20110811Kroger Q2-1 - Q2-2 to IPC.pdf

BOEHM, KURTZ & LOWRY
ATIORNS AT lAW
36 EAT SEV STRET
SUITE 1510
CICINNATI. OHIO 45202
TELEPHONE [phone]
TELECOPIER [phone]
RECEIVED
2011 AUG I I PH 2: 18
, r""L II
VI OVERNGHT MA
August 10,2011
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
In re: Case No. IPC-E-ll-08
Dear Ms. Jewell:
Enclosed please find the original and (7) copies of the SECOND SET OF INTERROGATORIS OF
THE KROGER CO. to IDAHO POWER COMPANY to be filed in the above referenced matter.
Please place this document of fie. Copies have been served on all parties listed on the attached
Certificate of Service.
KJkew
Enc!.
G:\WORK\MLK\KROGER\IDAHO\IPC-E-II-08\Commission Data Request letter.docx
CERTIFICATE OF SERVICE
I hereby certfY that tre copy of the foregoing was seed bj. ~ o~v.e eit . hit rn mal, unles otherwse noted this10" day of August, 2011 to the following: _\U~
Kurt J. Boehm, Esq.
IDAHO POWER COMPANY
Lisa D. Nordstrom
Donovan E. Walker
Jason B. Wiliams
Idaho Power Company
1221 W. Idaho Sf. (83702)
PO Box 70
Boise, ID 83707-0070
E-mail: lnordstrom(iidahopower.com
dwalker(iidahopower.com
iwiliams(iidaopower.com
Anthony Yanice1
29814 Lake Road
Bay Vilage, OH 44140
E-mail: tonwyankel.net
Gregory W. Said
Vice President, Regulatory Affairs
Idaho Power Company
1221 W. Idaho Sf. (83702)
PO Box 70
Boise, ID 83707-0070
E-mail: gsaid(iidahopower.com
INDUSTRIAL CUSTOMERS OF IDAHO
POWER:
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 77th Street
PO Box 7218
Boise, ID 83702
E-mail: peter(irichardsonandolearv.com
greg(irichardsonandoleary.com
Don Reading
6070 Hil Road
Boise, ID 83703
E-mail: dreading(imindspring.com
COMMISSION STAFF:
Donald L. Howell, II
Karl Klein
Deputy Attorneys General
Idaho Public Utilities Commission
472 W, Washington (83702)
PO Box 83720
Boise, ID 83720-0074
E-mail: don.howellCáuc.idaho.gov
karl.k1ein(ipuc.idaho.gov
THE UNITED STATES DEPARTMENT OF
ENERGY:
Arhur Perr Bruder
Attomey- Advisor
United States Department of Energy
1000 Independence Ave., SW
Washington, DC 20585
Email: Arhur.bruder(ihg.doe.gov
IDAHO IRRGATION PUMPERS
ASSOCIATION, INC:
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chartered
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-mail: e1o(i.racine1aw.net
Dwight Etheridge
Exeter Associates, Inc.
5565 Sterrett Place
Suite 310
Columbia, MD 21044
Email: detheridge(iexeterassociates.com
G:\WORK\MLK\KROGER\IDAHO\IPC-E-II-08\Commission Data Request letter.docx
Steven A. Porter
Assistant General Counsel
Electricity and Fossil Energy
United State Department of Energy
E-mail: steven.porterßYhg.doe.gov
COMMUITY ACTION PARTNRSHIP
ASSOCIATION OF IDAHO:
Brad M. Purdy, Attorney at Law
2019N.17thSt.
Boise, ID 83702
E-mail: bmpurdycqhotmai1.com
MICRON TECHNOLOGY, INC:
Richard E. Malmgren
Sr. Asst. General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, ID 83716
E-mail: remalmgrn(imicron.com
MaryV. York
Thorvald A. Nelson
Mark A. Davidson
Holland & Har, LLP
6800 S. Fiddlers Green Circle
Suite 500
Greenwood Village, CO 80 ILL
Email: rnyorkcqhollandhart.com
tnelson(ihollandhrt.com
madavidsoncqhollandhart.com
IDAHO CONSERVATION LEAGUE:
Benjamin J. Otto
Idaho Conservation League
710 N. Sixth Street
POBox 844
Boise, ID 83701
Email: botto(iidahoconservation.org
SNAKE RIVER ALLIANCE:
Ken Miler
Snake River Alliance
PO Box 1731
Boise, ID 83701
Email: kmilercqsnakeriveralliance.org
G:\WORK\MLK\KROGER\IDAHO\IPC-E-II-08\Commission Data Request letter.docx
John R. Hammond, Jr., ISB No. 5470
BATT FISHER PuSCH & ALDERMN, LLP
U.s. Ban Plaza, 5th Floor
101 S. Capitol Boulevard, Suite 500
P.O. Box 1308
Boise, Idaho 83701
Telephone: [phone]
Facsimile: 208.331.2400
E-mail: jrhigbattsher.com
RECEIVED
ioii AUG II PH 2: fa
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 E. Seventh St., Suite 1510
Cincinati, Ohio 45202
Telephone: [phone]
Facsimile: 513.421.2764
E-mail: KBoehmigbkllawfirm.com
Attorneys for Kroger Co.
BEFORE TH IDAHO PUBLIC UTILITIES COMMSSION
IN TH MATTER OF THE APPLICATION ) Case No. IPC-E-11-08
OF IDAHO POWER COMPAN FOR )
AUTHORITY TO INCREASE ITS RATES ) SECOND SET OF INTERROGATORIS
AND CHAGES FOR ELECTRIC SERVICE TO ) OF KROGER CO. TO IDAHO POWER
ITS CUSTOMERS IN THE STATE OF IDAHO ) COMPAN
)
)
SECOND SET OF INTERROGATORIS OF
THE KROGER CO.
TO IDAHO POWER COMPAN
August 10,2011
DEFINTIONS
1. "Document" means the original and all copies (regardless of origin and whether or not including
additional writing thereon or attched thereto) of memoranda, report, books, manuals, instrctions,
directives, records, forms, notes, letters, notices, confirmations, telegrams, pamphlets, notations of any
sort concerning conversations, telephone calls, meetings or other communications, bulletins, transcripts,
diaries, analyses, summares, correspondence investigations, questionnaires, surveys, worksheets, and all
drafts, preliminar versions, alterations, modifications, revisions, changes, amendments and written
comments concerning the foregoing, in whatever form, stored or contained in or on whatever medium,
including computeried memory or magnetic media.
2. "Study" means any written, recorded, transcribed, taped, filmed, or graphic matter, however produced or
reproduced, either formally or informally, a paricular issue or sitution, in whatever detail, whether or
not the consideration of the issue or situation is in a preliminary stage, and whether or not the
consideration was discontinued prior to completion.
3. "Person" means any natual person, corporation, professional corporation, parership, association, joint
ventue, proprietorship, fir, or the other business enterprise or legal entity.
4. A request to identify a natual person means to state his or her full name and residence address, his or her
present last known position and business affiiation at the time in question.
5. A request to identify a document means to state the date or dates, author or originator, subject matter, all
addressees and recipients, tye of document (e.g., letter, memorandum, telegram, char, etc.), number of
code number thereof or other means of identifying it, and its present location and custodian. If any such
document was, but is no longer in the Company's possession or subject to its control, state what
disposition was made of it.
6. A request to identify a person other than a natual person means to state its full name, the address of its
principal office, and the tye of entity.
7. "And" and "or" should be considered to be both conjunctive and disjunctive, unless specifically stated
otherwise.
8. "Each" and "any" should be considered to be both singular and plural, unless specifically stated
otherwise.
9. Words in the past tense should be considered to include the present, and words in the present tense
include the past, unless specifically stated otherwise.
10. "You" or ''yout' means the person whose filed testimony is the subject of these interrogatories and, to the
extent relevant and necessar to provide full and complete answers to any request, ''you'' or ''your'' may
be deemed to include any person with information relevant to any interrogatory who is or was employed
by or otherwise associated with the witness or who assisted, in any way, in the preparation of the witness'
testimony.
11. Idaho Power Co. ("Company") means any of their offcers, directors, employees, or agents who may have
knowledge of the paricular matter addressed.
INSTRUCTIONS
1. If any matter is evidenced by, referenced to, reflected by, represented by, or recorded in any document,
please identify and produce for discovery and inspection each such document.
2. These interrogatories are continuing in nature, and inormation which the responding par later becomes
aware of, or has access to, and which is responsive to any request is to be made available to Fred Meyer
Stores, studies, documents, or other subject matter not yet completed that wil be relied upon durg the
course of this case should be so identified and provided as soon as they are completed. The Respondent is
obliged to change, supplement and correct all answers to interrogatories to conform to available
information, including such information as it first becomes available to the Respondent after the answers
hereto are served.
3. Unless otherwise expressly provided, each interrogatory should be constred independently and not with
reference to any other interrogatory herein for purose of limitation.
4. The answers provided should first restate the question asked and also identify the person(s) supplying the
information.
5. Please answer each designated par of each information request separately. If you do not have complete
information with respect to any interrogatory, so state and give as much information as you do have with
respect to the matter inquired about, and identify each person whom you believe may have additional
information with respect thereto.
6. In the case of multiple witnesses, each interrogatory should be considered to apply to each witness who
wil testify to the information requested. Where copies of testimony, transcripts or depositions are
requested, each witness should respond individually to the information request.
7. The interrogatories are to be answered under oath by the witness(es) responsible for the answer.
SECOND SET OF INTERROGATORIS OF
THE KROGER CO. TO
IDAHO POWER COMPAN
CASE NO. IPC-E-ll-08
Q2-1. Please refer to Sparks Exhibit No. 48 - Biling Comparisons. Please provide all calculations, with
formulas intact, used in the derivation of the curent and proposed bil amounts shown for Schedule 9,
Large General Service (all voltage levels).
Q2-2. With regard to Schedule 9, Large General Service, please provide the following information:
a) On-peak, mid-peak and off-peak energy usage for an average primar voltage customer stated in kWh
per month, for the most recent 12 months.
b) Monthly biling demand, base load capacity, and on-peak demand for an average primar voltage
customer, stated in kW per month, for the most recent 12 months.
Please provide your responses to our consultat at the address listed below.
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, Utah 84111
khigginsigenergystrat.com
Respectflly submitted,
~
Kur J. Boehm, Esq.
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinati, Ohio 45202
Ph: [phone] Fax: [phone]
E-mail: kboehmigBKLlawfirm.com