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Home My WebLink About20110819IPC 152 to Staff.pdf*SIDA~POR~ An IDACORP Company LISA D. NORDSTROM Lead Counsel Inordstrom(âidahopower.com August 19, 2011 VIA HAND DELIVERY ):c=en ;0mam r-c: Jean D. Jewell, Secretary Idaho Public Utiities Commission 472 West Washington Street Boise, Idaho 83720 \. -0:: .¡... ,'"""..mt:J W\. 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 Eighth Production Request of the Commission Staff to Idaho Power Company in the above matter. Also enclosed are three (3) copies of a non-confidential disk containing information being produced in response to Staff's Eighth Production Request. Very truly yours, XwJ2'l~ Lisa D. Nordstrom LDN/kkt Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 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 Inordstromßìidahopower.com dwalkercaidahopower.com jwilliamscaidahopower.com ~--?" -..§ n-ornL -." Attorneys for Idaho Power Company -0~ .'C.. ç"o 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 EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Eighth Production Request of the Commission Staff to Idaho Power Company dated August 3, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO. 152: For each and every adjustment made in this case (IPC-E- 11-8), please provide workpapers showing the dollar calculation of the adjustment along with the direct assignment and allocation for each adjustment. Please provide these workpapers in electronic format with formulas operationaL. RESPONSE TO REQUEST NO. 152: Please see the attached Excel file Adjustment Summary.xlsx. This file summarizes all the adjustments contained in the Company's adjustment workpapers, which include: 2011 Est Close and Rets by plant acct.xlsx, OM Allocators2011.xlsx, and Annualizing Labor Adjustments to O&M 2011.xls. The Adjustment Summary file provided herein provides the detail of every adjustment (forecast adjustment or annualizing) that went into each Federal Energy Regulatory Commission ("FERC") account to arrive at the 2011 Test Year total. It is a summary of the Company's attached workpapers that provides the details for the forecast and annualizing adjustments made to create the 2011 Test Year amounts. The Adjustment Summary is divided up in the same manner as the tables in Kelley Noe's Exhibit 25, Development of the Revenue Requirement, and Exhibit 26, Jurisdictional Separation Study - Idaho Revenue Requirement. Each table has a corresponding tab in the Adjustment Summary file. The name of the Company witness who sponsored the adjustment, what the adjustment is, and a summary of the allocation basis is listed at the top of each tab. The Adjustment Summary file should be used in conjunction with Timothy E. Tatum's Exhibit No. 20, Forecast Methodology Manual, which provides comprehensive detail of the forecast adjustment. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 For each table (except those with adjustments that are only directly assigned), each adjustment has its own column and shows the amounts allocated to each account for that specific adjustment. All the adjustments listed are summed by account in a column entitled "Total by FERC Account," which matches the amounts in column 9 of Exhibit No. 25. The attached workpaper 2011 Est Close and Rets by plant acct.xlsx takes the 2011 forecast of Plant Closings by Project Type, and using the 5-year average of closings by Project Type, it allocates the 2011 Plant Closings by FERC account. In addition, this spreadsheet calculates estimated retirements by FERC account, which is integral in the final Electric Plant in Service 13-month average. This workpaper was used to create the "EPIS and Allocation Detail Pint Addition" tab in the Adjustment Summary spreadsheet. The attached workpaper OM Allocators2011 provided the detail of all the Labor and Non-Labor operations and maintenance ("O&M") forecast adjustments and how they were allocated by FERC account. This workpaper was used to create the "O&M" tab in the Adjustment Summary spreadsheet. Please note that the workpaper provides the information detailed to all accounts and subaccounts. The Adjustment Summary provides the detail at the total FERC account level which is how it is presented in the Jurisdictional Separation Study. The attached workpaper Annualizing Labor Adjustments to O&M 2011 provides the detail of the annualizing adjustments made and how they were spread to the individual FERC accounts. This workpaper was also used to prepare the "O&M" tab in the Adjustment Summary spreadsheet. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 19th day of August 2011. ~£2~14ìSORDS M Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 19th day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF 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 Karl T. Klein Deputy Attorneys General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Don.Howellcapuc.idaho.gov Karl. Kleincapuc. idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 2ih Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email petercarichardsonandoleary.com gregcarichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email drcabenjohnsonassociates.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 -l Email elocaracinelaw.net Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email tonycayankel.net IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 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 X Email kboehmcaBKLlawfirm.com jrhcabattisher.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email khigginscaenergystrat.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email myorkcahollandhart.com tnelsoncaholland hart. com madavidsoncaholland hart.com fschmidtca holland hart. com Inbuchana nca holland hart. com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email remalmgrencamicron.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Arthur.brudercahq.doe.gov Steven. portercahq .doe.gov Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email detheridgecaexeterassociates.com IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 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 -l Email bmpurdycahotmail.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 -l Email bottocaidahoconservation.org Snake River Allance Ken Miler Snake River Alliance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email kmillercasnakeriveralliance.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 -l Email nancycanwenergy.org JfÆti~Lisa D. Nordstr IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7