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Home My WebLink About20110811DOE Fourth Requests to IPC.pdfBEFORE 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 TO ITS CUSTOMERS IN THE STATE OF IDAHO. CASE NO. IPC-ll- S. DOE's Fourth Interrogatories and Production Requests to Idaho Power Company The United States Department of Energy, by and through its attorney of record Arthur Perry Bruder, hereby requests that Idaho Power Company ("the Company" or Idaho Power ) provide the following documents and information as soon as possible but no later than As per the Commission s Rules of Procedure, responses must include the name(s) and phone number of the person(s) who prepared the document, and the name(s), job title(s), location(s) and phone number(s) of the record holder(s) and, if different, the witness( es) who can sponsor the answer at hearing if need be. These Interrogatories and Production Requests are to be considered as continuing, and the Company is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that constitute relevant augmentation of the documents produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name, job title and telephone number of the person preparing the documents. Please provide all Excel and electronic files on CD with formulas activated. IDAHO POWER COMPANY CASE No. IPC- E-II- DOE's FOURTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS DOE- DOE- DOE- Referring to Idaho Power s response to DOE-5(b): (a) Please provide all studies and analyses conducted by or on behalf of the Company that empirically demonstrate that the fixed costs of the Company s thermal generating plant investments vary with the production of energy from such plants. (b) Please provide all studies and analyses conducted by or on behalf of the Company that empirically demonstrate that the fixed costs of the Company s hydro generating plant investments vary with the production of energy from such plants. (b) Please explain in detail why it is reasonable to assume that the percentage of Idaho Power s fixed production plant costs classified as energy-related changes annually based on changes in Idaho Power jurisdictional load factor. In recent class cost-of-service studies filed in rate cases by Rocky Mountain Power (RMP) before the Idaho Public Utilities Commission (IPUC), RMP has classified 25 percent of its fixed production plant investment costs as energy-related costs versus 50-60 percent that Idaho Power classifies as energy-related costs. The IPUC has approved RMP' production plant cost classification. (a) Has Idaho Power conducted any analyses to determine whether it is reasonable to classify twice as much of the Company s fixed production plant costs as energy-related (50-60 percent) compared to RMP's classification of fixed production plant costs (25 percent). Please provide any analyses that Idaho Power has conducted. (b) In the past 3 years, has Idaho Power had any discussions with the Commission Staff to discuss or review the reasonableness of Idaho Power s classification of fixed hydro and thermal plant costs? Please provide the dates of any such discussions, the names of Idaho Power and Staff participants, and any notes, emails, reports, or other written documents related to such discussions. Referring to Idaho Power s response to DOE-I- 7: (a) Please provide all studies, reports, analyses, or other data and information that support Idaho Power s assertion that "(aJs a result of economic dispatch ,... hydro facilities are typically operated on a year- round basis.... (b) Please provide all studies, reports, analyses, or other data and information that support Idaho Power s assertion that "(aJs a result of economic dispatch ,... gas-fired facilities are typically operated only in the high load summer months. IDAHO POWER COMPANY CASE No. IPC- E-II- DOE's FOURTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS DOE- DOE- DOE- DOE-4- 7. DOE- ( c) Please identify and provide Idaho Power s dispatch protocol or other written guidelines used to select the dispatch order of its generating fleet and power purchases. Referring to Idaho Power s response to DOE-I- 7, the request did not seek specific hours that were or were not used in the cost study, but rather witness Larkin s and Idaho Power s opinion on what hours would be designated as "low load or off-peak time period" hours. Please answer the request with this clarification. Referring to Idaho Power s response to DOE-, the request did not seek specific hours that were or were not used in the cost study, but rather witness Larkin s and Idaho Power s opinion on what hours would be designated as "shoulder hours.Please answer the request with this clarification. Referring to Idaho Power s response to DOE-, the request did not seek specific hours that were or were not used in the cost study, but rather witness Larkin s and Idaho Power s opinion on what hours would be designated as those in which "peak loads.. . occur during summer afternoons and evenings.Please answer the request with this clarification. Referring to Idaho Power s response to DOE-IO: (a) Please provide all workpapers, studies, analyses, and documents supporting and/or underlying Idaho Power s assertion that "(tJhe base and intermediate loads on the Company s system are typically served by the same generation resources. (b) Please identify the date, hour, and load of the Company s monthly system peaks from January 2008 through the current date. Referring to Idaho Power s response to DOE-14(c): (a) The response implies that the listed hydro projects are unable to provide operating reserves. Is this a correct interpretation of the response? (b) Regarding the 330 MW of summer 2011 peak load reduction capability provided by demand response programs, please provide the MW of peak load reduction capability provided by each available program. (c) For each supply resource used by Idaho Power to serve retail load please identify the position of each resource in the Company resource stack. IDAHO POWER COMPANY CASE No. IPC- E-II- DOE's FOURTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS DOE-Referring to Idaho Power s responses to DOE-17 (b), 1-18(b), and 1- 19(b), are the terms dynamic interchange and static interchange used in the responses consistent with the NERC National Tagging Standard 1.8 or its successor. If no, please provide detailed definitions of the terms. Referring to Idaho Power s responses to DOE-21: (a) Please provide in Excel format with working formulas and links intact all sales and load forecasts for a 12-month period prepared by the Company since August 25 2010. (b) If the most recent of the forecast provided in response to the previous subpart was not used as the test-year forecast of customers and kWh sales in the current rate case, please explain why. DOE-10. At Washington, D., this day of August, 2011. Arthur Perry Bruder Attorney for the United States Department of Energy Phone: (202) 586-3409Fax: (202) 586-7479 Arthur.Bruder~hq. doe.gov IDAHO POWER COMPANY CASE No. IPC- E-II- DOE's FOURTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS CERTIFICATE OF SERVICE I hereby certify that, this day of August, 2011, I served the foregoing fourth production request of the United States Department of Energy to Idaho Power Company, in Case No. IPC- 11- 08, by emailing it, and by a copy of it, (postage prepaid), to the following: Commission Staff Weldon Stutzman, DAG Randy Lobb Neil Price Idaho Public Utilities Commission 472 W. Washington St. Boise, ID 83702 Weldon. Stutzman~puc. idaho .gov Randylo b b~puc. Idaho. gov Nei1.Price ~puc.Idaho.gov Idaho Power Company Lisa D. Nordstrom Jason B. Williams Donovan E. Walker Greg Said John R. Gale Idaho Power Company O. Box 70 Boise, Idaho 83707-0070 lnordstrom~idahopower. com jwilliams~idahopower. com dwalker~idahopower. com gsaid~idahopower. com rgale~idahopower. com Community Action Partnership Association Brad M. Pudy Attorney at Law 2019 N. 17th St. Boise, ID. 83702 bmpurdy~hotmail.com IDAHO POWER COMPANY CASE No. IPC- E-II- DOE's FOURTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Idaho Conservation Lea2ue Benjamin 1. Otto 710 N. 6th St. Boise, ID 83701 botto~idahoconservation. org Idaho Irri2ation Pumpers Association Eric L. Olsen Racine, Olson, Nye, Bud & Bailey, Chartered O. Box 1391 201 East Center Street Pocatello, Idaho 83204-13 91 elo(illracinelaw.net Anthony Yanke I 29814 Lake Road Bay Village, Ohio 44140 tony~yankel. net Industrial Consumers of Idaho Power Peter 1. Richardson Gregory M. Adams Richardson & O'Leary PLLC 515 N. 27th St O. Box 7218 Boise, Idaho 83702 peter~richardsonandoleary. com greg~richardsonandoleary. com Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 dreading~mindspring. com IDAHO POWER COMPANY CASE No. IPC- E-II- DOE's FOURTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Kro2er John R Hammond, Jr. Batt Fisher Pusch & Alderman, LLP US. Bank Plaza, 5th Floor 101 S. Capitol Boulevard, Suite 500 O. Box 1308 Bois, ID 83701 jrh~battfisher. com Kurt 1. Boehm Boehm, Kurtz & Lower 36 E. Seventh St., Suite 1510 Cincinnati, OH 45202 KBohm~PBKLlawfirm. com Micron Mary V. York, ISB No. 5020 Holland & Hart LLP Suite 1400, U S. Bank Plaza 101 South Capitol Boulevard O. Box 2527 Boise, Idaho 83701-2527 myork~hollandhart. com Thorvald A. Nelson Mark A. Davidson Holland & Har LL 6800 South Fiddlers Green Circle, Ste. 500 Greenwood Village, CO 80 III tne1son~hollandhart. com madavidson~hollandhart. com Richard E. Malmgren Sr. Asst. General Counsel Micron Technology, Inc. 800 South Federal Way Boise, ID 83716 remalmgren~micron. com Snake River Alliance Ken Miller Clean Energy Program Director Boise, ID kmiler~snakeriveralliance. org IDAHO POWER COMPANY CASE No. IPC- E-II- DOE's FOURTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Arthur Perry Bruder Attorney for the United States Department of Energy