20110810IPC to ICIP 4-32(sic).pdf

o i: i; i:Ii '\L,.,It-
e:IDA~POR~
An IDACORP company
JASON B. WILLIAMS
Corporate Counsel
jwilliamscæidahopower.com
August 10, 2011.
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities 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 Second Requests for Production of the Industrial Customers of Idaho
Power in the above matter. In addition, enclosed for fiing are an original and one (1) copy
of Idaho Power Company's Confidential Response to the Second Requests for Production
of the Industrial Customers of Idaho Power in the above matter.
Also enclosed are three (3) copies of a non-confidential disk containing information
being produced in response to the above production request.
Please handle the enclosed confidential information in accordance with the
Protective! Agreement executed in this matter.
"
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: [phone]
Facsimile: [phone]
Inordstrom(Çidahopower.com
dwalker((idahopower.com
jwilliams((idahopower.com
RECEIVED
2011 AUG' 0 PM~: 13
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 SECOND
REQUESTS FOR PRODUCTION OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Second Requests for Production of the Industrial Customers of Idaho
Power dated July 20, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO.4: Reference Direct Testimony of Scott
Sparks, pp. 34 - 41. Please provide all supporting documentation, work papers in
electronic format, data, and assumptions used in the development of the proposed
facilties charges requested in this testimony, including the values in the table shown on
page 40.
RESPONSE TO REQUEST FOR PRODUCTION NO.4: All supporting
documentation and workpapers used in the development of the proposed facilties
charges are contained in the attached Excel file.
The response to this Requést was prepared by Shelby Leforgee, Finance
Leader, Idaho Power Company, under the direction of Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 5: Reference Direct Testimony of Scott
Sparks, pp. 34-41. Please provide all supporting documentation, work papers in
electronic format, data, and assumptions used in the development of the values used by
the Company in the development of the current 1.7% monthly facilties charge for
Schedule 19 in 1987 in Case No. U-1006-298.
RESPONSE TO REQUEST FOR PRODUCTION NO.5: All supporting
documentation and workpapers used in the development of the current facilities charges
are attached.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO.6: Reference Direct Testimony of Scott
Sparks, p. 41 (stating that the estimated reduction in revenue received by the Company
through the facilties charge "wil result in increases in the revenue requirements for
each customer class that collects facilities charge revenue").
(a) Please admit or deny that the Company's filng submits that a fair, just and
reasonable facilties charge for Schedule 9, 19, and 24 customers would be 1.41 %
monthly, which is a reduction from the charge currently in effect of 1.7 % monthly. If
deny, please explain.
(b) Please admit or deny that the Company's filng submits that the reduction
in revenue collected from customer classes attributable to the proposed reduction in the
facilities charge should result in a corresponding increase in revenue requirement for
those customer classes. If deny, please explain.
(c) If the response to the (a) and (b) is to admit, please explain the
Company's justification. Specifically, please fully explain why a reduction in Company's
rate of return since 1987 (or any other reduction in any other component of the facilities
charge) and a corresponding need to reduce the facilties charge should be coupled
with a corresponding increase the revenue requirement for these customer classes.
RESPONSE TO REQUEST FOR PRODUCTION NO.6:
(a) The Company's filng submits that a monthly facilties charge rate of 1.41
percent is a fair, just, and reasonable facilities charge for Schedule 9, 19, and 24
customers.
(b) A reduction in revenue collected from customer classes attributable to the
proposed reduction in the facilties charges wil result in a corresponding increase in
revenue requirement for those customer classes.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
(c) Revenue received from customers paying facilties charges is directly
related to the Company's cost of owning, operating, and maintaining facilties that are
solely dedicated to these customers. As a result, the revenue received from these
customers is applied as a direct offset or credit to the revenue requirement for the
corresponding customer class. Because these facilities are only used by customers
subject to facilties charges, it is reasonable to offset the respective customer classes'
revenue requirement. Therefore, a reduction in the revenue credit associated with
facilities charges results in a corresponding increase in the revenue requirement.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
REQUEST FOR PRODUCTION NO.7: Reference Direct Testimony of Scott
Sparks, p. 41 (stating that the estimated reduction in revenue received by the Company
through the facilties charge "wil result in increases in the revenue requirements for
each customer class that collects facilties charge revenue").
(a) Does the Company believe that it is entitled to remain revenue neutral with
regard to any changes in the facilties charge calculated in 1987? Does the Company
consider the level of facilities charge set for Schedule 19 customers in 1987 in Case No.
U-1006-298 to be a "grandfathered" rate to which it is entitled into perpetuity? If not,
please explain.
(b) Please identify any other rate recovery mechanism authorized by the
Commission which allows the Company to increase a customer class's revenue
requirement solely to keep the Company revenue neutral when it is fair, just and
reasonable to reduce some component of that customer class's rates.
RESPONSE TO REQUEST FOR PRODUCTION NO.7:
(a) As with all rates, charges, and credits in Idaho Power's tariff, the Company
files to update costs periodically in order to keep all rates, charges, and credits current
with the actual costs incurred by the Company. In the Company's revenue requirement
calculation for the determination of base rates, facilties charges are treated as a
revenue credit. Therefore, a reduction in the revenue credit results in an increase in the
revenue required from base rates. The Company believes this is the appropriate
manner in which to determine its revenue requirement regardless of the year in which
the currently effective facilties charge rate was determined. The Company does not
consider the level of facilities charge set for Schedule 19 customers in 1987 in Case No.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
U-1006-298 to be a "grandfathered" rate to which it is entitled into perpetuity. This is
evidenced by the Company's current request to adjust the facilties charge rate. The
Company believes that it should have an opportunity to recover its prudently incurred
costs and earn its authorized rate of return. This is true whether the associated revenue
comes from facilties charges or base rates.
(b) All of the Company's revenues for "non-recurring charges" such as
connection and disconnection charges as well as field visit charges and service
establishment charges are treated in the same manner as facilties charges in the
Company's revenue requirement determination for each class. That is, as revenues
from non-recurring charges move up or down resulting from changes in the charge
amounts without a corresponding change in costs, the revenue required from base rates
is naturally adjusted accordingly. Further, under the Company's Rule H, New Service
Attachments and Distribution Line Installations or Alterations, revenue collected from
contributions in aid of construction ("CIAC") are booked as a direct offset to the
corresponding customer classes' revenue requirement. As a result, if the Company's
collection of CIAC's is reduced for a particular customer class, then the classes'
revenue requirement wil increase as a result.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO.8: Referenæ Direct Testimony of Scott
Sparks, p. 35 (discussing the customer schedules that have paid the facilties charge).
(a) Please provide the revenue received by the Company from facilties
charges for each rate Schedule described for the period 1987 through 2010.
(b) Are there any other rate Schedules, or Special Contract Customers, that
the Company received facilties charge revenue from during the period 1987 through
2010? If so please identify the Schedule or Special Contract Customer and provide the
amount collected for each year, organized by Schedule.
RESPONSE TO REQUEST FOR PRODUCTION NO.8: The response to this
Request contains confidential customer information and wil be provided to those parties
that have executed the Protective Agreement.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
REQUEST FOR PRODUCTION NO.9: Is the Company wiling to sell the
Company-owned facilties beyond the point of delivery to its customers at the
depreciated book value? If yes, please explain why this option is not provided for in the
Schedule 19 tariff. If no, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO.9: No. It is the
Company's policy not to sell Company-owned facilties installed beyond the point of
delivery.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 10: Is the Company willng to sell the
Company-owned facilties beyond the point of delivery to its customers at the fair market
value? If yes, please explain why this option is not provided for in the Schedule 19
tariff. If no, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: No. It is the
Company's policy not to sell Company-owned facilties installed beyond the point of
delivery.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 10
REQUEST FOR PRODUCTION NO. 11: Reference the email contained in ICIP
Second Requests for Production Attachment 1. Please explain why the Company
determined it could not sell Company-owned facilities beyond the point of delivery to
J.R. Simplot Company. Please include explanation of both bases asserted for the
decision not to sell facilties - (1) I.C. § 61-328 and (2) the way Idaho Power wants to
run its business as a regulated public utilty.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:Company
representatives met with Don Sturtevant, Energy Manager, Conservation, Alternatives,
& Procurement, for the J.R. Simplot Company ("Simplot"); Simplots attorney, Mr. Greg
Adams; and Simplots consultant, Mr. Don Reading, Vice President and Consulting
Economist, with Ben Johnson Associates, Inc., at their request on December 28,2010,
and again on April 11, 2011, to discuss the Company's position related to the sale of
Company-owned facilities to Simplot. At the April 11, 2011, meeting, Idaho Power
representatives explained that it had made a business decision that it was not going to
sell Company-owned facilities to Simplot. As a regulated public utilty, the Company
operates its business within the parameters of the law, its regulators, and its tariffs with
customers. The Company is free to make any business decision so long as it does so
within those parameters. Idaho Code § 61-328 requires the Idaho Public Utiities
Commission ("Commission") to authorize the sale of any public utilty property finding
that such sale (a) is consistent with the public interest; (b) that the cost of and rates for
supplying service wil not be increased by reason of such transaction; and (c) that the
applicant for such acquisition or transfer has the bona fide intent and financial capability
to operate and maintain the transferred property in the public service. In this instance, if
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11
Idaho Power were to elect to sell Company-owned facilties to Simplot, it would need to
increase the revenue requirement and rates to recover the revenue requirement for
Schedule 19 customers as a result of the transaction. At the conclusion of the April 11,
2011, meeting, Simplots attorney indicated it was going to send a letter to Idaho Power
requesting a formal price quote for the amount necessary for Simplot to pay for the
removal of Company-owned facilties on its side of the point of delivery that included an
amount necessary that would hold all other Schedule 19 customers harmless. To date,
Idaho Power has not received any such request. Regardless of whether the Company
does receive such a request, Idaho Power has determined that, at this time, it is not in
the business of sellng these types of Company-owned facilties to third parties.
The response to this Request was prepared by Scott D. Sparks, Idaho Power
Company, and Greg Said, Vice President of Regulatory Affairs, Idaho Power Company,
in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
REQUEST FOR PRODUCTION NO. 12: Does the Company provide customers
paying the facilties charge with any option to ever stop paying the facilties charge, and
acquire and control their own equipment on their own property? If so, please identify
the language in the existing or proposed tariff highlighting this option for customers, and
explain how this process works. Please include explanation of the length of time it
would take Idaho Power to provide customers with a calculation of the cost for the
customer to pay Idaho Power to remove the facilities and stop paying the facilties
charge. Since 1987, how many customers have (1) inquired into this option, (2)
exercised this option?
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Customers paying a
facilities charge can request that the Company remove all of its facilties located on the
customets propert. In this case, the customer would no longer pay a monthly facilties
charge after all facilties were removed and all removal fees were paid. All customers
can request removals, relocations, upgrades, or conversions without specific tariff
language indicating that they can make such a request.
The length of time it would take Idaho Power to provide customers with a
calculation of the cost for the customer to pay Idaho Power to remove the facilities and
stop paying the facilities charge wil vary based on the site configuration and the number
of facilties being removed. The Company does not track the number of customers that
have inquired into this option or exercised this option.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13
REQUEST FOR PRODUCTION NO. 13:Please provide the capital
expenditures the Company has paid for facilties beyond the point of delivery for the
years 1987 through 2010, organized by rate Schedule.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The year-end capital
expenditures the Company has paid for facilties installed beyond its point of delivery for
the years 1997 through 2010 are shown in the table below. Capital expenditures for the
years 1987 through 1996 are not available and are beyond the Company's retention
period.
Capital expenditures for Schedules 15, 24, and 41 are not readily available and it
would be unduly burdensome to collect this information as these expenditures reside on
individual work orders only.
Year
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
Schedule 9
$2,085,340
$2,190,811
$2,771,916
$3,269,445
$4,002,323
$4,398,325
$5,530,487
$4,913,332
$6,195,982
$6,491,483
$6,630,890
$7,285,502
$8,390,079
$10,077,223
Schedule 19 Special Contract
Schedule 29
Year-End Capital
Expenditures
(Schedules
9,19,29)
$20,142,384
$21,695,487
$23,042,346
$24,244,901
$24,986,485
$26,089,187
$26,889,601
$27,273,966
$28,254,992
$28,753,551
$30,150,622
$32,182,392
$34,456,151
$36,827,960
$15,680,097
$17,080,467
$17,810,616
$18,515,753
$18,409,054
$19,143,765
$18,819,079
$19,820,599
$19,518,975
$19,722,033
$20,979,697
$22,369,277
$23,510,522
$24,179,239
$2,376,947
$2,424,209
$2,459,814
$2,459,703
$2,575,108
$2,547,097
$2,540,035
$2,540,035
$2,540,035
$2,540,035
$2,540,035
$2,527,613
$2,555,550
$2,571,498
The response to this Request was prepared under the direction of Scott D.
Sparks, Senior Regulatory Analyst, Idaho Power Company, in consultation with Jason
B. Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 14
REQUEST FOR PRODUCTION NO. 14: Reference Direct Testimony of Scott
Sparks, p. 39, lines 15-20. Does the insurance carried by the Company cover or
indemnify customers from accident or injury associated with Company- owned facilties
installed beyond the Company's Point of Delivery If not, does the Company make new
customers aware of the customer's lack of coverage or indemnification for Idaho Power
equipment on their property?
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: For Company""wned
facilties installed beyond the Company's point of delivery, the insurance carried by the
Company would cover any loss for which the Company was deemed negligent in an
accident or injury.
The response to this Request was prepared by Tim Tucker, Property and
Casualty Administrator, Idaho Power Company, at the direction of Scott D. Sparks,
Senior Regulatory Analyst, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 15
REQUEST FOR PRODUCTION NO. 15: Reference Direct Testimony of Scott
Sparks, p. 39, lines 18-19 (stating the policy covers equipment subject to the facilties
charge for "property, casualty, and workers compensation"). Please explain what
"property" is covered and in what fashion. Please explain why Idaho Power believes
that the policy covers "property" but does not cover "facility replacement costs."
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: The property covered
is the equipment on the customets facilties charge and the resulting exposure created
by Idaho Power owning, operating, and maintaining this equipment, which can result in
property, third-party liabilty, and workers' compensation losses. Idaho Power's property
insurance policy covers "property" damage that results from an insured event but does
not cover "facilty replacement costs" associated with normal wear and tear.
Additionally, virtually all "insured" propert losses occurring beyond the Company's point
of delivery would fall under Idaho Power's self-insured retention (deductible) and would
be an expense incurred directly by the Company.
The response to this Request was prepared by Tim Tucker, Property and
Casualty Administrator, Idaho Power Company, at the direction of Scott D. Sparks,
Senior Regulatory Analyst, Idaho Power Company, in consultation with Jason B.
Williams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER -16
REQUEST FOR PRODUCTION NO. 16: Reference Direct Testimony of Scott
Sparks, p. 39, lines 15-20. Please provide a copy of the currently effective insurance
polic(ies) referenced, and identify the provisions that apply to equipment subject to the
facilties charge.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the
attached summaries of insurance programs currently in place. Technically, there are no
provisions that refer directly "to equipment subject to the facilties charge" as Idaho
Power's insurance structure is a large "blanket" program that would cover catastrophic
losses associated with third-party liabilty, property, and workers' compensation losses
that could occur at or near the facilties and equipment in question. Most losses that
would occur with facilties charge exposure would fall under deductible levels and would
be paid directly by Idaho Power without any insurance recovery.
The response to this Request was prepared by Tim Tucker, Property and
Casualty Administrator, Idaho Power Company, at the direction of Scott D. Sparks,
Senior Regulatory Analyst, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 17
REQUEST FOR PRODUCTION NO. 17: Reference Direct Testimony of Scott
Sparks, p. 39, lines 15-20. Please provide the insurance premiums paid by the
Company for each year for the years 1987 through 2010 related to facilities charge
equipment, organized by Schedule.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: The response to this
Request is confidential and wil be provided to those parties that have executed the
Protective Agreement.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 18
REQUEST FOR PRODUCTION NO. 18: Reference Direct Testimony of Scott
Sparks, p. 39, lines 15-20. Please provide the insurance claims for Company-owned
equipment associated with the facilities charge filed by the Company for each year for
the years 1987 through 2010, organized by rate Schedule.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: There are technically
no "insurance" claims regarding this equipment as any loss during that time frame fell
within the self-insured deductible range. However, Idaho Power pays for any such
losses directly (without any insurance recovery). Idaho Power's current standard
property insurance deductible (Le., self-insured) is one millon dollars per loss.
The response to this Request was prepared by Tim Tucker, Property and
Casualty Administrator, Idaho Power Company, at the direction of Scott D. Sparks,
Senior Regulatory Analyst, Idaho Power Company, in consultation with Jason B.
Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 19
REQUEST FOR PRODUCTION NO. 19: Reference Direct Testimony of Scott
Sparks, p. 35, line 7 (stating, "At the option of the Company, facilities charges may be
offered. . . .). Is the facilties charge optional for Schedule 19 customers, or does the
Company choose whether any facilties beyond the point of delivery wil be owned by
the Company?
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: As stated in the
Company's tariff, facilties charges provisions are offered at the option of the Company.
When service is first established, Schedule 19 customers are expected to provide
facilities beyond the point of delivery. However, if requested by the customer, Idaho
Power may offer to own, operate, and maintain such facilties which, if offered and
accepted, require a facilties charge that is not optional to the customer.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 20
REQUEST FOR PRODUCTION NO. 20: Reference the Schedule 19 Tariff.
(a) Please admit or deny that the Schedule 19 Tariff states:
At the option of the Company, transformers and other
facilties installed beyond the Point of Delivery to
provided Primary or Transmission Service may be
owned, operated, and maintained by the Company in
consideration of the Customer paying a Facilties
Charge to the Company.
(b) Please admit or deny that the Schedule 19 tariff provides no statement
that customers have the option to own and operate all facilities beyond the point of
delivery. If deny, please explain.
(c) Please provide the legal basis for the Company to require that it own
facilities on the property of Schedule 19 customers. If the customer does not consent to
the Company placing and maintaining such equipment on the customer's property, does
the Company believe that the tariff gives it the legal right to do so? Does the Company
obtain written consent from customers to place facilities on the customers' property?
What type of consent does the Company obtain?
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
(a) The first paragraph of the facilities charge provisions in Schedule 19
states, "At the option of the Company, transformers and other facilities installed beyond
the Point of Delivery to provide Primary or Transmission Service may be owned,
operated, and maintained by the Company in consideration of the Customer paying a
Facilties Charge to the Company."
(b) Schedule 19 states what Idaho Power wil possibly do beyond the point of
delivery, but is not intended to address what customers mayor may not do with their
propert.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 21
(c) There is no legal requirement that the Company own facilties on the
property of Schedule 19 customers. At the customets request, the Company, at its
option, may install Company-owned facilties on the customer side of the point of
delivery. Schedule 19, on file and approved by the Commission, gives the Company
this option and the legal authority to do so.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 22
REQUEST FOR PRODUCTION NO. 21: Reference Direct Testimony of Scott
Sparks, p. 38, lines 12-13 (stating that the "Book Depreciation" component of the
facilties charge uses "a straight line annual depreciation of assets based on a levelized
31 year basis").
(a) Please admit or deny that the Company does not reduce the principal of
the initial investment in facilties by a depreciation factor. If deny, please explain how
the Company reduces the principaL.
(b) Please admit or deny that the principle (sic) on facilties subject to the
facilities charge is the same in year 1 as it would be in year 50. If deny, please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21:
(a) Under the Company's approved and effective facilties charge
methodology, the principal of the initial investment for a piece of equipment does not
change unless it is removed or replaced. However, the depreciation component of the
facilities charge represents a declining net book value that has been converted into a
levelized amount based on a 31-year useful life assumption.
(b) Please see the Company's response to (a) above.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 23
REQUEST FOR PRODUCTION NO. 22: Reference Direct Testimony of Scott
Sparks, p. 38, lines 12-13 (stating that the "Book Depreciation" component of the
facilities charge uses "a straight line annual depreciation of assets based on a levelized
31 year basis"). Please explain why customers should pay an additional charge for the
depreciation in value of the facilties. Please explain why depreciation in value of the
facilties over time should not decrease the amount customers pay over time for use of
that equipment.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Please see the
Company's response to the Industrial Customers of Idaho Powets ("ICIP") Request for
Production No. 21.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 24
REQUEST FOR PRODUCTION NO. 23: Reference Direct Testimony of Scott
Sparks, p. 38, lines 12-13 (stating that the "Book Depreciation" component of the
facilties charge uses "a straight line annual depreciation of assets based on a levelized
31 year basis"). Please identify any rate-based asset for which the Commission allows
the Company to charge the same annual rate on the same principal amount over time
when the value of the asset decreases over time.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: There are no rate-
based assets for which the Commission allows the Company to charge the same
annual rate on the same principal amount over time when the value of the asset
decreases over time. This is also not the case with the facilities charge. As described
by Mr. Sparks on page 38 of his testimony, the facilties charge is calculated using a 31-
year depreciable life assumption.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 25
REQUEST FOR PRODUCTION NO. 24: Reference Direct Testimony of Scott
Sparks, p. 38, lines 12-13 (stating that the "Book Depreciation" component of the
facilities charge uses "a straight line annual depreciation of assets based on a levelized
31 year basis").
(a) Please explain what steps Idaho Power takes if a piece of equipment fails
prior to the expiration of the 31-year depreciation schedule.
(b) Does the Company have manufacturets warranties on any of the
equipment subject to the facilities charge?
(c) Has the Company ever filed an insurance claim to replace equipment
subject the facilties charge since 1987?
RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
(a) If a piece of equipment fails prior to the expiration of the depreciation
schedule, then it is removed from the customets facilties charge investment calculation
and the investment costs for a replacement piece of equipment is added to the
customets facilities charge investment.
(b) The Company has limited manufacturets warranties on some equipment
subject to the facilties charge, such as transformers.
(c) No. Please see the Company's response to ICIP's Request for Production
No. 18.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 26
REQUEST FOR PRODUCTION NO. 25: Reference Direct Testimony of Scott
Sparks, p. 38, lines 12-13 (stating that the "Book Depreciation" component of the
facilties charge uses "a straight line annual depreciation of assets based on a levelized
31 year basis").
(a) Please explain if Idaho Power continues to charge the facilities charge
(the monthly percentage rate multiplied by the Company's initial investment) after the 31
year depreciation period expires.
(b) For Schedules 9, 19, 24 and Special Contract Customers, please identify
the oldest pieces of equipment for which the Company is stil assessing the monthly
facilties charge to a customer in each class. Please include the year the Company
purchased and installed the equipment, the Schedule of the customer, and the initial
cost of the piece of equipment.
(c) With regard to the pieces of equipment identified in (b), is the Company
stil calculating the customers' monthly facilties charge by multiplying the monthly
facilties charge percentage by the initial investment?
RESPONSE TO REQUEST FOR PRODUCTION NO. 25:
(a) Under the facilities charge provisions, Idaho Power charges a monthly
facilties charge for equipment installed beyond its point of delivery as long as the
equipment is installed and used and usefuL.
(b) For Schedule 9, the oldest pieces of equipment (24 in total) for which the
Company is assessing a monthly facilties charge were purchased and installed in 1969
with a combined initial investment $15,329. For Schedule 19, the oldest pieces of
equipment (2 in total) for which the Company is assessing a monthly facilties charge
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 27
were purchased and installed in 1945 with an initial investment of $259. No customers
under Schedule 24 are being assessed a facilties charge.
Importantly, whether a piece of equipment fails 5 years or 45 years after
installation, the Company, under the tariffed facilties charge provisions, wil replace the
piece of equipment and adjust customers' facilties charge for the equipment being
removed and the equipment being installed.
(c) Yes. Please see the Company's response to (a) above.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 28
REQUEST FOR PRODUCTION NO. 26: Reference Direct Testimony of Scott
Sparks, p. 40. Please admit or deny that the existing facilties charge mechanism
calculated in 1987 for Schedule 19 includes a 0.560% annual charge to the customer
for depreciation, and the proposed charge includes an annual depreciation charge of
3.23%. If deny, please explain. Please explain in detail the basis for the increase in the
depreciation charge to Schedule 19 customers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: The existing facilties
charge is not based upon a 0.560 percent annual charge for depreciation. However, for
presentational purposes, in 1987, the then-current authorized rate of return was shown
as constant in a levelized stream of computational components and the true
depreciation rate was replaced with a percentage that when added to the authorized
rate of return reflected the levelized sum of the cost components. The actual
depreciation rate used was a levelized 3.226 percent per year based upon a 31-year
life. The proposed charge includes an annual depreciation charge of 3.23 percent.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 29
REQUEST FOR PRODUCTION NO. 27: Reference Direct Testimony of Scott
Sparks, p. 35, lines 17-22. Please identif the Commission order and the case number
authorizing the Company to stop offering the facilities charge to Schedules 15 and 41.
If no such order or case exists, please explain the reason the Company stopped offering
the facilties charges to those Schedules. Did the Company allow any customers from
those Schedules to purchase the Company-owned facilities when it discontinued the
facilities charge for customer Schedules? Why or why not?
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: Approval of
Commission Order No. 29505 issued on May 25, 2004, in Case No. IPC-E-03-13,
authorized the Company to stop offering facilities charges under Schedules 15 and 41.
Existing customers receiving a facilties charge under Schedule 15 and 41 prior to
issuance of Order No. 29505 continued to pay a monthly facilties charge for facilities
installed prior to June 1, 2004. The Company did not offer to sell the Company-owned
facilities when it discontinued the facilities charge for customer Schedules 15 and 41
and all existing facilities remained on a facilties charge. In turn, the Company
continues to provide operation and maintenance on these "grandfathered" facilties as
long as they are installed.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 30
REQUEST FOR PRODUCTION NO. 28: Reference Direct Testimony of Scott
Sparks, p. 41, lines 1-3 (stating that the primary cost component that has driven the
reduction in the facilties charge rates is the Rate of Return, which has decreased since
the last update).
(a) Please admit or deny that the Rate of Return used in the 1987 calculation
for Schedule 19 was 9.952%. If deny, please identify the Rate of Return used in 1987.
(b) Please identify the Commission case number for all general rate cases
filed by Idaho Power since 1987, and the Company's authorized Rate of Return in each
of those cases.
(c) Please admit or deny that the Rate of Return authorized in 2005 (IPC-E-
05-28),2007 (IPC-E-07-08), 2008 (IPC-E-08-10), was less than the Rate of Return used
to calculate the facilties charge since 1987. If deny, please explain.
(d) Please explain why the Company has not updated the facilties charge
since 1987 in light of the decrease in Rate of Return occurring at the time of general
rate case filings listed in (c). Has the Company been overcharging for the facilties
charge by failng to update the charge prior to now?
RESPONSE TO REQUEST FOR PRODUCTION NO. 28:
(a) The rate of return used in the 1987 calculation for Schedule 19 was 9.902
percent, which corresponds to a levelized rate of return of 6.905 percent. In
comparison, the 2010 rate of return used in the proposed facilties charge calculation is
8.013 percent, which corresponds to a levelized rate of return of 4.81 percent; as shown
on page 40 of the Direct Testimony of Mr. Sparks.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 31
(b) The Commission case numbers for all general rate cases filed by Idaho
Power since 1987 and the Company's authorized rates of return in each of those cases
are shown in the table below.
General Rate Rate of
Case Year Filed Case Number Return
1994 IPC-E-94-5 9.199%
2003 IPC-E-03-13 7.852%
2005 IPC-E-05-28 8.1%
2007 IPC-E-07-08 8.1%
2008 IPC-E-08-10 8.18%
(c) Please see the Company's responses to (a) and (b) above.
(d) The Company has not updated the facilities charges since 1987 because
its periodic validations of the existing facilties charges did not warrant an update when
using the current approved calculation methodology.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 32
REQUEST FOR PRODUCTION NO. 29: Reference Direct Testimony of Scott
Sparks, p. 40. Please provide evidence justifying the Company's proposal to charge a
higher percentage for operation and maintenance for Schedule 19 compared to
Schedule 41.
RESPONSE TO REQUEST FOR PRODUCTION NO. 29: Please see the
Company's response to ICIP's Production Request NO.4.
The response to this Request was prepared by Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 33
REQUEST FOR PRODUCTION NO. 30: Reference Direct Testimony of
Matthew Larkin, pp. 21-25 (discussing the Company's proposed method of adjusting
coincident peak demand for the impact of demand response (DR) programs). Please
provide:
(a) Electronic copies of all input, output, and adjustment spreadsheets used to
adjust coincident peak demand data for the impact of DR programs,
(b) The work papers supporting and the document titled, "Peak Responsibilty
Methods for the 2011 General Rate Case" referenced on page 24, and
(c) The Global Energy Partners, LLC research document titled, "Demand
Response: It's A Resource, So Treat It Like One."
RESPONSE TO REQUEST FOR PRODUCTION NO. 30:
(a) Please see the Company's responses to the Department of Energy's
Request Nos. 3-4 through 3-7.
(b) The document titled, "Peak Responsibilty Methods for the 2011 General
Rate Case" is provided on page 50 of Mr. Larkin's workpapers.
(c) Please see the Company's response to the Department of Energy's
Request No. 3-8.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 34
REQUEST FOR PRODUCTION NO. 31: Reference the Company's Application,
pp. 5-6, ,- 15.
(a) Please explain any differences to rates between increasing the EE Rider
above 4.75% to cover the approximately $11.3 milion in demand response incentive
payments and the Company's proposed treatment to include that same amount as a
power supply expense in base rates.
(b) Are there differences in cost-allocation between customer classes under
the two approaches? Please explain.
(c) How does Idaho Power propose to allocate the demand response
incentive payments as a power supply expense in base rates among customer classes?
(d) Wil the incentive payment costs be assigned to the customer class
receiving the incentive payment, or wil it be assigned to all customer classes the same
as a system resource? If the costs are assigned as a system resource, does the cost of
service study allocate them 100% to demand to account for their use to address peak
demand? If not, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31:
(a) Increasing the Company's Energy Efficiency Rider ("Ridet') would result in
an increased percentage applied to each customets base rate revenue above the 4.75
percent surcharge currently in place. By including the approximately $11.3 milion of
demand response incentive payments in base rates, the current 4.75 percent Rider
would remain at its current level, and base rates would be increased to reflect the
inclusion of the incentive payments in net power supply expenses. If approved, the
$11.3 milion included in base rates would carry forward into future Power Cost
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 35
Adjustment ("PCA") calculations in the same manner as other PCA-related power
supply expense accounts.
(b) Yes. Under the Rider, revenues are collected from customers as a
uniform percentage (currently 4.75 percent) of base rate revenues. This results in the
collection of Rider-related expenses from customers proportional to each customer's
amount of base rate charges. Under the Company's current proposal, the $11.3 million
in demand response incentive payments is allocated to classes according to the D10P
allocator, which represents the sum of each class's coincident peak demands for the
three summer months of June, July, and August.
(c) Please see the Company's response to (b) above.
(d) Under the Company's proposal, demand response incentive payments are
allocated to customer classes as a system resource in the same manner as costs
associated with the Company's supply-side resources. Because demand response
programs are designed to provide load reduction during peak hours, the Company has
classified the incentive costs as 100 percent peak-demand related in the same manner
as the Company's current gas-fired facilties, which were also constructed to meet
capacity requirements during high load summer months.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 36
REQUEST FOR PRODUCTION NO. 31 r!!: Reference Direct Testimony of
Greg Said, p. 24 (stating the "the Company intends to accumulate Custom Efficiency
incentive payments as a regulatory asset with a carrying charge equal to the currently
authorized rate of return until the Company's next revenue requirement proceeding").
Please provide the revenue requirement impact that would occur if the Custom
Efficiency incentive payments were requested and authorized for recovery in this case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31 (sic): Had the Custom
Efficiency incentive payments been requested and ultimately authorized for recovery in
this case, the revenue requirement for Idaho would increase from $917,609,020 to
$919,633,525, or a total of $2,024,505, as seen on the attached Excel file. This
scenario assumes a four-year amortization of the Custom Efficiency payments. The
balance of the incentive payments would be included in Account 182 and increases rate
. base by $4,406,249 and the first year expense would be included in operations and
maintenance Account 908 and would total $1,468,750. Both figures would be allocated
directly to the Idaho jurisdiction in the jurisdictional separation study.
The response to this Request was prepared by Kelley Noe, Regulatory Analyst,
Idaho Power Company, under the direction of Greg Said, Vice President of Regulatory
Affairs, Idaho Power Company, in consultation with Jason B. Willams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 37
REQUEST FOR PRODUCTION NO. 32 (sic): Reference Order No. 31093
(approving an increase in normalized base power supply costs of approximately $25
millon for affilate Bridger Coal Company ("BCC") mine costs and noting "because any
profits obtained by BCC are passed on to Idaho Powets customers in rate cases, the
usual concern about improper charges to customers in affliate transactions is largely
removed").
(a) Please identify the BCC profits occurring since the last general rate case.
(b) Please identify where in the Company's filng the profits flow back to
customers in this case.
(c) Please explain the changes to net power supply expense in this case
related to BCC costs. Have operating costs changed for BCC coal? Has the Company
requested a corresponding change in NPSE in this case?
(d) Please provide the Company's lower market or cost analysis in of the BCC
costs supporting the request for the BCC component of NPSE in this case, per Order
No. 30530, Revised Code of Conduct, at p. 2, ,- 8(g).
RESPONSE TO REQUEST FOR PRODUCTION NO. 32 (sic):
(a) Idaho Energy Resources Company ("IERCo") is an Idaho Power Company
subsidiary that manages a one-third ownership interest in the Bridger Coal Company.
IERCo's net income for 2008, 2009, and 2010 is listed below. These amounts do not
include interest on inter-company notes payable (net of tax).
2008 $4,121,080
2009 $4,957,254
2010 $7,546,333
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 38
(b) Exhibit No. 26, page 1, line 26, shows that IERCo's operating income was
added to Idaho Powets operating income, shown on line 25, thereby reducing the
Company's earnings deficiency in this case.
(c) The Company has not requested authority to change power supply
expenses related to Bridger Coal Company as part of this case. However, Company
witness Scott Wright describes on page 6 of his testimony the changes in the cost of
coal burned at the Jim Bridger Power Plant that have occurred since the last update to
power supply expenses approved by Order No. 31093.
(d) The requested analysis does not exist. The Company does not interpret
Order No. 30530 as requiring such an analysis. The Company has not requested
authority to change power supply expenses related to Bridger Coal Company as part of
this case.
The response to this Request was prepared under the direction of Timothy E.
Tatum, Manager of Cost of Service, Idaho Power Company, in consultation with Jason
B. Wiliams, Corporate Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 10th day of August 2011.
\
"\
Ä N B. WILLIAMS
orney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 39
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of August 2011 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER 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
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U.S. Mail
_ Overnight Mail
FAX
-Å Email Don.Howell((puc.idaho.gov
Karl T. Klein
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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U.S. Mail
_ Overnight Mail
FAX
-Å Email KarI.Klein((puc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 2th Street
P.O. Box 7218
Boise, Idaho 83702
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-Å Email peter((richardsonandoleary.com
greg((richardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
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-Å Email dreading((mindspring.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
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-Å Email elo((racinelaw.net
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 40
Anthony Yankel
29814 Lake Road
Bay Vilage, Ohio 44140
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-- Email tony((yankel.net
Kroger Co.
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
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-- Email kboehm((BKLlawfirm.com
jrh((battisher.com
Kevin Higgins
Energy Strategies, LLC
215 South State Street, Suite 200
Salt Lake City, Utah 84111
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-- Email khiggins((energystrat.com
Micron Technology, Inc.
MaryV. York
HOLLAND & HART LLP
101 South Capital Boulevard, Suite 1400
Boise, Idaho 83702
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-- Email myork((hollandhart.com
tnelson((holland hart. com
madavidson((hollandhart.com
fschmidt((hollandhart.com
Richard E. Malmgren
Senior Assistant General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
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-- Email remalmgren((micron.com
Department of Energy
Arthur Perry Bruder, Attorney-Advisor
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
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-- Email Arthur.bruder((hq.doe.gov
Steven. porter((hq.doe.gov
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 41
Dwight D. Etheridge
Exeter Associates, Inc.
5565 Sterrett Place, Suite 310
Columbia, Maryland 21044
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-- Email detheridge((exeterassociates.com
Community Action Partnership
Association of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1 th Street
Boise, Idaho 83702
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-- Email bmpurdy((hotmail.com
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
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-- Email botto((idahoconservation.org
Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
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-- Email kmiler((snakeriverallance.org
NW Energy Coalition
Nancy Hirsh, Policy Director
NW Energy Coalition
811 First Avenue, Suite 305
Seattle, Washington 98104
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-- Email nancy((nwenergy.org
\~~ãSilliams
\..
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 42