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HomeMy WebLinkAbout20110811IPC to Micron 2-1 to 2-26.pdfJASON B. WILLIAMS Corporate Counsel jwilliams(âidahopower.com ;SIDA.~~POR~ An IDACORP Company August 11, 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 filing are an original and one (1) copy of Idaho Power Company's Response to the Second Production Request of Micron Technology, Inc., to Idaho Power Company in the above matter. Also enclosed are three (3) copies of a non-confidential disk and three (3) copies of a confidential disk containing information being produced in response to Micron's Second Production Request. Please handle the enclosed confidential information in accordance with the Protective Agreement executed in this matter. Very truly yours,~~ ~~n'B. Wiliams "'c- 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: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(aidahopower.com dwalker(aidahopower.com jwilliams(aidahopower.com RECEí D zan AUG II Pti 4: 16 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 PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the Second Production Request of Micron Technology, Inc. to Idaho Power Company dated July 21, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 1 REQUEST NO. 2-1: For projects greater than $2.0 milion provide plant closings by month for each month of the test period by project. RESPONSE TO REQUEST NO. 2-1: Please see the column labeled "In Service Date" as well as columns 1 and 2 on pages 1 and 2 of Kelley Noe's Exhibit No. 22 that show the plant closing (in-service) date and amounts for projects greater than $2.0 million. Please also see the Excel file provided on the non-confidential CD for further detaiL. The response to this Request was prepared by Larry Tuckness, Finance Team Leader, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY. INC. TO IDAHO POWER COMPANY - 2 REQUEST NO. 2-2: Provide all spreadsheet, documents for other workpapers for all closings to plant during the test period. RESPONSE TO REQUEST NO. 2-2: Please see the Excel file provided on the non-confidential CD. The response to this Request was prepared by Larry Tuckness, Finance Team Leader, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY. INC. TO IDAHO POWER COMPANY - 3 REQUEST NO. 2-3: For all projects greater than $2.0 milion provide closings to plant for each of the last ten years by project and by month. RESPONSE TO REQUEST NO. 2-3: Please see the Excel file provided on the non-confidential CD. The response to this Request was prepared by Larry Tuckness, Finance Team Leader, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 4 REQUEST NO. 2-4: Provide all data, workpapers and spreadsheets used to develop forecast sales revenues by class and by month for the test year. RESPONSE TO REQUEST NO. 2-4: Please see the Company's response to Staff's Production Request NO.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 PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 5 REQUEST NO. 2-5: Provide the most recent marginal cost study prepared by the company. RESPONSE TO REQUEST NO. 2-5: Please see the Company's 2011 Marginal Cost Analysis filed in Docket No. UE 233 with the Public Utility Commission of Oregon on July 29, 2011, provided on the non-confidential CD. The methodology used to prepare this study is similar to that prepared for Case No. IPC-E-11-08 with two primary differences. First, the Idaho study calculates the marginal costs of generation and transmission, while the Oregon study calculates the marginal costs of generation, transmission, and distribution. Second, due to the later filng date, the Oregon study incorporates data from the 2011 Integrated Resource Plan ("IRP"), whereas the Idaho study utilizes data from the 2009 IRP. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Williams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 6 REQUEST NO. 2-6: Provide in electronic format the actual Excel workbooks used to prepare the cost of service studies, including all the input data and formulas. RESPONSE TO REQUEST NO. 2-6: Please see Exhibit Nos. 31-36 and all associated workpapers produced by the Company in its response to the Idaho Irrigation Pumpers Association Inc.'s ("IIPA") Data Request No. 26. 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 PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 7 REQUEST NO. 2-7: Provide all cost of service studies prepared by the Company for rate proceedings since 2000. RESPONSE TO REQUEST NO. 2-7: The cost-of-service study prepared for Case No. IPC-E-11-08 using 2011 test year data was produced by the Company in its response to the IIPA's Data Request No. 26. In addition, please see the non- confidential CD for cost-of-service studies in Excel format prepared for Case Nos. IPC- E-08-10, IPC-E-07-08, IPC-E-05-28, and IPC-E-03-13. 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 PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 8 REQUEST NO. 2-8: Provide the Company's most recent Integrated Resource Plan. RESPONSE TO REQUEST NO. 2-8: Idaho Power's 2011 IRP and supporting appendices can be found on the Company's website via the following link: http://ww.idahopower.com/AboutUs/PlanningForFuture/irp/2011/default.cfm. The response to this Request was prepared by M. Mark Stokes, Manager, Power Supply Planning, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 9 REQUEST NO. 2-9: Provide generation, maximum hourly generation, minimum hourly generation by month for all IPC owned resources for.each of the last 5 years. RESPONSE TO REQUEST NO. 2-9: Please see the Excel file provided on the non-confidential CD. The response to this Request was prepared by Sandy Ward, Operations Accountant II, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, and Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 10 REQUEST NO. 2-10: Provide monthly system retail sales and coincident peak loads for the last 10 years. RESPONSE TO REQUEST NO. 2-10: Please see the PDF file provided on the non-confidential CD. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 11 REQUEST NO. 2-11: Provide all LOLP or other capacity risk or load loss studies performed by or for the Company during the last 3 years. RESPONSE TO REQUEST NO. 2-11: Please see the Excel files provided on the confidential CD which provide two macro driven spreadsheets utilzed in 2009 and 2011 to analyze LOLP for the Integrated Resource Plan. These spreadsheets contain confidential data/proprietary softare and as such wil only be provided to those parties that have executed the Protective Agreement. The response to this Request was prepared by Ronald D. Schellberg, Consulting Engineer, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 12 REQUEST NO. 2-12: Provide monthly firm purchased energy amounts for all energy purchased by supplier for each month and each supplier for the last 3 years. RESPONSE TO REQUEST NO. 2-12: Please see the confidential information provided on the confidential CD, which wil be provided to those parties that have signed the Protective Agreement in this docket. The response to this Request was prepared by Sandy Ward, Operations Accountant ", Idaho Power Company, in consultation with Randy Henderson, Finance Team Leader, Idaho Power Company, and Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 13 REQUEST NO. 2-13: Provide all data, workpapers, spreadsheets and other documents used to develop the annualizing adjustments to rate base for the test year. RESPONSE TO REQUEST NO. 2-13: Please see the Excel files provided on the non-confidential CD. The response to this Request was prepared by Kelly Noe, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 14 REQUEST NO. 2-14: Provide all requests for proposals for firm energy purchases, including all requested terms and conditions, issued by IPC during the last 3 years. RESPONSE TO REQUEST NO. 2-14: The two firm requests for proposal Idaho Power has issued in the last three years, including all requested terms and conditions, are provided on the non-confidential CD. The response to this Request was prepared by Randy Henderson, Leader, Finance Team II, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 15 REQUEST NO. 2-15: Provide all workpapers, spreadsheets, documents and other materials to develop the test year results of operations and revenue deficiency. RESPONSE TO REQUEST NO. 2-15: All workpapers used to develop the test year were provided in the Company's response to the IIPA's Data Request No. 26. On July 11, 2011, a disk with the workpapers was mailed to the following people for Micron Technology, Inc.: Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 MaryV. York Thorvald A. Nelson Mark A. Davidson HOLLAND & HART LLP 6380 South Fiddlers Green Circle, Suite 500 Greenwood Vilage, Colorado 80111 The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 16 REQUEST NO. 2-16: What level of test year wheeling revenues is included in the IPC filng and where are they found and developed in this GRC filng? RESPONSE TO REQUEST NO. 2-16: Please see Jones Exhibit No. 14, page 1 of 23, lines 13 and 14. The response to this Request was prepared by Timothy E. Tatum, Senior Manager of Cost of Service, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 17 REQUEST NO. 2-17: How are test year wheeling revenues allocated in the Company filing. RESPONSE TO REQUEST NO. 2-17: Wheeling revenues are allocated using the D11 allocator. The D11 allocator is based upon the sum of each jurisdiction's 12 coincident peak ("CP") demands. Please see the Excel file provided on the non- confidential CD for the workpaper detailng the D11 allocator. The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 18 REQUEST NO. 2-18: Please identify the manner in which the test year wheeling revenues are allocated among state and federal jurisdictions. Provide work papers for same. RESPONSE TO REQUEST NO. 2-18: In the Jurisdictional Separation Study ("JSS"), the wheeling revenues are allocated based on the D11 allocator. The D11 allocator is based on the sum of each jurisdiction's 12 CP demands. In this rate case, the Company has requested to remove all allocations to the Firm Transfer customers, which are subject to the Company's Federal Energy Regulatory Commission's ("FERC") approved Open Access Transmission Tariff ("OATT") rate, and allocate all investment, revenues, and expenses to the state jurisdictions. The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 19 REQUEST NO. 2-19: What is the FERC Docket No. for the Company's last approved OA TT filing? RESPONSE TO REQUEST NO. 2-19: The last OATT Annual Informational Filing was filed under FERC Docket No. ER09-1641. The response to this Request was prepared by Tami White, Manager FERC and Regional Affairs, Idaho Power Company, in consultation with Jason B. Williams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 20 REQUEST NO. 2-20: What is the level of FERC Account 456.1 revenues that are contained in the Company's last approved OA TT filng. RESPONSE TO REQUEST NO. 2-20: Idaho Power is required to reflect short- term firm and non-firm point-to-point transmission revenues as a revenue credit in the calculation of its FERC OATT annual Total Transmission Revenue Requirement. Typically, this amount is reflected as a credit, or reduction, to the annual Total Transmission Revenue Requirement. However, the revenue credit included in the currently effective rates was a positive $3.7 milion due to a $14.3 milion out-of- period adjustment that more than offset the $10.6 millon in short-term firm and non-firm point- to-point transmission revenues that would have otherwise been revenue credited. The response to this Request was prepared by Tami White, Manager FERC and Regional Affairs, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 21 REQUEST NO. 2-21: When does the Company plan to file a new OATT filng with FERC? RESPONSE TO REQUEST NO. 2-21: Idaho Power wil file the annual update required under its OA TT formula rate with the FERC by September 1, 2011, for rates to be in effect October 1, 2011, through September 30, 2012. The response to this Request was prepared by Tami White, Manager FERC and Regional Affairs, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 22 REQUEST NO. 2-22: What is the most recent status of the Gateway West transmission project, including projected construction schedules, budgets, and expected completion dates of each segment of Gateway West? RESPONSE TO REQUEST NO. 2-22: The Gateway West project is being jointly developed by Rocky Mountain Power, a division of PacifiCorp, and Idaho Power Company. The companies are presently engaged in permitting the project within the National Environment Policy Act process. On Friday, July 29, 2011, the Bureau of Land Management ("BLM") released the Draft Environmental Impact Statement ("DE IS") to the public for review and comment. During the 90-day public comment period, which ends on October 28, 2011, the BLM wil be conducting 17 open house style public meetings that wil be held in locations along the proposed and alternate line routes. The DEIS is a significant milestone for the permitting of the Gateway West project. Following this process step, the BLM wil release the Final Environmental Impact Statement, followed by a Record of Decision ("ROD") and Notice to Proceed. The companies expect to receive the ROD in June 2014 with construction to be completed in phases thereafter based on the companies' transmission requirements. More information on the Gateway West project is available at: http://gatewaywestproject.com. At this point in the project timeline, specific construction schedules, budgets, and completion dates by segment are not available. In addition, no Gateway West project costs are included in this rate case. The response to this Request was prepared by Doug Dockter, Delivery Projects Manager, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 23 REQUEST NO. 2-23: For the most recent year that data are available, please identify all of the Company's OATT Long-Term Firm Point-to-Point transmission service customers and current revenues paid by same. RESPONSE TO REQUEST NO. 2-23: As reported on Idaho Powets 2010 FERC Form No.1, pages 328-330, OATT Long-Term Firm Point-to-Point customers and revenues for the calendar year 2010 were as follows: Customer PacifiCorp Seattle City Light Revenues $4,999,118 $1,645,532 The response to this Request was prepared by Tami White, Manager FERC and Regional Affairs, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 24 REQUEST NO. 2-24: For the most recent year that data are available, please identify all of the Company's OA TT Network Service customers and current revenues paid by same. RESPONSE TO REQUEST NO. 2-24: As reported on Idaho Powets 2010 FERC Form No.1, pages 328-330, OATT Network Integration Transmission Service customers and revenues for the calendar year 2010 were as follows: Customer Bonneville Power Administration - OTEC Bonneville Power Administration - USBR Bonnevile Power Administration - Raft River Bonnevile Power Administration - PF PacifiCorp Revenues $1,213,927 $1,186,608 $ 489,067 $1,842,418 $ 7,775 The response to this Request was prepared by Tami White, Manager FERC and Regional Affairs, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 25 REQUEST NO. 2-25: Please provide the annual wheeling revenues received by the Company for the last 5 years. Please distinguish between Account 456.1 and each other account for which these revenues are booked. RESPONSE TO REQUEST NO. 2-25: Please see the table below. Account 2006 2007 2008 2009 2010 456121 9,997,406.74 14,934,128.36 17,187,381.57 491,990.45 14,176,699.99 456122 725,998.31 1,294,962.41 1,135,908.23 558,882.36 1,221,701.78 456281 1,431,850.21 ---- 456282 1,581.90 Total 12,155,255.26 16,229,090.77 18,323,289.80 1,050,872.81 15,398,401.77 The response to this Request was prepared by Tami White, Manager FERC and Regional Affairs, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 26 REQUEST NO. 2-26: Are any of the transmission paths serving Idaho Power congested? Please identify and summarize any congested paths. RESPONSE TO REQUEST NO. 2.26: Yes, several of Idaho Power's internal transmission paths and paths which interconnect Idaho Power to neighboring states are congested. The following transmission paths are congested, defined as having no long- term firm available transmission capacity: Transmission Path Idaho-Northwest Transmission Lines Included in the Path The Idaho-Northwest transmission path consists of the 500 kilovolt ("kV") Hemingway-Summer Lake line, the three 230 kV lines between the Hells Canyon Complex and the Pacific Northwest, and the 115 kV interconnection at Harney substation near Burns, Oregon. The Idaho- Northwest path is most likely to be capacity limited during summer months in low to normal water years due to transmission-wheeling obligations for BPA's eastern Oregon and south Idaho loads and energy imports from the Pacific Northwest to serve Idaho Powets retail load. Brownlee East The Brownlee East transmission path is on the east side of the Idaho-Northwest Interconnection. Brownlee East is comprised of the 230 kV and 138 kV lines east of the Hells Canyon Complex and Quart substation, near Baker City, Oregon. When the Hemingway-Summer Lake 500 kV line is included with the Brownlee East path, the path is typically referred to as the Brownlee East Total path. The capacity limitation on the Brownlee East transmission path is located between Brownlee and the Treasure Valley. The Brownlee East transmission path has different capacity limitations than the Northwest path. The 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 into the Treasure Valley, concurrent with transmission-wheeling obligations for BPA's eastern Oregon and southern Idaho loads and Idaho Power energy imports from the Pacific Northwest. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 27 Idaho-Montana The Idaho-Montana transmission path consists of the Antelope-Anaconda 230 kV and Jefferson-Dilon 161 kV transmission lines. The Idaho-Montana path is also capacity limited during the summer months as Idaho Power and others move energy south from Montana into Idaho. Borah West The Borah West transmission path is internal to the Idaho Power system. The path is comprised of 345 kV, 230 kV, and 138 kV transmission lines west of the Borah substation, located near American Falls, Idaho. Idaho Powets share of energy from the Jim Bridger plant flows over this path, as well as east-side hydroelectric and energy imports from Montana, Wyoming, and Utah. The Borah West path is capacity limited during summer months due to transmission-wheeling obligations coinciding with high eastern thermal and wind production. Heavy path flows are also likely to exist during the light load hours of the fall and winter months as high eastern thermal and wind production moves east to west across the system. Midpoint West The Midpoint West path is an internal path comprised of the 230 kV and 138 kV transmission lines west of Midpoint substation, located near Jerome, Idaho. Capacity on the Midpoint West path is fully subscribed with east-side Idaho Power resources and energy imports. Similar to the Borah West path, the heaviest path flows are likely to exist during the fall and winter when significant wind and thermal generation is present east of the path. Idaho-Nevada The Idaho-Nevada transmission path is comprised of the 345 kV Midpoint-Humboldt line. The available import, or northbound, capacity on the transmission path is fully subscribed with Idaho Powets share of the Valmy generation plant. The response to this Request was prepared by David Angell, Delivery Planning Manager, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 28 DATED at Boise, Idaho, this 11 th day of August 2011.,- ,. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 29 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX .. Email Don.Howell(apuc.idaho.gov Karl T. Klein Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX .. Email KarI.Klein(apuc.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 Hand Delivered U.S. Mail _ Overnight Mail FAX .. Email peter(arichardsonandoleary.com greg(arichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX .. Email dreading(amindspring.com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED 201 East Center P.O. Box 1391 Pocatello, Idaho 83204-1391 Hand Delivered U.S. Mail _ Overnight Mail FAX .. Email elo(aracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 30 Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email tony(ayankel.net Kroger Co. Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email kboehm(aBKLlawfirm.com jrh(abattisher.com Kevin Higgins Energy Strategies, LLC 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email khiggins(aenergystrat.com Micron Technology, Inc. MaryV. York HOLLAND & HART LLP 101 South Capital Boulevard, Suite 1400 Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email myork(ahollandhart.com tnelson(ahollandhart.com madavidson(ahollandhart.com fschm idt(aholland hart. com Inbuchanan(ahollandhart.com Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email remalmgren(amicron.com Department of Energy Arthur Perry Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Arthur.bruder(ahg.doe.gov Steven. porte r(a hg .doe.gov IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 31 Dwight D. Etheridge Exeter Associates, Inc. 10480 Little Patuxent Parkway, Suite 300 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email detheridge(aexeterassociates.com Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email bmpurdy(ahotmail.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email botto(aidahoconservation.org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email kmiler(asnakeriverallance.org NW Energy Coalition Nancy Hirsh, Policy Director NW Energy Coalition 811 First Avenue, Suite 305 Seattle, Washington 98104 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email nancy(anwenergy.org ~I~ ~-- Wiliams IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 32