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Home My WebLink About20110817IPC to ICIP 33-36.pdføsIDA~POR~ LISA D. NORDSTROM Lead Counsel Inordstromcæidahopower.c0"i! T I L¡(:f"'ii~ f~; An IDACORP Company August 17, 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 Third Requests for Production of the Industrial Customers of Idaho Power 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 this production request. Please handle the enclosed confidential information in accordance with the Protective Agreement executed in this matter. Very truly yours, ~ ri L-/ICì~¿¿. 'liK~ Lisa D. Nordstrom LDN:kkt Enclosures 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(Çidahopower.com dwalker(Çidahopower.com jwilliams(Çidahopower.com RECE!VED 2011 AUG' 7 PM 4: 22 , (,..,iV 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 THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the Third Requests for Production of the Industrial Customers of Idaho Power dated July 27,2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1 REQUEST FOR PRODUCTION NO. 33: Reference the Company's Response to Idaho Irrigation Pumpers Association Inc.'s ("IIPA") Data Request No. 26. Please provide all documents, descriptions, and analyses that were used in the development or support of the excel spreadsheet titled "Larkin Workpapers - Marginal Cost Analysis Schedules." RESPONSE TO REQUEST FOR PRODUCTION NO. 33: Please see the attached Excel file that contains all but one of the supporting worksheets for the Marginal Cost Analysis Schedules. The worksheet that has been removed from the supporting worksheets contains confidential forward-looking transmission information and is included on the confidential CD, which has been provided to those parties that have executed the Protective Agreement in this docket. Additional detail regarding the derivation of the Marginal Cost Analysis can be found on page 59 of Company witness Matthew T. Larkin's workpapers. The response to this Request was prepared by Timothy E. Tatum, Senior Manager of Cost of Service, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2 REQUEST FOR PRODUCTION NO. 34: Reference the excel spreadsheet titled "Larkin Workpapers - Marginal Cost Analysis Schedules" included with the Company's Response to IIPA Data Request No. 26. In the tab titled "Schedule 2 - SGCMC," the Notes state "1/ G & T Assignment Factors Workpaper." (This note was also included in the tab titled "Schedule 3 - STMS.") Please provide the work papers titled "G & T Assignment Factors Workpapet' in electronic format along with all documents, descriptions, and analyses that were used in the development or support of the work papers. RESPONSE TO REQUEST FOR PRODUCTION NO. 34: Please refer to the Company's response to the Industrial Customers of Idaho Powets ("ICIP") Production Request No. 33. The response to this Request was prepared by Timothy E. Tatum, Senior Manager of Cost of Service, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 35: Reference the excel spreadsheet titled "Larkin Workpapers - Marginal Cost Analysis Schedules" included with the Company's Response to IIPA Data Request No. 26. In the tab titled "Schedule 2 - SGCMC," the Notes state "1/ G & T Assignment Factors Workpaper Seasonalized based on average monthly share of peak hour deficiencies for the five year period 2011-2015. Source: 2009 IRP Technical Appendix, p. 120." Please explain how the eight months of April, May, June, July, August, September, November, and December were selected for the calculation of Monthly Marginal Cost. Please include in your response an explanation of the specific data that was used from the 2009 IRP in the development of the Monthly Marginal Costs, along with all documents, descriptions, and analyses that were used in the development or support of the calculations. RESPONSE TO REQUEST FOR PRODUCTION NO. 35: The eight months of April, May, June, July, August, September, November, and December were selected based on the monthly peak hour deficiencies identified in the 2009 Integrated Resource Plan ("IRP"), starting on page 120 of the IRP Technical Appendix. As can be seen on page 120 of the IRP Technical Appendix, the deficiencies were calculated based upon the monthly peak hour load forecast, including the impacts of existing energy efficiency programs. The generation capacity associated with existing resources consisting of coal, hydro, PURPA, power purchase agreements, and gas peakers, in addition to the 2006 IRP Preferred Portolio of Resources, was subtracted from the monthly peak hour load forecast, calculating either a surplus or a deficiency. In the development of the peak hour deficiencies used in the Company's Marginal Cost Analysis, the Firm Pacific IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4 NW Import Capabilty was not considered a Company resource; therefore, it was not included in the calculation. The response to this Request was prepared by Timothy E. Tatum, Senior Manager of Cost of Service, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5 REQUEST FOR PRODUCTION NO. 36: Reference the excel spreadsheet titled "Larkin Workpapers - Marginal Cost Analysis Schedules" included with the Company's Response to IIPA Data Request No. 26. In the tab titled "Schedule 3 - STMC," the Notes state "3/ Seasonalized based on monthly share of peak hour load growth between 2011 and 2020 Source: 2009 IRP Technical Appendix, p. 59-68." Please explain how these peak hour load growth shares were calculated. Please include in your response an explanation the specific data that was used from the 2009 IRP in the development of the Monthly Marginal Costs, along with all documents, descriptions, and analyses that were used in the development or support of the calculations. RESPONSE TO REQUEST FOR PRODUCTION NO. 36: The peak hour load growth used in the Company's Marginal Cost Analysis represents the deviation between the forecast of the monthly peak hour loads for 2011 and the forecast of monthly peak hour loads for 2020 included in the 2009 IRP. The data source starts on page 59 of the 2009 IRP Technical Appendix. The Excel file provided by the Company in its response to ICIP's Production Request No. 33 includes a tab labeled "G & T Assignment Factors WP" which details the calculation of the monthly peak hour load growth factors based upon the 2009 IRP peak hour load data. The response to this Request was prepared by Timothy E. Tatum, Senior Manager of Cost of Service, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 17th day of August 2011. æ~l)72rk~ LISA D. NORDStROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 1 ih day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Karl T. Klein Deputy Attorneys General Idaho Public Utilties Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email Don.Howell(Çpuc.idaho.gov Karl. Klein(Çpuc. idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email peter(Çrichardsonandoleary.com greg(Çrichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email dr(Çbenjohnsonassociates.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(Çracinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email tony(Çyankel.net IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7 The Kroger Co. Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Kevin Higgins Energy Strategies, LLC 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Micron Technology, Inc. MaryV. York HOLLAND & HART LLP 101 South Capital Boulevard, Suite 1400 Boise, Idaho 83702 Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 The United States Department of Energy Arthur Perry Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Dwight D. Etheridge Exeter Associates, Inc. 10480 Little Patuxent Parkway, Suite 300 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email kboehm(ÇBKLlawfirm.com jrh(Çbattfisher .com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email khiggins(Çenergystrat.com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email myork(Çhollandhart.com tnelson(Çholland hart. com madavidson(Çholland hart. com fsch midt(Çholland hart. com Inbuchanan(Çholland hart. com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email remalmgren(Çmicron.com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email Arthur.bruder(Çhq.doe.gov Steven. porter(Çhq .doe. gov Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email detheridge(Çexeterassociates.com IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8 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 -. Email bmpurdy(Çhotmail.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email botto(Çidahoconservation .org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email kmiller(Çsnakeriverallance.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 -. Email nancy(Çnwenergy.org g~Qt~ Lisa D. Nordstrom IDAHO POWER COMPANY'S RESPONSE TO THE THIRD REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9