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HomeMy WebLinkAbout20110802IPC to DOE 2-1 thru 2-25.pdfJASON B. WILLIAMS Corporate Counsel iwilliamscæidahopower.com REGE '1IEW~POR~ An IDACORP Company 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: Enclosed for filng are an original and one (1) copy of Idaho Power Company's Response to the U.S. DOE's Second Interrogatories and Production Requests to Idaho Power Company in the above matter. Also enclosed are three (3) copies of a non-confidential disk containing information being produced in response to the U.S. DOE's second production request. \ Very truly yours,,W~'" :: == JBW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 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 jwilliamsCâidahopower.com R. r:rr-I\/Ff)',-'~'i.I" ,-" 2m i PiUG -2 P¡,~ 4= 22 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 SECOND 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 Second 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST NO. 2.1: Provide copies of all Idaho Power credit rating reports since January 1, 2010. RESPONSE TO REQUEST NO. 2.1: All credit rating reports from Standard and Poots and Moody's from January 1, 2010, to present are provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHQ POWER COMPANY - 2 REQUEST NO. 2-2: Provide copies of all presentations to securities analysts by management for Idaho Power or IdaCorp since January 1, 2010. RESPONSE TO REQUEST NO. 2-2: Copies of all presentations made by the management of Idaho Power and IDACORP since January 1, 2010, are provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST NO. 2-3: 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 utility DCF study as opposed to his other cost of equity studies, in formulating his recommended range. RESPONSE TO REQUEST NO. 2-3: Dr. Avera did not apply specific mathematical weights or a formulaic approach in determining his recommended return on equity ("ROE"). Rather, he considered the results of all of the quantitative methods discussed in his testimony and evaluated a fair ROE based on his professional judgment and his assessment of the relative strengths and weaknesses of the alternative methods, while conservatively giving less emphasis to the upper- and lower- most boundaries of the range of results. The response to this Request was prepared under the direction of Wiliam E. Avera, FINCAP, Inc., in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 4 REQUEST NO. 2.4: Does Dr. Avera intend to submit a cost of equity update in this case? If so, please state when. RESPONSE TO REQUEST NO. 2.4: Dr. Avera has no specific plans to update the cost of equity analyses supporting his testimony in this case. The response to this Request was prepared under the direction of Wiliam E. Avera, FINCAP, Inc., in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 5 REQUEST NO. 2-5: 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. RESPONSE TO REQUEST NO. 2-5: Yes. (a) Dr. Avera submitted cost of equity testimony for Idaho Power using a West Region electric utilty proxy group in 2005, Case No. IPC-E-05-28. (b) The companies comprising that Proxy Group are Black Hils Corporation; Edison International; Hawaiian Electric Industries; IDACORP, Inc.; MDU Resources Group; PNM Resources Group; Pinnacle West Capital Corporation; Puget Energy, Inc.; Sempra Energy; and Xcel Energy. (c) Following the energy crisis of 2000-2001, investors were intently focused on the risk exposures associated with the western region, and the sensitivity to related geographic risks was highlighted by Ms. Marsha Smith, a Commissioner with the Idaho Public Utilities Commission ("Commission"), as justifying a regional approach. (Idaho Commissioner Meets with ELCON, ELCON Report (No.2, 2003) at 7). However, since that time, concerns over the western energy crisis have waned. While there can be instances where geography can serve as a reasonable basis to define a proxy group, Dr. Avera determined that there is no adequate rationale for Idaho Power in this case. A copy of the above-referenced source document is provided on the enclosed CD. The response to this Request was prepared under the direction of Wiliam E. Avera, FINCAP, Inc., in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 6 REQUEST NO. 2-6: 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. RESPONSE TO REQUEST NO. 2-6: The rationale used by Dr. Avera to eliminate low- and high-end outliers was fully articulated in his direct testimony at pp. 49-54. The response to this Request was prepared under the direction of Wiliam E. Avera, FINCAP, Inc., in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 7 REQUEST NO. 2-7: Please specify all reasons why Dr. Avera selected Value Line as the source of the "beta" instead of using other publically-available sources of beta. RESPONSE TO REQUEST NO. 2-7: Support for Dr. Avera's reliance on the beta values published by Value Line was provided in his direct testimony at pp. 57-58. The response to this Request was prepared under the direction of Wiliam E. Avera, FINCAP, Inc., in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 8 REQUEST NO. 2.8: Please list all public common stock issues during the last three years by IdaCorp. In each case, please include: (a) Date of issuance; (b) Net proceeds; and (c) Expenses associated with issuance (including underwriting fees). RESPONSE TO REQUEST NO. 2.8: Please see the Excel file provided on the enclosed CD. The response to this Request was prepared by Steven Keen, Vice President Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 9 REQUEST NO. 2.9: Please describe any plans for a public stock issuance within the next three years for IdaCorp. RESPONSE TO REQUEST NO. 2-9: IDACORP does not issue forward looking information in regard to public stock issuances. The Company has stated its intent to keep the debt to equity ratio near its current level of approximately 50/50. Actual financial results, actual levels of cash expenditures, and prevailing market conditions wil drive the ultimate combination of new stock and debt issuances. The response to this Request was prepared by Steven Keen, Vice President Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 10 REQUEST NO. 2.10: 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 January 1,2010. RESPONSE TO REQUEST NO. 2.10: Copies of the research reports from security analysts since January 1, 2010, are provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 11 REQUEST NO. 2-11: 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." RESPONSE TO REQUEST NO. 2-11: On multiple occasions in 2011 during verbal discussions, equity analysts covering utilties in the northwestern part of the U.S. had discussions with Mr. Keen and the Company team that handles investor relations. Those analysts have pointed to the 9.9 percent allowed ROE that was granted to Rocky Mountain Power in its recent Idaho Commission order and asked questions around the Company's concern with that level of allowed return below 10 percent, if it was perceived as any type of shift in supportive regulatory treatment, and if the Company can be rightly differentiated from Rocky Mountain Power. Mr. Keen's direct testimony speaks to the belief that there are explainable differences between Idaho Power and Rocky Mountain Power. The response to this Request was prepared by Steve Keen, Vice President Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 12 REQUEST NO. 2.12: Provide copies of all Rocky Mountain Power credit rating reports since January 1, 2010 that Mr. Keen has reviewed. RESPONSE TO REQUEST NO. 2.12: Mr. Keen does not receive Rocky Mountain Powets ratings reports. However, the Standard & Poots report referred to was submitted as an exhibit in Case No. PAC-E-10-07 by Mr. Bruce Wiliams of Rocky Mountain Power, which was reviewed in preparation of Mr. Keen's testimony. A copy of the referenced Standard's & Poots report is provided on the enclosed CD. The response to this Request was prepared by Steven Keen, Vice President Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -13 REQUEST NO. 2.13: Please provide a copy of the Standard and Poor's research update of January 31,2008. (S. Keen, p. 13.) RESPONSE TO REQUEST NO. 2.13: A copy of the requested report is provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 14 REQUEST NO. 2.14: Please provide a copy of the Moody's publication(s) of July 8,2009. (S. Keen, pp. 13-14.) RESPONSE TO REQUEST NO. 2.14: A copy of the requested report is provided on the enclosed CD. The response to this Request was prepared by Larr Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -15 REQUEST NO. 2.15: Please provide a copy of the Moody's publication(s) of March 30, 2010. (S. Keen, pp. 14-15.) RESPONSE TO REQUEST NO. 2.15: A copy of the requested report is provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 16 REQUEST NO. 2.16: Please provide a copy of the Moody's publication(s) of March 31, 2010. (S. Keen, pp. 15-16.) RESPONSE TO REQUEST NO. 2.16: A copy of the requested report is provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 17 REQUEST NO. 2.17: Please provide a copy of the Standard and Poots publication(s) of May 20, 2011. (S. Keen, pp.16-17.) RESPONSE TO REQUEST NO. 2.17: A copy of the requested report is provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 18 REQUEST NO. 2.18: 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.) RESPONSE TO REQUEST NO. 2.18: Mr. Keen's comments regarding unforeseen events were meant to point out that risks exist that could have potential financial impacts on the Company. Idaho Power plans for many things but does not know and cannot predict every possible risk the Company is exposed to at any given time. It is also difficult to point to a risk that has not yet been anticipated or is unforeseen. Once it is recognized, it is no longer unforeseen. Please see the risk factor sections identified in the Company's 10-K for an example of this phenomena. In 2006, the risk factors identified amounted to roughly two and one-half pages of information. (Those factors, beginning on page 10, are available on-line via the following link: http://ww.idacorpinc.com/pdfs/10k/10k2006.pdf).ln 2010, that same section had grown to approximately seven and one half pages. (Those factors, beginning on page 17, are available on-line via the following link: http://ww.idacorpinc.com/pdfs/10K/10k2010a.pdf). The financial crisis in 2008 and 2009 certainly elevated the awareness of new risks and possibly increased the general focus on risk. The risk factors themselves are not expected but could occur; there were more than three in both 2006 and 2010. In that four year time span, more than three new or expanded risks evolved. The point of Mr. Keen's direct testimony is that events can occur that are not anticipated. When a company is viewed as less credit worthy, the impacts of those events can have a more detrimental effect. Mr. Keen used the example of the IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 19 commercial paper ("CP") market as an ilustration. After the financial crisis, the same event had different impacts on CP issuers depending on their credit standing at the time. The three levels of CP issuer under the Standard & Poots system are categorized as A-1, A-2, and A-3. During and immediately after the large financial disruption in 2008, the A-3 CP issuers were essentially unable to issue CP at alL. The A-2 level that Idaho Power was and is currently included in had difficulty issuing CP for maturities of any length (at times limited to terms of only over a single night) and rates that were paid escalated significantly. The A-1 issuers saw the least amount of impact. The response to this Request was prepared by Steven Keen, Vice President, Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 20 REQUEST NO. 2.19: Please provide a copy of the Standard and Poots publication(s) of May 9,2011. (S. Keen, pp. 27-28.) RESPONSE TO REQUEST NO. 2.19: A copy of the requested report is provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 21 REQUEST NO. 2.20: Please provide a copy of the Standard and Poor's publication(s) of January 28,2008. (S. Keen, pp. 31-32.) RESPONSE TO REQUEST NO. 2.20: A copy of the requested report is provided on the enclosed CD. The response to this Request was prepared by Larr Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 22 REQUEST NO. 2.21: Please explain in detail what Mr. Keen means when he states that "(ilf the Company cannot 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 understanding of the Idaho Power system, when is it likely that it will be most advantageous for the system to use the generation to which Mr. Keen refers? Likewise, when does Mr. Keen feel that it wil be least advantageous for the system to use the generation to which Mr. Keen refers? RESPONSE TO REQUEST NO. 2.21: Mr. Keen's comments were made primarily in regard to relicensing efforts for the Hells Canyon project. As water usage for energy is looked at in the relicensing process, it competes with concerns over habitat, water quality, endangered species, and agricultural and recreational interests, to name a few. It is likely that the relicensing process wil deliver more restrictions on how and when those projects operate. Those additional restrictions could have negative financial impacts. Potential outcomes and requirements of the relicensing process may likely reduce operational flexibilty. Less flexibilty means Idaho Powets plants may not be able to generate at capacity when they are most needed or when they are most economicaL. The Company has also disclosed the impact of additional costs and potential operating restrictions on page 22 of IDACORP's 2010 10-K report and on pages 14 and 15 of the Company's 2011 Integrated Resource Plan. The report and Integrated Resource Plan can be accessed via the following links: http://ww.idacorpinc.com/pdfs/10K/10k2010a.pdf and http://ww.idahopower.com/pdfs/AboutUs/PlanningForFuture/irp/2011/2011IRPFINAL.pdf IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 23 The response to this Request was prepared by Steven Keen, Vice President Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 24 REQUEST NO. 2.22: 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.) RESPONSE TO REQUEST NO. 2.22: As stated in Mr. Keen's direct testimony, the timing of the issuance of the new license remains uncertain. The Company expects to be granted annual license renewals under the existing license until the new license is issued. The response to this Request was prepared by Steven Keen, Vice President Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 25 REQUEST NO. 2.23: Please provide a copy of the Standard and Poots publication(s) of May 2003. (S. Keen, pp. 41-42.) RESPONSE TO REQUEST NO. 2.23: A copy of the Standard and Poots publication was included in the workpapers associated with Steve Keen's direct testimony. As a courtesy, an additional copy is provided on the enclosed CD. The response to this Request was prepared by Steven Keen, Vice President Finance and Treasurer, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 26 REQUEST NO. 2.24: Please identify the dollar amounts of debt obligation S&P and Moody's presently impute to Idaho Power for credit rating purposes for its long-term purchase power contracts. (S. Keen, pp. 40-42.) RESPONSE TO REQUEST NO. 2.24: Please see the document provided on the enclosed CD. The response to this Request was prepared by Larry Spencer, Director of Investor Relations, 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 SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 27 REQUEST NO. 2.25: Please provide the capital investments planned by the Company for each of the years 2011 through 2013 disaggregated into production, transmission, distribution, and other plant. (S. Keen, p. 44.) RESPONSE TO REQUEST NO. 2.25: Idaho Power's planned capital investments are disclosed on pages 54 and 55 of IDACORP's 2011 1st quarter 10-Q report. The report is available at http://ww.idacorpinc.com/pdfs/10Q/10q20111a.pdf. The response to this Request was prepared by Steven Keen, Vice President Finance and Treasurer, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 2nd day of August 2011. \~£2 J B. WILLIAMS Attorney for Idaho Power Company --- IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 28 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 SECOND 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 Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Don.Howell(Qpuc.idaho.gov Karl T. Klein Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email KarI.Klein(Qpuc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 2ih Street P.O. Box 7218 Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email peter(Çrichardsonandoleary.com greg(Çrichardsonandoleary. com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hill Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email dreading(Çmindspring.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 -2 Email elo(Çracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 29 Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email tonyCâyankel.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 kboehmCâBKLlawfirm.com jrhCâbattisher.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 khigginsCâenergystrat.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 myorkCâhollandhart.com tnelsonCâholland hart. com madavidsonCâholland hart. com fsch midtCâholland hart. 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 remalmgrenCâmicron.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.bruderCâhg.doe.gov Steven. porterCâhq. doe. gov IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 30 Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Place, Suite 310 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email detheridge((exeterassociates.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 -. Email bmpurdy((hotmail.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 -. Email botto((idahoconservation.org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email kmiller(ësnakeriverallance.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 Mail FAX -. Email nancy(ënwenergy.org\." G~r2~~\Jiliams IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 31