HomeMy WebLinkAbout20110802IPC to DOE 2-1 thru 2-25.pdfJASON B. WILLIAMS
Corporate Counsel
iwilliamscæidahopower.com
REGE
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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.
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Very truly yours,,W~'"
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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
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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\."
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IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S SECOND
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 31