Loading...
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 DOE- DOE- DOE- DOE- DOE- DOE- DOE- DOE- 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