HomeMy WebLinkAbout20110811DOE Third 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-11-
S. DOE's Third 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 TUESDAY, AUGUST 9, 2011.
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 THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
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Please provide the document referred to by Mr. Larkin on page 24, 9-
and that is included in his workpapers, in native format (e., Adobe
Word).
Please provide Idaho Power s "estimated demand reductions achieved
through the respective DR programs" that were used to derive system
coincident demand factors in this case, both by program (i., Irrigation
Peak Rewards, A/C Cool Credit, and FlexPeak Management) and in total
and on an hourly basis to the extent these reductions were estimated on an
hourly basis, in native format (e., Excel) with all links and formulas
intact (if applicable). (M. Larkin, p. 23, 22-25.) Please also provide the
derivation of the requested demand reduction information.
Please provide Idaho Power s estimated demand reductions by DR
program and in total for the years 2006 through 2010, and on an hourly
basis to the extent these reductions were estimated on an hourly basis, in
native format (e., Excel) with all links and formulas intact (if
applicable). Please also provide the derivation of the requested demand
reduction information.
Please provide Idaho Power s "historical hourly system loads" and "(tJhe
resulting load shape" that were used to derive system coincident demand
factors in this case, on an hourly basis in native format (e., Excel) with
all links and formulas intact (if applicable). (M. Larkin, p. 23, 22-25.
Please provide all workpapers that show how "(tJhe adjusted data was then
used to determine the hour that the system peak would have occurred
absent DR programs" in native format (e., Excel) with all links and
formulas intact (if applicable). (M. Larkin, p. 24
Please provide all workpapers that show how "system coincident demand
factors were calculated according to the adjusted peak hour and historical
usage data" in native format (e., Excel) with all links and formulas intact
(if applicable), and please include the referenced historical usage data.
(M. Larkin, p. 24, 3-
Please provide all workpapers that show how "these factors were applied
to forecast average demand to derive coincident peak demands by rate
class for each month of the test period" in native format (e., Excel) with
all links and formulas intact (if applicable), and please include the
referenced forecast average demand. (M. Larkin, p. 24, 7-
Please provide the document referred to by Mr. Larkin on page 24, 22-
in native format (e., Adobe, Word).
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-
DOE-10.
Per Mr. Larkin, page 19, 17-
, "
the Company used 2010 load research
data to derive the coincident demand values used in the cost-of-service
study prepared in this proceeding.
(a) Please provide the referenced 2010 load research data in native format
(e., Excel) with all links and formulas intact (if applicable).
(b) Please provide all hourly class load shapes Idaho Power has
developed from its 2010 load research data in native format (e.
Excel) with all links and formulas intact (if applicable).
Mr. Tatum explains his responsibilities to include overseeing the
Company s cost-of-service activities, including marginal cost studies. (T.
Tatum, p. 3, 3-) Please respond to the following information requests
related to generation capacity marginal costs.
(a) Please provide the inputs and calculations currently used by Idaho
Power to calculate generation capacity marginal cost in native format
(e., Excel) with all links and formulas intact (if applicable). Please
explain Idaho Power s rationale for calculating generation capacity
marginal cost in this manner.
(b) Please provide the inputs and calculations currently used by Idaho
Power to seasonalize generation capacity marginal cost in native
format (e., Excel) with all links and formulas intact (if applicable).
Please explain Idaho Power s rationale for seasonalizing generation
capacity marginal cost in this manner.
( c) Please explain how Idaho Power utilizes generation capacity marginal
costs in the normal course of its business (e., rate design studies
demand side management studies, contract negotiations), and please
explain why Idaho Power utilizes those marginal cost estimates in the
manner that it does.
(d) To what extent have Idaho Power s generation capacity marginal
costs varied on both an annual and seasonal basis over the period
from and including Idaho Power s 2002 Integrated Resource Plan
through the present? What has been the primary factor( s) that has
caused Idaho Power s annual generation capacity marginal cost to
vary over this time period? What has been the primary factor(s) that
has caused Idaho Power s seasonalized generation capacity marginal
costs to vary over this time period?
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-11.
(e) To what extent does Idaho Power believe its generation capacity
marginal costs will vary on both an annual and seasonal basis over the
period from and including Idaho Power s 2011 Integrated Resource
Plan through 2015? What does Idaho Power believe will be the
primary factor(s) that will cause Idaho Power s annual generation
capacity marginal cost to vary over this time period? What does
Idaho Power believe will be the primary factor(s) that will cause
Idaho Power s seasonalized generation capacity marginal costs to
vary over this time period?
Mr. Tatum explains his responsibilities to include overseeing the
Company s cost-of-service activities, including marginal cost studies. (T.
Tatum, p. 3, 3-) Please respond to the following information requests
related to transmission capacity marginal costs.
(a) Please provide the inputs and calculations currently used by Idaho
Power to calculate transmission capacity marginal cost in native
format (e., Excel) with all links and formulas intact (if applicable).
Please explain Idaho Power s rationale for calculating transmission
capacity marginal cost in this manner.
(b) Please provide the inputs and calculations currently used by Idaho
Power to seasonalize transmission capacity marginal cost in native
format (e., Excel) with all links and formulas intact (if applicable).
Please explain Idaho Power s rationale for seasonalizing transmission
capacity marginal cost in this manner.
( c) Please explain how Idaho Power utilizes transmission capacity
marginal costs in the normal course of its business (e., rate design
studies, demand side management studies, contract negotiations), and
please explain why Idaho Power utilizes those marginal cost estimates
in the manner that it does.
(d) To what extent have Idaho Power s transmission capacity marginal
costs varied on both an annual and seasonal basis over the period
from and including Idaho Power s 2002 Integrated Resource Plan
through the present? What has been the primary factor( s) that has
caused Idaho Power s annual transmission capacity marginal cost to
vary over this time period? What has been the primary factor(s) that
has caused Idaho Power seasonalized transmission capacity
marginal costs to vary over this time period?
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-12.
DOE-13.
(e) To what extent does Idaho Power believe its transmission capacity
marginal costs will vary on both an annual and seasonal basis over the
period from and including Idaho Power s 2011 Integrated Resource
Plan through 2015? What does Idaho Power believe will be the
primary factor(s) that will cause Idaho Power s annual transmission
capacity marginal cost to vary over this time period? What does
Idaho Power believe will be the primary factor(s) that will cause
Idaho Power s seasonalized transmission capacity marginal costs to
vary over this time period?
A discussion of marginal costs is included in Exhibit No. 30, page 5, in the
paragraph that begins "(tJhe marginal costs associated with new resource
integration. "
(a) Please explain what Idaho Power means by "(tJhe marginal costs
associated with new resource integration." Please provide the inputs
and calculations currently used by Idaho Power to calculate those
marginal costs in native format (e., Excel) with all links and
formulas intact (if applicable).
(b) Please explain what Idaho Power means by "(tJhe marginal costs
associated with planned system expansions.Please provide the
inputs and calculations currently used by Idaho Power to calculate
those marginal costs in native format (e., Excel) with all links and
formulas intact (if applicable).
Per Mr. Larkin, page 31, 1-, Idaho Power s "(uJpdated marginal energy
costs were calculated for the five-year period 2011 through 2015." Also
Idaho Power explains in Exhibit No. 30, page 5, that "(uJpdated marginal
energy costs are calculated by quantifying the difference in net power
supply costs resulting from the addition of 50 megawatts of load to all
hours of the Company s base case system simulation run for the five-year
planning period.Please respond to the following information requests
related to Idaho Power s marginal energy costs.
( a) Please explain Idaho Power s rationale for calculating marginal
energy costs in this manner.
(b) Please provide total net power supply costs from the base case system
simulation run by month for the planning period 2011 through 2015 in
Excel format.
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
( c) Please provide net power supply costs from the base case system
simulation run by month for the planning period 2011 through 2015 in
Excel format disaggregated by source of supply for the following cost
categories: costs associated with coal-fired plants; costs associated
with hydropower plants; costs associated with purchased power; costs
associated with natural gas-fired combined cycle plants; costs
associated with natural gas-fired combustion turbines; revenues
associated with surplus sales; and all other costs.
(d) Please provide Idaho Power s natural gas price inputs from the base
case system simulation run by month for the planning period 2011
through 2015 in Excel format.
( e) Please provide Idaho Power s wholesale market electricity price
inputs from the base case system simulation run by month for the
planning period 2011 through 2015 in Excel format. If Idaho Power
used different price inputs to model purchases and sales, please
provide both sets of price inputs.
(f) Please provide total net power supply costs by month for the planning
period 2011 through 2015 in Excel format from the simulation run
that includes incremental loads of 50 megawatts above the base case
simulation in all hours.
(g) Please provide net power supply costs from the simulation run that
includes incremental loads of 50 megawatts above the base case
simulation in all hours by month for the planning period 2011 through
2015 in Excel format disaggregated by source of supply for the
following cost categories: costs associated with coal-fired plants;
costs associated with hydropower plants; costs associated with
purchased power; costs associated with natural gas-fired combined
cycle plants; costs associated with natural gas-fired combustion
turbines; revenues associated with surplus sales; and all other costs.
(h) Please provide Idaho Power s incremental marginal energy costs by
month and by hour for the planning period 2011 through 2015 in
Excel format. Please also provide the derivation of the requested
marginal energy costs.
(i) Please provide total net power supply costs by month for the planning
period 2011 through 2015 in Excel format from a simulation run that
includes decremental loads of 50 megawatts below the base case
system simulation in all hours.
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-14.
DOE-15.
G) Please provide net power supply costs from a simulation run that
includes decremental loads of 50 megawatts below the base case
system simulation in all hours by month for the planning period 2011
through 2015 in Excel format disaggregated by source of supply for
the following cost categories: costs associated with coal-fired plants;
costs associated with hydropower plants; costs associated with
purchased power; costs associated with natural gas-fired combined
cycle plants; costs associated with natural gas-fired combustion
turbines; revenues associated with surplus sales; and all other costs.
(k) Please provide Idaho Power s decremental marginal energy costs by
month and by hour for the planning period 2011 through 2015 in
Excel format based upon the previously requested decremental net
power supply cost simulation and Idaho Power s base case system
simulation. Please also provide the derivation of the requested
marginal energy costs.
(I) To what extent have Idaho Power s marginal energy costs varied on
both an annual and seasonal basis over the period from and including
Idaho Power s 2002 Integrated Resource Plan through the present?
What has been the primary factor(s) that has caused Idaho Power
annual and monthly marginal energy costs to vary over this time
period?
(m) What does Idaho Power believe will be the primary factor(s) that will
cause Idaho Power s annual and monthly marginal energy costs to
vary over the planning period 2011 through 2015?
In Idaho Power s 2011 Integrated Resource Plan, page 57, Idaho Power
states
, "
(h Jistorically, Idaho Power has been a summer peaking utility with
peak loads driven by irrigation pumps and air conditioning in the months
of June, July, and August."
(a) Please provide the information relied upon by Idaho Power in making
this statement.
(b) Over what historical time period does Idaho Power believe this
statement is true?
In Idaho Power s 2011 Integrated Resource Plan, page 60, Idaho Power
states
, "
(sJummertime peak-hour load growth accelerated in the previous
decade as air conditioning became standard in nearly all new residential
home construction and new commercial buildings.
(a) Please provide the information relied upon by Idaho Power in making
this statement.
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-16.
DOE-17.
DOE-18.
DOE-19.
In Idaho Power s 2011 Integrated Resource Plan, page 60, Idaho Power
states
, "
(iJn another improvement to this year s forecast, Idaho Power used
Itron, Inc.s residential Statistically Adjusted End-Use (SAE) model to
prepare the long-term residential sales forecast. Recently, many utilities
have adopted Itron, Inc.' s SAE modeling approach to include greater end-
use information into the forecasting process.
(a) Please list the end-use information Idaho Power utilized to develop its
residential sales forecast.
(b) Please provide the historical and projected end-use information on
residential air conditioning utilized by Idaho Power in its forecast
model development.
Please list, describe, and provide in Excel format the hourly load shapes
used by Idaho Power in the preparation of its 2011 Integrated Resource
Plan. Please also provide the derivation of the requested hourly load
shapes.
Mr. Sparks describes the Company s proposed methodology that was used
to calculate the proposed rate component adjustments for Schedules 7, 9
and 19. (S. Sparks, p. 4, 1-19.
(a) Please provide workpapers in native format (e., Excel) with all links
and formulas intact (if applicable) that show specifically how this
methodology was applied in developing the proposed Schedule 19
secondary voltage rate components shown on Exhibit No. 47, page 6.
(b) Please provide workpapers in native format (e., Excel) with all links
and formulas intact (if applicable) that show specifically how this
methodology was applied in developing the proposed Schedule 19
primary voltage rate components shown on Exhibit No. 47, page 7.
(c) Please provide workpapers in native format (e., Excel) with all links
and formulas intact (if applicable) that show specifically how this
methodology was applied in developing the proposed Schedule 19
transmission voltage rate components shown on Exhibit No. 47, page
Idaho Power s proposed rate design for Schedule 24 includes a proposal
that "the Company is proposing to move the individual rate components 5
percent closer to the costs indicated by" the Company s class cost-of-
service study. (S. Sparks, p. 15, 8-12.
(a) Please provide workpapers in native format (e., Excel) with all links
and formulas intact (if applicable) that show specifically how this
methodology was applied in developing the proposed Schedule 24
secondary voltage rate components shown on Exhibit No. 47, page 9.
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-20.
DOE-21.
DOE-22.
DOE-23.
DOE-24.
Idaho Power s Exhibit No. 45 includes Idaho Power s proposed projected
2011 test-year billing determinants for multiple residential rate classes.
(D. Nemnich, Exhibit No. 45.Please provide the historical actual
monthly billing determinants for the period 2006 through the present for
rate class Schedules 1 , 3, 4, and 5 in Excel format. Please explain changes
in the definitions of billing determinants over this time period, if any. To
the extent available, please provide the weather normalized billing
determinants for these rate schedules over the same time period.
Idaho Power s Exhibit No. 47 includes Idaho Power s proposed projected
2011 test-year billing determinants for multiple non-residential rate
classes. (S. Sparks, Exhibit No. 47.) Please provide the historical actual
monthly billing determinants for the period 2006 through the present for
rate class Schedules 7, 9, 19, and 24 by voltage level, if applicable, in
Excel format. Please explain changes in the definitions of billing
determinants over this time period, if any. To the extent available, please
provide the weather normalized billing determinants for these rate
schedules over the same time period.
Idaho Power s Exhibit No. 43 includes Idaho Power s proposed projected
2011 test-year billing determinants for multiple non-residential rate
classes. (M. Youngblood, Exhibit No. 43.) Please provide the historical
actual monthly billing determinants for the period 2006 through the
present for rate class Schedules 26, 29, 30, and 32 in Excel format. Please
explain changes in the definitions of billing determinants over this time
period, if any. To the extent available, please provide the weather
normalized billing determinants for these rate schedules over the same
time period.
Idaho Power "used 2010 load research data to derive the coincident
demand values used in the cost-of-service study prepared in this
proceeding" rather than "the five-year median approach." (M. Larkin
, p.
, 11-20.) Please provide the data that would be necessary to calculate
the five-year median approach in Excel format.
In Idaho Power s 2011 Integrated Resource Plan, page 79, Idaho Power
states
, "
(h Jistorically, Idaho Power has been a summer peaking utility,
while most other utilities in the Pacific Northwest experience system peak
loads during the winter.
(a) Please provide the information relied upon by Idaho Power in making
this statement.
(b) Over what historical time period does Idaho Power believe this
statement is true?
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-25.
DOE-26.
DOE-27.
In Idaho Power s 2011 Integrated Resource Plan, page 79, Idaho Power
states
, "
Idaho Power purchases energy from the Mid-Columbia energy
trading market to meet peak summer load and sells excess energy to
Pacific Northwest utilities during winter and spring.
(a) Please provide the information relied upon by Idaho Power in making
this statement.
(b) Over what historical time period does Idaho Power believe this
statement is true?
( c) What is the magnitude of purchases in megawatt-hours that Idaho
Power made to "meet peak summer load" during each summer month
over the time period beginning in 2006 and continuing through the
present? Please also provide the derivation of the requested
information on purchases.
(d) Are the purchases made by Idaho Power to meet peak summer loads
independent of the excess sales Idaho Power makes to Pacific
Northwest utilities during winter and spring? Please explain.
In Idaho Power s 2011 Integrated Resource Plan, page 79, while referring
to its practice of making purchases from the Mid-Columbia energy trading
market to meet peak summer load and selling excess energy to Pacific
Northwest utilities during winter and spring, Idaho Power states
, "
(tJhis
practice benefits the environment and Idaho Power s customers because
the construction of additional peaking resources to serve summer peak
load is delayed or avoided, revenue from off-system sales during the
winter and spring is credited to customers through the PCA, and revenue
from others' use of the transmission system is credited to customers in
general rates.
(a) Please provide the information relied upon by Idaho Power in making
this statement.
(b) Over what historical time period does Idaho Power believe this
statement is true?
( c) Please quantify the magnitude of peaking resources that have been
delayed or avoided" as a result of this practice. Please also provide
the derivation of the requested information on peaking resources.
In Idaho Power s 2011 Integrated Resource Plan, pages 81-, Idaho
Power states
, "
(tJhe Idaho-Northwest path is most likely capacity-limited
during summer months in low-to-normal water years due to transmission-
wheeling obligations for BP A's eastern Oregon and south Idaho loads and
energy imports from the Pacific Northwest to serve Idaho Power s retail
load.
(a) Please provide the information relied upon by Idaho Power in making
this statement.
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(b) Over what historical time period does Idaho Power believe this
statement is true?
DOE-28.
(c) For the period 2006 through the present, please explain when this
transmission path was capacity-constrained with respect to Idaho
Power s ability to use this path to import power to serve its retail load.
(d) For the period 2006 through the present, please explain when this
transmission path was not capacity-constrained with respect to Idaho
Power s ability to use this path to import power to serve its retail load.
In Idaho Power s 2011 Integrated Resource Plan, page 82, Idaho Power
states
, "
(tJhe Brownlee East path is most likely to face capacity limitations
in the summer during normal-to-high water years. The capacity
limitations result from a combination of Hells Canyon Complex
hydroelectric generation flowing east to the Treasure Valley, concurrent
with transmission-wheeling obligations for BP A's eastern Oregon and
southern Idaho loads and Idaho Power energy imports from the Pacific
Northwest. "
(a) Please provide the information relied upon by Idaho Power in making
this statement.
(b) Over what historical time period does Idaho Power believe this
statement is true?
DOE-29.
(c) For the period 2006 through the present, please explain when this
transmission path was capacity-constrained with respect to Idaho
Power s ability to use this path to import power to serve its retail load.
(d) For the period 2006 through the present, please explain when this
transmission path was not capacity-constrained with respect to Idaho
Power s ability to use this path to import power to serve its retail load.
In Idaho Power s 2011 Integrated Resource Plan, page 82, Idaho Power
states
, "
(tJhe Idaho-Montana path is also capacity-limited during the
summer months as Idaho Power and others move energy south from
Montana into Idaho.
(a) Please provide the information relied upon by Idaho Power in making
this statement.
(b) Over what historical time period does Idaho Power believe this
statement is true?
(c) For the period 2006 through the present, please explain when this
transmission path was capacity-constrained with respect to Idaho
Power s ability to use this path to import power to serve its retail load.
(d) For the period 2006 through the present, please explain when this
transmission path was not capacity-constrained with respect to Idaho
Power s ability to use this path to import power to serve its retail load.
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-30.
DOE-31.
DOE-32.
DOE-33.
DOE-34.
In Idaho Power s 2011 Integrated Resource Plan, page 83, while referring
to the Idaho-Utah path, which is referred to as Path C, Idaho Power states
(tJhe path effectively feeds into Borah West path when power is moving
from east-to-west and, consequently, the import capability of Path C is
limited by Borah West path capacity limitations." In Idaho Power s 2011
Integrated Resource Plan, page 82, while referring to the Borah West path
Idaho Power states
, "
(tJhe Borah West path is capacity constrained during
summer months due to transmission wheeling obligations coinciding with
high eastern thermal and wind production.
(a) Please provide the information relied upon by Idaho Power in making
these statements.
(b) Over what historical time period does Idaho Power believe these
statements are true?
(c) For the period 2006 through the present, please explain when Path C
or Borah West were capacity-constrained with respect to Idaho
Power s ability to use these paths to import power to serve its retail
load.
(d) For the period 2006 through the present, please explain when Path C
or Borah West were not capacity-constrained with respect to Idaho
Power s ability to use these paths to import power to serve its retail
load.
Please define the Treasure Valley load center from a geographical
perspective, and also from an electrical perspective using Idaho Power
transmission facilities to describe the boundaries of this load center.
Please provide the peak load and annual energy during 2010 for loads
within the Treasure Valley load center.
Please provide the peak load and annual energy during 2010 for loads
located east of Midpoint West path and west of Borah West path.
Please provide the peak load and annual energy during 2010 for loads
located east of Borah West path.
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-35.In Idaho Power s 2011 Integrated Resource Plan, page 122, Idaho Power
states
, "
(tJhe preferred portfolio also includes a market purchase from the
east side of Idaho Power s system. The purchase is necessary to cover a
summer peak-hour deficit in 2015 that exists before the Boardman to
Hemingway line becomes available in 2016. Idaho Power has used the
east side for market purchases in the past, but prices have historically been
higher than the prices at the Mid-C hub in the Pacific Northwest. A
purchase on the east side does not require substantial lead time, and Idaho
Power will continue to monitor market prices, load growth, and the status
of the Boardman to Hemingway project prior to committing to this
purchase.
(a) Is the peak-hour deficit to which Idaho Power refers the 83 megawatt
deficit shown under the row heading "2015 Eastside Purchase" in July
2015 listed in Idaho Power s 2011 Integrated Resource Plan
Appendix C, page 48?
(b) Please explain the energy figures shown under the row heading "2015
Eastside Purchase" on Idaho Power s 2011 Integrated Resource Plan
Appendix C, page 26.
( c) Please provide specific examples of east side purchases that Idaho
Power has made in the past, and list the actual eastside purchases that
were made during the period including 2006 through the present."
(d) Please provide the information relied upon by Idaho Power in making
the statement that "prices have historically been higher than the prices
at the Mid-C hub in the Pacific Northwest."
(e) Please explain exactly what Idaho Power meant when it said "(aJ
purchase on the east side does not require substantial lead time.
(f) Over which transmission path (e., Idaho-Utah path) does Idaho
Power anticipate making this purchase?
At Washington, D., this 19th day of July, 2011.
Arthur Perry Bruder
Attorney for the United States
Department of Energy
Phone: (202) 586-3409
Fax: (202) 586-7479
Arthur.Bruder~hq. doe.gov
IDAHO POWER COMPANY CASE No. IPC- E-II-
DOE's THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
CERTIFICATE OF SERVICE
I hereby certify that, this 19th day of July, 2011 , I served the foregoing first production
request of the United States Department of Energy to Idaho Power Company, in Case No.
IPC- 11- 08, by emailing it, and by mailing 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
Inordstrom~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 THIRD 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 THIRD 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 80111
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 THIRD REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
Arthur Perry Bruder
Attorney for the
United States Department of Energy