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
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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. )
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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
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Micron Technology, Inc.
MaryV. York
HOLLAND & HART LLP
101 South Capital Boulevard, Suite 1400
Boise, Idaho 83702
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Richard E. Malmgren
Senior Assistant General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
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Department of Energy
Arthur Perry Bruder, Attorney-Advisor
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
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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
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Community Action Partnership
Association of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1 ih Street
Boise, Idaho 83702
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Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
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Boise, Idaho 83701
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Snake River Allance
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Snake River Allance
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Boise, Idaho 83701
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NW Energy Coalition
Nancy Hirsh, Policy Director
NW Energy Coalition
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Seattle, Washington 98104
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~I~
~-- Wiliams
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 32