilzes its Hells Canyon projects for load following purposes during the winter months of December through February. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 22 (g) Please explain how Idaho Power actually used the Hells Canyon projects for load following purposes for each hour on each of the monthly system peak days for the months of June 2010 through August 2010. (h) Please explain how Idaho Power actually used the Hells Canyon projects for load following purposes for each hour on each of the monthly system peak days for the months of December 2009 through February 2010. RESPONSE TO REQUEST NO. 1-14: (a) The requested information is provided in the table below. 2006 2007 2008 2009 2010 Brownlee Generation (MW)381 404 564 384 527 Oxbow Generation (MW)191 201 214 182 200 Hells Canyon Generation (MW)264 200 323 301 355 Annual System 24-Jul-06 13-Jul-07 30-Jun-08 22-Jul-09 28-Jun-10 Peak (date and 18:00:00 16:00:00 15:00:00 20:00:00 19:00:00 hour ending) (b) The requested information is provided in the table below. 2006 2007 2008 2009 2010 Brownlee 95 76 148 40 93 Generation (MW) Oxbow 39 47 97 55 55 Generation (MW) Hells Canyon 243 159 181 224 206 Generation (MW) Minimum 24-Jul-06 13-Jul-07 30-Jun-08 22-Jul-09 28-Jun-10 Morning Load on 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 Day of Annual System Peak (date and hour ending) IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 23 (c) While the Brownlee, Oxbow, and Hells Canyon hydroelectric projects are important resources that contribute to the generation capacity necessary to serve peak loads, Idaho Power would consider its four natural gas peaking units (Danskin and Bennett Mountain projects) as equally important resources for providing capacity and meeting peak hour loads. These four units provide approximately 420 megawatts ("MW") of capacity. The major advantages of these resources are that they are dispatchable year-round on relatively short notice, they are able to provide operating reserves as well as generation, and they are located close to Idaho Powets primary load center in the Treasure Valley making them less susceptible to transmission issues. Idaho Powets demand response programs are also an important part of being able to serve peak hour load. For the summer of 2011, these programs are providing in excess of 330 MW of peak load reduction capability. While these programs have historically performed as designed, the value they provide is limited to the summer peaking season when the programs are available. (d) Load following capabilty refers to the abilty to ramp generation up or down in response to short-term changes in system load. This is accomplished through a control package, automatic generation control ("AGC"), which is only installed on certain generating units capable of operating in load following mode. (e) Hells Canyon Complex generators are equipped with AGC, and thus are capable of following load as described in the Company's response to the DOE's Request No. 1-14(d). System load during summer months typically peaks once per day. The daily minimum load is commonly around 6:00 a.m., with loads increasing steadily to their late afternoon/early evening peak. Idaho Power manages the Hells IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 24 Canyon projects such that the shape of the generation profile is similar to the system load shape, while ensuring compliance with Federal Energy Regulatory Commission ("FERC") license requirements (e.g., Hells Canyon ramping rate constraints). Thus, the Hells Canyon projects are typically utilized to follow short-term (AGC-managed) and long-term changes in load during summer months. (f) Hells Canyon Complex generators are equipped with AGC, and thus are capable of following load as described in the Company's response to the DOE's Request No. 1-14(d). System load during winter months typically peaks twice per day, once in the morning (around 7:00 a.m.) and a second peak occurring during the early evening (around 6:00 p.m.). Loads during the morning peak are commonly slightly higher than those of the evening peak. Load up ramps for both peaks are frequently quite severe (steeper than observed for summer peaks). Idaho Power manages the Hells Canyon projects such that the shape of the generation profile is similar to the system load shape (maintaining compliance with project operating constraints), although the similarity during winter months is typically less pronounced than during summer months. Thus, the Hells Canyon projects are typically utilzed to follow short- term (AGC-managed) and long-term changes in load during winter months. (g) Idaho Powets utilzation of the Hells Canyon projects for load following purposes for each hour on each of the monthly system peak days for the months of June 2010 through August 2010 closely matched the typical utilzation described in the Company's response to the DOE's Request No. 1-14(e). (h) Idaho Powets utilization of the Hells Canyon projects for load following purposes for each hour on each of the monthly system peak days for the months of IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 25 December 2009 through February 2010 closely matched the typical utilization described in the Company's response to the DOE's Request No. 1-14(f). The response to this Request was prepared by M. Mark Stokes, Manager, Power Supply Planning, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 26 REQUEST NO. 1-16 (sicl: In Idaho Powets 2011 Integrated Resource Plan, page 31, Idaho Power states, "(t)he Danskin plant operates as needed to support system load" and "(t)he Bennett Mountain plant also operates as needed to support system load." (a) What does the Company mean by "operates as needed to support system load"? (b) What is the load following capabilty of those combustion turbines, and to what extent does Idaho Power use those combustion turbines for load following? Using the month of July 2010 as an example, provide specific examples of hours in which Idaho Power used these combustion turbines for load following purposes. (c) What are the input parameters that are used by Idaho Power in its production simulation modeling for the 179 megawatt Siemens 501 F combustion turbine at the Danskin plant? In particular, what is Idaho Powets assumed minimum loading on this unit for production simulation purposes. (d) What are the input parameters that are used by Idaho Power in its production simulation modeling for the two 46 megawatt Siemens-Westinghouse W251B12A combustion turbines at the Danskin plant? In particular, what is Idaho Powets assumed minimum loading on each of these units for production simulation purposes. (e) What are the input parameters that are used by Idaho Power in its production simulation modeling for the 173 megawatt Siemens-Westinghouse 501 F combustion turbine at the Bennett Mountain plant? In particular, what is Idaho Power's assumed minimum loading on this unit for production simulation purposes. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 27 RESPONSE TO REQUEST NO. 1-16(sicl: (a) The operation of these plants is driven by the need to meet system load during peak load periods. (b) The combustion turbines of the Danskin and Bennett Mountain plants are not equipped with automatic generation control, and, consequently, are not used for load following as described in the Company's response to the DOE's Request No. 1- 14(d). (c) The input parameters used in the AURORA model for the Company's peaking plants include heat rates, generation capacities, and natural gas prices. Idaho Power believes generation from these peaking resources should be available when needed; therefore, the restrictions traditionally placed on base load generation resources (Le., forced outage rates, maintenance schedules, and minimum capacities) are not applied to these peaking resources. The maximum modeled capacity is the nameplate rating of each unit and the minimum loading levels are set at 0 MW. (d) Please refer to the Company's response to the DOE's Request No. 1- 16(c). (e) Please refer to the Company's Response to the DOE's Request No. 1- 16(c). The response to this Request was prepared by M. Mark Stokes, Manager, Power Supply Planning, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 28 REQUEST NO. 1-17(sicJ: Please answer the following regarding Idaho Powets share of the Jim Bridger coal-fired plant. (a) What is the maximum summer capacity associated with Idaho Powets share of each of the four units at this plant? (b) How does Idaho Power schedule its share of the output from the four units at the Jim Bridger plant? (c) How does Idaho Power typically use its share of the output from the four units at the Jim Bridger plant to meet peak loads during the summer months of June through August? (d) How does Idaho Power typically use its share of the output from the four units at the Jim Bridger plant to meet peak loads during the winter months of December through February (e) How does Idaho Power typically use its share of the output from the four units at the Jim Bridger plant for load following purposes during summer and winter months? (f) What flexibility does Idaho Power have to ramp up or down its share of the output from the four units at the Jim Bridger plant? (g) Please list when each of the Jim Bridger units was off-line for scheduled maintenance for the period January 2008 through the present. (h) Please list when each of the Jim Bridger units is scheduled to be off-line for maintenance for the period from the present through 2012. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 29 RESPONSE TO REQUEST NO. 1-17(sic)(a): The maximum summer capacity associated with Idaho Powets share of each of the Jim Bridger units is: Unit 1 -177.0 MW Unit 2 -175.7 MW Unit 3 -176.7 MW Unit 4 -176.7 MW The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-17(sic)(b): Idaho Power schedules its share of the output from the four units at the Jim Bridger plant as dynamic interchange. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-17(sicJ(c): Idaho Power typically schedules its share of the output from the four units at the Jim Bridger plant at full generating capability. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-17(sic)(d): Idaho Power typically schedules its share of the output from the four units at the Jim Bridger plant at full generating capabilty. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 30 RESPONSE TO REQUEST NO. 1-17£sicJ(e): Idaho Power typically schedules its share of the output from the four units at the Jim Bridger plant at full generating capability. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-17£sicJ(fl: Idaho Power typically has the flexibilty to ramp its share of the output from the four units at the Jim Bridger plant up to 16 MW up or down every 10 minutes for each unit available. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-17£siclCg): The Jim Bridger units were off-line for scheduled maintenance for the period January 2008 through the present for the following dates: Unit 1 03/19/2008 01 :34 to 11/06/2008 22: 15 to 11/13/2008 00:00 to 11/14/2008 12:00 to 04/14/200901 :56 to 12/17/200907:04 to 03/27/201002:43 to 06/27/201003:00 to 08/11/201002:01 to 09/23/2010 05:55 to 03/08/2011 03:00 to 03/22/200805:35 11/13/200800:00 11/14/2008 12:00 11/15/2008 02:30 04/17/200903:51 12/17/200912:13 06/07/201002:43 06/30/2010 01 :33 08/12/201019:14 09/30/2010 17:48 03/09/2011 03:01 IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 31 Unit 2 OS/24/2008 01 :52 to OS/27/2008 11 :48 04/17/2009 23:24 to 06/13/2009 00:00 06/13/2009 00:00 to 06/14/2009 00:00 06/14/2009 00:00 to 06/14/2009 17:00 06/14/2009 17:00 to 06/17/200902:43 06/17/200902:43 to 06/17/2009 19:00 06/17/2009 19:00 to 06/19/2009 09:00 06/19/2009 09:00 to 06/20/2009 16:31 06/21/2009 16:42 to 06/21/2009 17:42 06/21/2009 17:42 to 06/22/2009 15:00 07/04/200902:59 to 07/07/2009 00:00 07/07/2009 00:00 to 07/08/2009 00:20 10/10/200902:57 to 10/10/2009 04:39 12/11/200907:02 to 12/11/200921:09 03/16/201001:14 to 03/19/2010 01: 1 0 03/19/201001:10 to 03/19/2010 10:30 04/15/2011 00:56 to 04/19/2011 00:00 04/19/2011 00:00 to 04/22/2011 00:00 04/19/2011 00:00 to 04/22/2011 00:00 04/22/2011 00:00 to 04/24/2011 07:39 Unit 3 03/23/2008 03: 12 to 03/26/2008 18:39 11/22/2008 02:03 to 11/24/2008 03:47 04/04/2009 01: 14 to 04/09/2009 22: 18 10/01/200902:30 to 10/03/2009 22:48 10/19/2010 11 :00 to 10/20/2010 10:39 04/30/2011 00:06 to 06/25/2011 00:06 06/25/2011 00:06 to 06/27/2011 16:00 06/27/2011 16:00 to 06/30/2011 01 :00 06/30/2011 01 :00 to 07/01/2011 13:16 07/05/2011 10:00 to 07/05/2011 22:40 IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 32 Unit4 03/29/2008 01 :46 to 06/02/200801 :46 to 06/06/2008 00:00 to 06/08/2008 13:58 to 06/08/2008 18:47 to 06/10/2008 17:41 to 10/27/2008 03: 15 to 10/30/2008 02:00 to 04/08/2009 17:46 to 12/08/2009 23:48 to 12/09/2009 01 :00 to 12/10/2009 06:54 to 03/20/2010 00:02 to 03/23/2010 08:00 to 03/24/2010 16:00 to 03/25/2010 15:00 to 03/25/2010 22:00 to 03/26/2010 02:00 to 10/09/201006:13 to 10/09/201006:13 to 10/09/201006:13 to 10/09/201006:13 to 10/10/2010 12:00 to 10/13/201009:30 to 11/17/201012:00 to 04/23/2011 21 :17 to 04/23/2011 21 :17 to 06/02/200801 :46 06/06/200800:00 06/08/2008 13: 14 06/08/2008 18:33 06/08/2008 19:59 06/10/2008 18:30 10/30/2008 02:00 11/06/2008 14:42 04/13/2009 02:06 12/09/2009 01 :00 12/09/2009 04:42 12/10/200921:24 03/23/2010 08:00 03/24/2010 16:00 03/25/2010 15:00 03/25/2010 22:00 03/26/2010 02:00 03/26/2010 11 :05 10/13/2010 09:30 10/12/2010 01 :30 10/11/2010 10:00 10/11/2010 12:00 10/12/2010 15:00 10/17/201009:12 11/18/2010 15:42 04/28/2011 23:02 04/28/2011 23:02 The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 33 RESPONSE TO REQUEST NO. 1-17(sicKh): The dates when each of the Jim Bridger units is scheduled to be off-line for maintenance for the period from the present through 2012 is as follows: Unit Dates 1 3/12 -3/15 2012 2 3/28 - 3/31 2012 3 4/1 - 4/4 2012 4 4/14 - 5/282012 The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 34 REQUEST NO. 1-18(sicJ: Please answer the following regarding Idaho Power's share of the Valmy coal-fired plant. (a) What is the maximum summer capacity associated with Idaho Powets share of each of the two units at this plant? (b) How does Idaho Power schedule its share of the output from the two units at the Valmy plant? (c) How does Idaho Power typically use its share of the output from the two units at the Valmy plant to meet peak loads during the summer months of June through August? (d) How does Idaho Power typically use its share of the output from the two units at the Valmy plant to meet peak loads during the winter months of December through February (e) How does Idaho Power typically use its share of the output from the two units at the Valmy plant for load following purposes during summer and winter months? (f) What flexibilty does Idaho Power have to ramp up or down its share of the output from the two units at the Valmy plant? (g) Please list when each of the Valmy units was off-line for scheduled maintenance for the period January 2008 through the present. (h) Please list when each of the Valmy units is scheduled to be off-line for maintenance for the period from the present through 2012. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 35 RESPONSE TO REQUEST NO. 1-18(sicJ(a): The maximum summer capacity associated with Idaho Power's share of each of the North Valmy units is: Unit 1 - 121.7MW Unit 2 - 136.5MW The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-18(sicJ(b): Idaho Power schedules its share of the output from the two units at the Valmy plant as static interchange. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-18(sicJ(c): Idaho Power typically schedules its share of the output from the two units at the Valmy plant at full generating capability. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-18(sicJ(d): Idaho Power typically schedules its share of the output from the two units at the Valmy plant at full generating capabilty. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-18(sicJ(e): Idaho Power typically schedules its share of the output from the two units at the Valmy plant at full generating capability. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 36 The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-18(sicUfl: Idaho Power typically has the flexibilty to ramp its share of the output from the two units at the Valmy plant up to 25 MW up or down every 60 minutes for each unit available. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-18(sic)(g): The North Valmy units were off- line for scheduled maintenance for the period January 2008 through the present for the following dates: Unit 1 02/29/2008 06:41 04/09/2008 00: 14 10/18/200809:51 01/08/2009 22:55 01/14/200900:26 02/05/2009 23:20 04/17/2009 00:00 01/09/2010 01 :48 OS/23/2010 01 :20 01/19/2011 23:20 04/08/2011 23:59 to 02/29/2008 10: 15 to 05/08/200823:24 to 10/18/2008 15:45 to 01/09/200923:02 to 01/18/2009 18:59 to 02/12/2009 23:09 to 04/25/200900:00 to 01/11/201012:00 to 05/30/2010 04:41 to 01/23/2011 22:05 to 06/18/201114:30 IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 37 Unit 2 03/10/2008 12:00 03/30/200823:30 04/25/200821 :52 05/11/2008 11 :44 08/06/2008 01 :09 04/14/2009 14:42 05/23/200900:51 07/07/200923:19 09/19/2009 01 :28 10/22/2009 23:26 03/19/201023:50 06/10/201023:51 06/29/2010 03:00 11/02/201007:51 to 03/18/2008 11 :44 to 04/03/2008 11 :41 to 04/29/2008 02:20 to 05/14/2008 05:44 to 08/07/200806:05 to 04/14/2009 20:00 to 06/01/200900:00 to 07/08/2009 09:09 to 09/26/200923:36 to 10/25/2009 21 :23 to 05/15/2010 00:00 to 06/15/2010 18:00 to 06/29/201004:19 to 11/04/201007:51 The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-18(sic)(h): The following is a list when each of the North Valmy units is scheduled to be off-line for maintenance for the period from the present through 2012. Unit #1 Unit #2 4/7/12 0000 hours to 4/15/12 0000 hours 4/21/120000 hours to 4/29/12 0000 hours The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 38 REQUEST NO. 1-19(sicl: Please answer the following regarding Idaho Powets share of the Boardman coal-fired plant. (a) What is the maximum summer capacity associated with Idaho Powets share of this plant? (b) How does Idaho Power schedule its share of the output from the Boardman plant? (c) How does .Idaho Power typically use its share of the output from the Boardman plant to meet peak loads during the summer months of June through August? (d) How does Idaho Power typically use its share of the output from the Boardman plant to meet peak loads during the winter months of December through February? (e) How does Idaho Power typically use its share of the output from the Boardman plant for load following purposes during summer and winter months? (f) What flexibility does Idaho Power have to ramp up or down its share of the output from the Boardman plant? (g) Please list when the Boardman plants was off-line for scheduled maintenance for the period January 2008 through the present. (h) Please list when the Boardman plant is scheduled to be off-line for maintenance for the period from the present through 2012. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 39 RESPONSE TO REQUEST NO. 1-19(sicH.: The maximum summer capacity associated with Idaho Power's share of the Boardman Plant is 58.6 MW. The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-19(sicJ(b): Idaho Power schedules its share of the output of the Boardman plant as dynamic interchange. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-19(siclCc): Idaho Power typically schedules its share of the output from the Boardman plant at full generating capabilty. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-19(sicJ(d): Idaho Power typically schedules its share of the output from the Boardman plant at full generating capabilty. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-19(siclCe): Idaho Power typically schedules its share of the output from the Boardman plant at full generating capability. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 40 The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-19(sicUl): Idaho Power typically has the flexibility to ramp its share of the output from the Boardman plant up to 30 MW up or down every 10 minutes. The response to this Request was prepared by John Anderson, Power Supply Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. RESPONSE TO REQUEST NO. 1-19(sic)(g): The Boardman Plant was off-line for scheduled maintenance for the period January 2008 through the present for the following dates: 3/1/2008 3:28 to 4/26/20080:00 to 6/16/2008 0:34 to 7/412008 1 :37 to 9/19/200922:20 to 4/3/200922:57 to 6/20/2009 18:30 to 6/28/2009 3: 14 to 5/1/2010 1 :40 to 4/15/2011 23:42 to 3/2/2008 13:40 5/26/20080:00 6/16/2008 1 :40 7/712008 10:10 9/22/20092:17 6/20/2009 13:01 6/20/2009 21 :20 8/3/20097:02 5/29/2010 13:49 6/6/2011 0:00 The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 41 RESPONSE TO REQUEST NO. 1-19(siclCh): The following is when the Boardman Plant is scheduled to be off-line for maintenance for the period from the present through 2012: 4/21/120000 hours to 5/20/12 24:00 hours The response to this Request was prepared by John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 42 REQUEST NO. 1-20(sicJ: In Idaho Powets 2011 Integrated Resource Plan, page 67, Idaho Power states, "(m)onthly average generation for Idaho Powets hydroelectric resources is calculated with a generation model developed internally by Idaho Power. The generation model treats the projects upstream of the Hells Canyon Complex as run-of-river plants. The generation model mathematically manages reservoir storage in the Hells Canyon Complex to meet the remaining system load, while adhering to the operating constraints on the Brownlee Reservoir and outfows from the Hells Canyon project. For peak-hour analysis, a review of historical operations was performed to yield relationships between monthly energy production and achieved one-hour peak generation. The projected peak-hour capabilties for the IRP were derived to be consistent with the observed relationships." (a) Please provide a copy of the referenced model in native format (e.g., Excel) with all links and formulas intact (if applicable)? (b) Please explain how the model mathematically manages reservoir storage in the Hells Canyon Complex to meet remaining system load? (c) Please explain specifically what is meant by remaining system load? (d) Please provide the historical data that was reviewed and the calculations that were preformed to yield the relationships between monthly energy production and achieved one-hour peak generation, and please provide this information electronically in native format (e.g., Excel) with all links and formulas intact? IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 43 RESPONSE TO REQUEST NO.1-20(sicJ: (a) The referenced generation model, PDR-580, is not an Excel spreadsheet. Rather, it is a proprietary Java-coded program consisting of over 40 class files. The Company wil make available for review the PDR-580 model at its corporate headquarters. Please contact Doug Jones at (208) 388-2615 or Camila Victoria at (208) 388-5821 to arrange a time to review the requested materiaL. (b) The referenced model, PDR-580, executes on a monthly time-step. Its results are expressed in terms of average monthly energy output for each hydroelectric plant. Results are not calculated on a generating unit basis, but rather in aggregate for the entire plant. The primary inputs to PDR-580 include the following: · Monthly average inflow for each hydroelectric project in the Idaho Power system, except Oxbow and Hells Canyon Reservoirs (the reason for this exception is described below). · Monthly average hydraulic capacity of each hydroelectric project in Idaho Powets system. This is the combined maximum rate of water which can be accommodated for flow through a given plant's turbines. Note that for select months this capacity is adjusted downward to reflect reduced availability associated' with maintenance. · Operating constraints, in the form of upper and lower bounds, on month-end headwater elevations at Brownlee Reservoir. · Monthly average retail demand (load). IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 44 · Monthly average energy output from non-hydro resources (e.g., thermal plants), aggregate output from spring flow driven hydroelectric plants in the Hagerman, Idaho, area, and contractual off-system purchases. The PDR-580 model calculates monthly average energy output through use of a "k-factor," which relates the rate of flow through a hydroelectric plant to energy output. A k-factor is typically expressed in terms of kilowatts of electricity per unit of water flow (in cubic feet/second) through the plant. The PDR-580 model is designed to meet total electrical demand using resources made available to it, where those resources are first considered to include external energy sources (Le., non-hydro, spring flow hydro, off- system purchases) and calculated energy output at run-of-river type hydroelectric projects above Brownlee Reservoir. Remaining electrical demand is then met through use of storage at Brownlee Reservoir, while honoring user-specified constraints imposed on Brownlee's headwater elevation. Thus, the PDR-580 model computes monthly average outflow from Brownlee Reservoir, which may (and typically does) differ from input monthly average inflow, reflecting Brownlee's capability as a large reservoir having seasonally allocated storage. Monthly average Brownlee outflow is then directly routed downstream by the program to Oxbow and Hells Canyon Reservoirs, with no adjustment for storage effects because of the relatively small size of these downstream reservoirs and existing operational and FERC license constraints. Remaining electrical demand after accounting for Hells Canyon Complex (Brownlee, Oxbow, and Hells Canyon dams) generation is designated as deficit. Conversely, generation (and contractual purchases) in excess of demand is surplus. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 45 (c) The portion of the monthly average load assumed for the Integrated Resource Plan ("IRP") modeling that is not met by generation from Idaho Powets coal generators, power purchase contracts (including Public Utilty and Regulatory and Policies Act of 1978 and Power Purchase Agreements), and its hydroelectric generators upstream of the Hells Canyon Complex is defined as remaining system load in the context of the referenced discussion from page 67 of the IRP. (d) Please see the attached Excel workbook. The response to this Request was prepared by Philp B. DeVol, Power Supply Planning Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 46 REQUEST NO. 1-21(sicJ: Per Mr. Larkin, page 3, "(t)he 2011 test year customer and kWh sales forecast is based upon the Sales and Load Forecast prepared for the 2011 Integrated Resource Plan." Please. answer the following regarding the load forecast used in Idaho Power's 2011 Integrated Resource Plan. (a) Was that forecast prepared on or about August 2010? (b) What were the last available actual monthly sales used in preparing that forecast? RESPONSE TO REQUEST NO. 1-21 (sicJ: (a) Yes. The sales and load forecast was completed on August 25,2010. (b) The last available actual monthly sales used in preparing the forecast were the July 2010 booked energy figures. The response to this Request was prepared at the direction of Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 47 REQUEST NO. 1-22(sicJ: Per Mr. Larkin, pages 6-7, "(h)istorical data from the most currently available four calendar years is used to derive an average load factor by month for each rate class. These average load factors are then applied to monthly kWh sales figures to determine total forecasted biling demand and BLC by class for each month of the test period." (a) Please provide the historical data and the calculations that were preformed to derive average load factors by month for each rate class, and please provide this information electronically in native format (e.g., Excel) with all links and formulas intact? (b) Why did Idaho Power elect to use a four-year average? RESPONSE TO REQUEST NO. 1-22(sicJ: (a) Please see the Excel file provided on the CD produced by the Company in response to the IIPA's Data Request No. 15. (b) The load factor calculation is designed to achieve a stable and appropriate factor for revenue forecasting purposes. A 48-month historical basis for calculation is designed to account for inherent variabilty in the energy and peak relationship within each month for each of the separate rate classes. This variability can be caused by many factors, such as plant shutdowns and weather extremes that can impact historical data. Statistical testing supports the appropriateness of the 48 monthly factors. An analysis of monthly variance across the four years shows that there is no statistically significant difference between the years at the .99 confidence leveL. The series exhibits IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 48 no bias and serves to mute exogenous influences that are undesirable for valid revenue forecasting purposes. The response to this Request was prepared at the direction of Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 49 REQUEST NO. 1-23(sicl: Please provide Exhibit Nos. 31 through 37 in native format (e.g., Excel) with all links and formulas intact (if applicable). (M. Larkin, pp. 26- 27.) RESPONSE TO REQUEST NO. 1-23~: Please see Exhibit Nos. 31 through 37, with formulas intact, provided on the CD produced by the Company in response to the IIPA's Data Request No. 26. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 2nd day of August 2011. .. /' " IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 50 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 2nd day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Don.HoweIlCëpuc.idaho.gov Karl T. Klein Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Karl.KleinCëpuc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email peterCërichardsonandoleary.com gregCërichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email dreadingCëmindspring.com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED 201 East Center P.O. Box 1391 Pocatello, Idaho 83204-1391 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email eloCëracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 51 Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email tonYCëyankel.net Kroger Co. Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email kboehmCëBKLlawfirm.com jrhCëbattfisher.com Kevin Higgins Energy Strategies, LLC 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email khigginsCëenergystrat.com Micron Technology, Inc. MaryV. York HOLLAND & HART LLP 101 South Capital Boulevard, Suite 1400 Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email myorkCëhollandhart.com tnelsonCëholland hart. com madavidsonCëhollandhart.com fschmidtCëhollandhart. com Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email remalmgrenCëmicron.com Department of Energy Arthur Perry Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Arthur.bruderCëhq.doe.gov Steven. po rterCëhq .doe. gov IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 52 Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Place, Suite 310 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email detheridgeCëexeterassociates.com Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email bmpurdYCëhotmail.com Idaho Conservation league Benjamin J. Otto Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email bottoCëidahoconservation.org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email kmilerCësnakeriverallance.org NW Energy Coalition Nancy Hirsh, Policy Director NW Energy Coalition 811 First Avenue, Suite 305 Seattle, Washington 98104 Hand Delivered U.S. Mail _ Overnight MailFAX 1. -2 Email nancYCënwenergY;.rg ¿;w~ IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIRST INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 53