20110819IPC to Staff 77-139.pdf

~IDA~POR~
An 10ACORP Company
LISA D. NORDSTROM
Lead Counsel
Inordstromc.idahopower.com
August 18, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
Boise, Idaho 83720
Re: Case No. IPC-E-11-08
General Rate Case
Dear Ms. Jewell:
Enclosed for filng are an original and one (1) copy of Idaho Power Company's
Response to the Fifth 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 and three (3) copies of
a confidential disk containing information being produced in response to Staffs Fifth
Production Request.
Please handle the enclosed confidential information in accordance with the
Protective Agreement executed in this matter.
Very truly yours,
~:. 12.'- o.~
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise. 10 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: [phone]
Facsimile: [phone]
Inordstromcæidahopower.com
dwalkercæidahopower.com
jwilliamscæidahopower.com
RECEI n
Zvn AUf; ¡ Q Dy I." v ni l.: S3
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 FIFTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Fifth Production Request of the Commission Staff to Idaho Power
Company dated July 28, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 77: Page 8 of Exhibit 20 (Forecast Methodology Manual
prepared at Witness Tatum's direction) states that Miscellaneous Service Revenues
were "projected for 2011 to be the same as the 12 month actual ended December 2010
Base." Please provide a 5-year historical schedule of this account by month.
RESPONSE TO REQUEST NO. 77: Please see the Excel file provided on the
non-confidential CD for a 5-year historical schedule for Miscellaneous Service
Revenues by month.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 78: Page 8 of Exhibit 20 states: "Substation equipment rentals,
transformer and distribution rentals, station and line rentals, real estate rents, dark fiber
rents, joint pole attachments, overnight park rents were forecasted to be the same as
the 2010 Base." Please provide a 5-year historical schedule of these accounts by
month.
RESPONSE TO REQUEST NO. 78: Please see the Excel file provided on the
non-confidential CD for a 5-year historical schedule for substation equipment rentals,
transformer and distribution rentals, station and line rentals, real estate rents, dark fiber
rents, joint pole attachments, and overnight park rents by month.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO. 79: Please provide a 5-year historical schedule of the
cogeneration and small power production revenues and facilties charge revenues
amounts by account by month.
RESPONSE TO REQUEST NO. 79: Please see the Excel file provided on the
non-confidential CD for a 5-year historical schedule for cogeneration and small power
production revenues and facilties charge revenues by month.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 80: Page 8 of Exhibit 20 states that cogeneration and small
power production revenues 2010 Base was "increased for thirteen new wind projects
that have or wil come on-line in 2011."
a) Please identify each wind project and provide the actual on-line or
expected on-line date for each.
b) Please also provide workpapers showing the calculations behind the
increase from the 2010 Base.
c) Please provide workpapers and explanations for how it was determined
that an annual growth rate of 4.5% should be used.
RESPONSE TO REQUEST NO. 80:
a) Please see tab "80a" of the Excel workbook provided on the non-
confidential CD identifying the wind projects anticipated at the time of the Company's
filng.
b) Please see tab "80b&c" of the Excel workbook provided on the non-
confidential CD for the calculation behind the increase from the 2010 Base.
c) The annual growth rate of 4.5 percent was determined by calculating the
average annual operations and maintenance ("O&M") increase from 2008-2010 for wind
projects. Please see tab "80b&c" of the Excel workbook provided on the non-
confidential CD containing the calculation of the annual growth rate of 4.5 percent.
The response to this Request was prepared by Christina Kreikemeier, Financial
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 81: Page 9 of Exhibit 20 states that facilty charge revenues are
reviewed intermittently and "IPC determined that the rate should be decreased based
on the current methodology." Please provide a copy of the most recent reviews. Was
the "current methodology" used the same as the methodology the Company used in the
last rate case?
RESPONSE TO REQUEST NO. 81: For the most recent review of the facilty
charge rate, see the Company's response to the Industrial Customers of Idaho Powets
Request for Production NO.4. The overall methodology applied in the development of
the facility charge has remained unchanged since the current facilties charge was
developed in 1987. However, in the preparation of the proposed facilities charge, the
Company modified a number of the inputs used in the development of the individual
facilities charge components to reflect changes in the Company's business and
accounting processes. For example, unemployment and social security taxes were
previously held at the Company level and were categorized as "other taxes" in the
facilities charge calculation. These costs are now assigned directly to the applicable
operations and maintenance accounts. Therefore, an adjustment was made in the
development of the proposed facilties charge to reassign these costs from "other taxes"
to the O&M facilities charge component. Descriptions of the facilty charge cost
components are provided in the Direct Testimony of Scott D. Sparks, pp. 37-39.
The response to this Request was prepared by Shelby Leforgee, Finance
Leader, Idaho Power Company, under the direction of Scott D. Sparks, Senior
Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO. 82: Page 9 of Exhibit 20 states that "revenues related to the
photovoltaic station service, Antelope substation, Sierra stand-by service, and
miscellaneous were projected for 2011 to be the same as the 2010 Base." Please
provide a 5-year historical schedule by month of these accounts.
RESPONSE TO REQUEST NO. 82: Please see the Excel file provided on the
non-confidential CD for revenues related to the photovoltaic station service, Antelope
substation, Sierra stand-by service, and miscellaneous for 5-years by month.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO. 83: Please provide a 5-year historical schedule of the 2011
Network Transmission Customer revenues and the 2011 point-to-point wheeling
revenues.
RESPONSE TO REQUEST NO. 83: Please see the table below.
Network Transmission Point to Point Year Total
2006 4,251,146.35 7,905,690.81 12,156,837.16
2007 5,222,584.09 11,006,506.68 16,229,090.77
2008 5,419,546.74 12,903,743.06 18,323,289.80
2009 1,331,976.67 (281,103.86)1,050,872.81
2010 4,739,971.06 10,658,430.71 15,398,401.77
Total 20,965,224.91 42,193,267.40 63,158,492.31
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST NO. 84: Page 9 of Exhibit 20 describes how the Company calculated
the 2011 Network Transmission Customer revenues.
a) Please provide all workpapers for this calculation in electronic format with
formulas intact.
b) Please provide a schedule and explanation of how the 2 MW increase for
new customer demand was determined.
RESPONSE TO REQUEST NO. 84: Please see the Excel spreadsheets on the
confidential CD containing the 2011 Network Transmission Customer Revenues
calculation and the schedule for new customer demand increase of 2 megawatts
("MW"). The confidential CD wil be provided to those parties that have executed the
Protective Agreement in this matter.
The 2011 Network Transmission Customer revenues were calculated based on
nine months of the network transmission customers' average load ratio share times the
formula-based Federal Energy Regulatory Commission ("FERC") transmission revenue
requirement in effect from October 1, 2010, through September 30, 2011, and three
months of the network transmission customers' average load ratio share times the
forecasted FERC transmission revenue requirement. The timing for the Transmission
Revenue Requirement is the same as the point-to-point wheeling rate (Request No. 85).
The 2011 estimated network customer MW demand used to calculate the Network
Transmission Customer revenue was calculated by taking 2009 MW demand and
escalating it using a 0.7 percent annual growth factor for 2010. The escalated 2010
MW demand was then increased by 2 MW for new network customer MW demand- in
2011.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
With regard to Request No. 84.b, the 2 MW increase for new customer demand
was determined by using 2010 actual peak demand for Raft River Nevada Border for
October through December 2011. Raft River Nevada Border load is currently served by
Idaho Power. When Raft River Nevada Bordets Network Service Agreement ends on
October 1, 2011, it has opted to become a customer of Bonnevile Power
Administration. This change wil result in the load moving to Firm Network Service for
Others rather than Firm Network Service for Self as reported on the FERC Form 1.
The response to this Request was prepared under the direction of 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 FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -10
REQUEST NO. 85: Page 9 of Exhibit 20 describes how the Company calculated
the 2011 point-to-point wheeling revenues were calculated. Please provide all
workpapers for this calculation.
RESPONSE TO REQUEST NO. 85: Please see the Company's response to
Staffs Production Request No. 84.
The response to this Request was prepared under the direction of Timothy E.
Tatum, Senior Manger 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 FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST NO. 86: Page 9 of Exhibit 20 states that "Valmy usage is not
expected to exceed capacity; therefore no revenues from Sierra Pacific Power Usage
are expected." Please provide a 3-year historical schedule of usage for Valmy.
RESPONSE TO REQUEST NO. 86: Sierra Pacific Power Usage revenues for
2008, 2009, and 2010 were $66,423.00, $241,339.57, and ($55,846.28), respectively.
Sierra Pacific Power Usage revenues are for reimbursement of shared O&M expenses
based on ownership and capacity usage between Valmy and Idaho Power. For
example, when either company exceeds its 50 percent share of capacity each month, it
reimburses the other company for its increased portion of the O&M expenses. During
2008 and 2009, Sierra Pacific reimbursed Idaho Power for shared O&M expenses of
$66,423.00 and $241,339.57, respectively. In 2010, Idaho Power reimbursed Sierra
Pacific for shared O&M expenses related to 2009 of $56,084.48 and recorded $238.20
in revenues related to 2010 for a net reimbursement of $55,846.28.
The response to this Request was prepared under the direction of 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 FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -12
REQUEST NO. 87: Please provide the workpapers, and all detail necessary to
verify all of the deferred income tax items in Witness Jones' Exhibit No. 14, page 21 of
23, pertaining to Accumulated Deferred Income Taxes.
RESPONSE TO REQUEST NO. 87: Please see the documents provided on the
non-confidential CD.
The response to this Request was prepared by Gene Marchioro, Corporate Tax
Director, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
REQUEST NO. 88: Reference Exhibit 20, page 11, 2011 Labor Expense of
$133 Millon.
a) Please provide supporting documentation for the labor allocations.
b) Please show how this amount is allocated to all accounts and identify
each account number.
c) Please provide the most current update (year-to-date) of the 2011 Labor
Expenses table, including the three-year historical average percentage.
d) Identify months where there are extra pay periods (3 vs 2) in the three-
year average and 2011.
e) If there are extra pay periods, what was done to insure the periods are
comparable?
RESPONSE TO REQUEST NO. 88:
a&b) Please see supporting documentation for the labor allocations in the
"Request 88a And 88b" tab of the Excel file provided on the non-confidential CD.
c) Please see the most current update of the 2011 Labor Expense table in
the "Request 88c" tab of the Excel file provided on the non-confidential CD.
d&e) Please see data relating to 3 pay period months in the "Request 88d and
88e" tab of the Excel file provided on the non-confidential CD.
The response to this Request was prepared by Jerry McCabe, Corporate Budget
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
The following questions (Nos. 89-139) are in reference to "2011 O&M Non-
Labor Expenses" from Witness Tatum's Exhibit No. 20, page 11.
REQUEST NO. 89:Please provide any and all workpapers, emails,
spreadsheets, cost estimates, contracts and any other supporting documentation for the
following items. Include in your response all studies and assumptions used in
estimating the expenses. For items not expected to recur in 2012, or for items that are
not normally recurring, please provide information about the timing of the event, for
example, if the expense is for a survey, how often is the survey expected to be
performed and how often is the survey required. In addition, please include a
description of each item, and the benefits each item provides to ratepayers.
a) Thermal O&M Increases from Operating Partners
b) Bennett Mountain - 2011 Combustor Inspection
c) NERC Required L1DAR Surveys
d) BLM Rate increase - Land Rents
e) Idaho Fish and Game's Projected Hatchery Increases
f) Increased IT maintenance Expenses
g) Special Reliability Projects - Transmission
RESPONSE TO REQUEST NO. 89:
a) Thermal O&M expense increases are due to numerous factors, including,
but not limited to, increased costs for chemicals driven by both unit cost and volume
increases, union driven wages and benefi increases at the Bridger plant, lower than
typical 2010 maintenance at the Boardman plant, and labor shifting from capital projects
to O&M expense. Customers benefit from these expenditures by having well
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -15
maintained and reliable generating plants that are in compliance with newly enacted
pollution control standards. Please see further explanations for increased thermal O&M
in the Excel file provided on the non-confidential CD.
b) Combustor inspections (and/or hot gas path inspections) are a required
maintenance function at natural gas-fired power plants and are performed
approximately every four years. The timing of the inspections is based on hours of
operations and number of plant starts. Customers benefit from these expenditures by
having well maintained and reliable generating plants.Please see further
documentation for the 2011 Bennett Mountain combustor inspection in the Excel file
provided on the non-confidential CD.
c) In October of 2011, the North American Electric Reliability Corporation
("NERC") issued an Alert that required each utilty to verify that transmission lines'
operating ratings were based on actual conditions rather than design conditions. Idaho
Power is conducting a 3-year Light Detection and Ranging ("L1DAR") survey to meet the
requirements of this NERC Alert. Customers will benefit from these expenditures by
having a transmission system that is in compliance with NERC standards. Please see
further information relating to the L1DAR surveys in the document provided on the non-
confidential CD.
d) Bureau of Land Management ("BLM") land rent increases are due to new
federal rent schedules and zone schedule changes. Customers benefi from these
expenditures by having continued right-of-way for existing transmission and distribution
facilities over federally owned lands. Please see further information relating to the cost
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
increase for BLM land rent rate increase in the document provided on the non-
confidential CD.
e) Funding for these Fish and Game run hatcheries is a requirement of
FERC licenses for certain of the Company's hydro generating plants. Customers
benefit from these expenditures by having inexpensive hydro generating facilties that
are in compliance with their associated FERC licenses. Please see further
documentation for the 2011 Idaho Fish and Game's projected hatchery increases in the
Excel file provided on the non-confidential CD.
f) Idaho Power wil see increased IT maintenance expense in 2011 largely
due to Smart Grid related softare and hardware whose maintenance expense is not
reimbursed to the Company after the first year of the contracts. Customers benefit
because Smart Grid technologies wil provide them with detailed information about their
energy usage. This information wil help customers better understand how they can
change their consumption and become more energy effcient. Other benefits of the
Smart Grid are improved abilty to respond to outages, reduced outage duration, and
improved power reliability. Please see the detail of the increased IT maintenance
expense, and associated explanations, in the documents provided on the non-
confidential CD.
g) These two Special Transmission Reliabilty Projects (Bridger Goshen Line
Guy Wires and Replace Dead-ends on. Oxbow-Palette Junction and Brownlee Palette
Junction) are above and beyond the normal levels of transmission maintenance
performed in 2010. Combined, they represent $3.4 milion in additional maintenance
and, as such, the work is being spread over three and four years, respectively,
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -17
beginning in 2011. Customers wil benefi from these expenditures through increased
reliabilty of the transmission system. Please see further documentation on the Special
Transmission Reliabilty Projects in the Excel file provided on the non-confidential CD.
The response to this Request was prepared by Jerry McCabe, Corporate Budget
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -18
REQUEST NO. 90: Please provide a printout of all expenses charged to
Accounts 920, 921, 923, 925, 926, 928, 930, 931 and 935 during 2009, 2010 and 2011
to date and continuing when available. Please include amounts paid, vendor, date, and
a brief explanation of the expense. This information should be provided on CD in Excel
format with all formulas intact.
RESPONSE TO REQUEST NO. 90: Please see the Excel file provided on the
confidential CD containing all expenses charged to Accounts 920, 921, 923, 925, 926,
928, 930, 931 and 935 during 2009, 2010, and through June 2011. The confidential CD
wil be provided to those parties that have executed the Protective Agreement in this
matter.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
REQUEST NO. 91: Please provide a schedule of Contributions in Aid of
Construction (CIAC) as of December 31, 2010 showing names, dates, amounts and
accounts used. Please include within your response any significant changes to CIAC
occurring in, or planned for 2011.
RESPONSE TO REQUEST NO. 91: Please see the Excel file provided on the
non-confidential CD. This information does not include CIACs in Account 107
(Construction Work In Progress), which is not included in rate base. CIACs closed to
plant are closed to specific assets from the construction work order. Totals have been
summarized at the accounting year, plant account level due to the volume of data.
Names of the payee are not included in the asset management data base. Outside of
normal Company collections, no significant CIAC changes are anticipated.
The response to this Request was prepared by Larry Tuckness, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
REQUEST NO. 92: Please provide a schedule of Customer Advances for
Construction for the year ending 2010 showing names, dates, amounts and accounts
used. Please include within your response any significant changes to Advances
occurring in, or planned for 2011.
RESPONSE TO REQUEST NO. 92: Please see the Excel file provided on the
non-confidential CD for a summary of FERC Account 252 balances by district for the
year ended December 31, 2010. Idaho Power does not have an existing report that
shows the balances by customer as of December 31, 2010, and Idaho Power's system
shows only the current real-time balances. However, provided on the non-confidential
CD is a schedule of FERC Account 252 customer balances as of August 10, 2011.
These schedules do not include any balances for Account 252100 (Network
Transmission Upgrades) because there currently are no in-service network transmission
upgrade projects that have a refundable deposit in FERC Account 252. Please see
Company witness Timothy E. Tatum's Exhibit No. 20, pp. 33-34 for a description of the
2011 FERC Account 252 forecast methodology.
The response to this Request was prepared under the direction of Shelby
Leforgee, Finance Team Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
REQUEST NO. 93: Please provide an analysis of the sale of land and plant for
the years 2010 and 2011 to date. Please show gains, losses and supporting
documentation including accounting entries for removal of items from rate base.
RESPONSE TO REQUEST NO. 93: The following is a summary of the land and
plant sales for the years 2010 and 2011 to date. Please see the document provided on
the non-confidential CD for details of each transaction. In addition, please see the
below summaries.
Pocatello Line 103. To solve encroachments of Transmission Line #103, .6
acres of Idaho Power land was quitclaimed to homeowners and Idaho Power retained
the easement over the property. The transaction was recorded by the county on April
27, 2009, and resulted in a net loss of $200.00. Due to an error in the set up of the
work order, the accounting entries were not recorded until 2010.
Distribution Facilties and Appurtenant Rights-of-Way. On March 2, 2010,
Idaho Power sold a 1.5 mile distribution line in Idaho solely used to serve Raft River to
Raft River Electric Cooperative, Inc., which included the appurtenant right-of-way
permits for $43,191.05.
The Goshen Series Capacitor Bank. The Goshen Series Capacitor Bank is a
345 kilovolt, 3-phase, 60 hertz, 2 equal segment, outdoor series capacitor bank that
Idaho Power sold to PacifiCorp on April 30, 2010, at the net book value of
$6,533,307.28.
Pocatello Pole Yard Exchange. On April 30, 2010, Idaho Power closed a
property exchange transaction with Varsity Square, LLC ("Varsity") relating to the
Company's Pocatello pole yard. Under the exchange, Idaho Power conveyed its
original .579 acre Pocatello pole yard property to Varsity in exchange for a comparable
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22
parcel of land owned by Varsity approximately one block away. The Pocatello
Exchange resulted in recognition of no gain.
Right-of-Way on Franklin Road. The Ada County Highway District acquired
two strips of Idaho Power land located on the northern boundary of Franklin Road on
June 15, 2010, for a road widening project. The first strip acquired was from Idaho
Power's Cloverdale Substation property and the second strip acquired was from Idaho
Power property currently leased to Divotz Discount Golf and Range, Inc., also along
Franklin Road. The total payment for both strips of land was $171,756.20.
Landis Land Exchange. On July 14, 2010, Idaho Power closed a property
exchange transaction with Tim and Melody Landis involving lands located near the
Company's C.J. Strike Hydroelectric Project. Idaho Power conveyed 47 acres of land
located above the C.J. Strike Project boundary to the Landis' and the Landis' conveyed
to Idaho Power (1) 46.6 acres of existing farming and grazing easements held by the
Landis' on Idaho Power lands within the C.J. Strike Project boundary, (2) power line
easements over portions of the 47 acres of land conveyed by Idaho Power to the
Landis', and (3) road access over separate lands owned by the Landis' near the C.J.
Strike Project. The total loss in aggregate for the transactions was $3,155.11.
Right-of-Way at Locust Substation. On February 22, 2011, the Ada County
Highway District acquired a strip of Idaho Power land located at the Locust Substation
for a road widening project. The total payment for the land plus related easements,
improvements, and administrative settlement was $182,100.00.
The response to this Request was prepared by Larry Tuckness, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23
REQUEST NO. 94: Please provide details of any planned sales of land and/or
plant for the remainder of 2011. Please include within your response the estimated date
of these sales and planned treatment (including accounting entries) for them.
RESPONSE TO REQUEST NO. 94: No land or plant sales are planned for the
remainder of 2011.
The response to this Request was prepared by Larr Tuckness, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
REQUEST NO. 95: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2010 through 2011 to date and continuing when
available.
RESPONSE TO REQUEST NO. 95: There were no "out of period adjustments"
or "extraordinary items" in 2010 or 2011 to date.
The response to this Request was prepared by Mark Annis, Manager, Financial
Reporting and Accounting Research, Idaho Power Company, in consultation with Lisa
D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25
REQUEST NO. 96: Please provide a list of all pending legal cases and their
status including description of the issue, estimates of liability and possible ramifications
to the Company.
RESPONSE TO REQUEST NO. 96: In responding to this Request, the
Company assumes that "all pending legal cases" means actual cases filed in either
state or federal court in which Idaho Power is either a named plaintiff or defendant; it
does not include cases pending before any state or federal regulatory agencies.
Provided on the non-confidential CD is (1) a list of all docketed cases involving Idaho
Power, as well as a description and status of the matter, and (2) pages 25-29 of the
Company's most recent Securities and Exchange Commission 10-Q filng detailng legal
contingencies. The provided document lists all of the Company's pending legal cases
at this time. Estimates of liability and possible ramifications to the Company are
attorney-client privileged information and/or information protected by the Attorney Work
Product Doctrine IRCP Rule 26(b)(3).
The response to this Request was prepared by Jason B. Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26
REQUEST NO. 97: Please provide the amounts spent for injuries and damages
for the years 2010 to date. Please include within your response the description of each
item, the amount for each item and the account charged.
RESPONSE TO REQUEST NO. 97: Please see the Excel file provided on the
confidential CD. The confidential CD wil be provided to those parties that have
executed the Protective Agreement in this matter.
The response to this Request was prepared by Sandy Kowalls, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 27
REQUEST NO. 98: Please provide detail of all advertising expenses recorded
above the line including account and subaccount where posted, dates posted, vendor
names, explanations, and amounts posted during 2010. Please identify each expense
that is related to safety. In addition, please provide copies of the ads used during 2010
and correlate the ad copy with the specific detail provided in this production request
response.
RESPONSE TO REQUEST NO. 98: Please see the Excel file provided on the
non-confidential CD that details the requested advertising expenses. These expenses
have been grouped into two categories, those that are recoverable and those that are
not recoverable (FERC Account 930100). The advertising expenses recorded in FERC
Account 930100 have been removed in their entirety from the revenue requirement.
Also provided on the non-confidential CD are the advertisements and a summary of
safety related costs.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28
REQUEST NO. 99: Please provide a list of all consultants who performed
services for Idaho Power for the years 2009 to date. Please include within your
response the services performed, amounts paid, the accounts charged, the allocation
factor and amount allocated to the Idaho jurisdiction.
RESPONSE TO REQUEST NO. 99: The requested information is proprietary
and confidentiaL. It wil be made available for Staff audit at Idaho Powets corporate
headquarters. Please contact Doug Jones at [phone] or Camila Victoria at
[phone] to arrange a time to review the requested materiaL.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 29
REQUEST NO. 100: Please provide copies of all internal audit reports for the
years 2008, 2009, 2010 and 2011 to date and continuing when available.
RESPONSE TO REQUEST NO.1 00: The requested information is voluminous,
confidential, and may be subject to both attorney-client and accountant-client privilege.
Notwithstanding the foregoing, Idaho Power is wiling to make the requested
information, excluding attorney-client information, available for Staff audit at Idaho
Powets corporate headquarters. Please contact Doug Jones at [phone] or
Camila Victoria at [phone] to arrange a time to review the requested materiaL.
The response to this Request was prepared by Jeff McCormick, Audit Director,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30
REQUEST NO. 101: Please provide a description of all audits/organizational
reviews currently in progress or planned through 2012 year-end. Please include within
your response the description of reviews that are currently underway for which no report
has been issued and the estimated report date.
RESPONSE TO REQUEST NO. 101: All audits currently in progress or planned
for audit year April 1, 2011, through March 2012 are noted in the Company's response
to Staff's Production Request Nos. 28 and 100. No audit schedule is currently available
for April through December 2012.
The response to this Request was prepared by Jeff McCormick, Audit Director,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31
REQUEST NO. 102: Please provide a copy of the policy for bad debt write-offs
and collection of past due amounts.
RESPONSE TO REQUEST NO. 102: Prior to write-off, the Company follows the
Idaho Public Utilties Commission collection requirements in compliance with UCRR
304. Once the account is closed, either at the request of the customer or as a result of
nonpayment, the Company wil attempt to collect the debt via biling statements and
notices. After 60 days, outstanding balances for residential customers and for
commercial customers with balances under $3,000 are systematically written off and
referred to an outside collection agency for further collection activity.
For closed commercial accounts with balances greater than $3,000, the
Company wil mail a demand letter and attempt to collect payment prior to write-off. If
payment is not received within 15 days of receipt of the demand letter, the account is
referred to an outside collection agency or attorney for further collection activity.
Delinquent irrigation debts are written off annually. Prior to write-off, the
Company wil mail demand letters to irrigators with outstanding debts greater than
$1,000. If payment is not received within 30 days of receipt of the demand letter, the
account is referred to an outside collection agency or attorney for further collection
activity.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 32
REQUEST NO. 103: Please provide a schedule of bad debt amounts for 2010
and 2011 to date and continuing when available.
RESPONSE TO REQUEST NO. 103: The bad debt amount for 2010 was
$4,930,037. The bad debt amount for year to date June 2011 is $2,303,990.
The response to this Request was prepared under the direction of Shelby
Leforgee, Finance Team Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 33
REQUEST NO. 104: Please provide the amounts spent for injuries and
damages for the years 2010 and 2011 to date and continuing when available. Please
include within your response the description of each item, the amount for each item and
the account charged.
RESPONSE TO REQUEST NO. 104: Please see the Company's response to
Staff's Production Request No. 97 for 2010 and 2011 injuries and damages.
The response to this Request was prepared by Sandy Kowalls, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 34
REQUEST NO. 105: Please provide a matrix identifying the major capital
expenditure approval levels that includes the dollar level of authorization by employee
title, division and company. Please include within your response the dollar level at
which individual capital expenditure projects require approval by the Board of Directors.
RESPONSE TO REQUEST NO. 105: For this response, approval level for major
capital expenditure is defined as approval level for authorizing a work order estimated at
$1 million or greater. Please see the table on the following page for a list of titles that
meet the criteria.
Idaho Powets Board of Directors ("Board") approves the capital budget for each
calendar year. Any individual project which wil be completed within the budget year
and will cost more than $2 millon or which wil take multiple years to complete and cost
more than $10 millon must be specifically approved by the Board. During the budget
year, an increase in the cost of a project which wil result in an increase of 2 percent or
more in the total capital budget approved by the Board must be reported to the Board.
Unbudgeted projects which need to commence during the budget year and which wil
cost more than $2 milion or which wil take multiple years to complete and cost more
than $10 milion must be approved by the Board.
The response to this Request was prepared by Dave Bean, Operations
Controller, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 35
Work Order Authorization Levels - $1 milion or greater
BUSINESS APPROVAL AUTHORIZATION
TITLE UNIT OBJECT AMOUNT
President & CEO Corporate W/O 999,999,999,999
EVP, Administration & CFO Administration W/O 500,000,000
EVP, Operations Operations W/O 500,000,000
SVP, Gen Counsel Corporate W/O 100,000,000
SVP, Power Supply Operations W/O 100,000,000
VP, Engineering & Operations Operations W/O 100,000,000
VP, Customer Operations Operations W/O 50,000,000
Contr, Corp & Chf Acct Officer Administration W/O 5,000,000
Controller, Operations Administration W/O 5,000,000
GM, Corporate Services Administration W/O 5,000,000
Mgr, Delivery Projects Operations W/O 5,000,000
Mgr, Enterprise Materials Administration W/O 5,000,000
Mgr, Joint Projects Operations W/O 5,000,000
Mgr, Power Production Operations W/O 5,000,000
VP, Chief Information Officer Administration W/O 5,000,000
VP, Chief Risk Officer Corporate W/O 5,000,000
VP, Finance & Treasurer Administration W/O 5,000,000
VP, HR & Corp Services Administration W/O 5,000,000
VP, Public Affairs Corporate W/O 5,000,000
VP, Supply Chain Administration W/O 5,000,000
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 36
BUSINESS APPROVAL AUTHORIZATION
TITLE UNIT OBJECT AMOUNT
Corporate Secretary Corporate W/O 2,000,000
Dir, Environmental Affairs Operations W/O 1,000,000
Mgr, Construction Project Operations W/O 1,000,000
Mgr, Cust Relations & Eng Eff Operations W/O 1,000,000
Mgr, Customer Service Operations W/O 1,000,000
Mgr, Delivery Construction Operations W/O 1,000,000
Mgr, Delivery Eng & Design Operations W/O 1,000,000
Mgr, Delivery Planning Operations W/O 1,000,000
Mgr, Grid Operations Operations W/O 1,000,000
Mgr, Power Plant Eng & Const Operations W/O 1,000,000
Mgr, Regional II Operations W/O 1,000,000
Mgr, Regional Ops Support Operations W/O 1,000,000
Mgr,Ops Analysis & Development Operations W/O 1,000,000
Mgr,Smart Grid Projects Operations W/O 1,000,000
Spec, Reliabilty Operations W/O 1,000,000
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 37
REQUEST NO. 106: Please provide a detailed listing of all entries to Account
451 - Miscellaneous Service Revenues for the years 2010 and 2011 to date and
continuing when available.
RESPONSE TO REQUEST NO. 106: Please see the Excel file provided on the
non-confidential CD for a 5-year detailed listing of all entries to Account 451,
Miscellaneous Service Revenues, for the years 2010 and 2011 through June.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 38
REQUEST NO. 107: Please provide a detailed listing of all entries to Account
454 - Rent from Electric Property years 2010 and 2011 to date and continuing when
available.
RESPONSE TO REQUEST NO. 107: Please see the Excel file provided on the
non-confidential CD for a 5-year detailed listing of all entries to Account 454, Rent from
Electric Property, for the years 2010 and 2011 through June.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 39
REQUEST NO. 1 08: Plea~e provide a detailed listing of all entries to Account
456 - Other Electric Revenues for the years 2010 and 2011 to date and continuing
when available.
RESPONSE TO REQUEST NO. 108: Please see the Excel file provided on the
non-confidential CD for a 5-year detailed listing of all entries to Account 456, Other
Electric Revenues, for the years 2010 and 2011 through June.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 40
REQUEST NO. 109: Please prepare a narrative showing the monthly, quarterly
and annual comparison of operating and capital budgets to actual expenditures for the
years 2010 and 2011 to date and continuing when available. Please include within your
response any narrative explanations for budget variations. This should include, but not
be limited to, written operating and capital budget variance reports and explanations
used by Company officers and managers to monitor and control budgets under their
areas of responsibilty.
RESPONSE TO REQUEST NO. 109: Idaho Power actively monitors its
performance relative to budget in several ways. The Company does not use a standard
set of monthly, quarterly, or annual budget reports that is used throughout the
Company; rather, it uses ProClarity, an on-line analytical processing ("OLAP") reporting
tool. An Excel file output from ProClarity that provides monthly, quarterly, and annual
comparisons to budget, and is representative of the type of data from the OLAP tool that
might be reviewed by a manager, is included on the non-confidential CD. A screen shot
showing the actual ProClarity screen with various fields and time periods available for
selection is also included within the provided Excel workbook as a further example of
what is available within the ProClarity reporting application.
On a bi-monthly basis, Budget Recasts are prepared at the business unit and
total Company level for O&M and Capital and are reviewed by Executive Vice
Presidents, after which they are presented to the entire group of the Company's officers.
The Recasts present year-to-date, remaining year projections, and total year
comparisons to prior Recasts, and to total year budget. Explanations for significant
variances are included on the Recast reports to give management an understanding of
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 41
the nature of the variances to date, and to explain projections for future months.
Examples of O&M and Capital Recast reports from October 2010 and March 2011 are
provided on individual tabs in the Excel file included on the non-confidential CD.
The response to this Request was prepared by Jerry McCabe, Corporate Budget
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 42
REQUEST NO. 110: Please provide copies of the monthly, quarterly, and
annual presentations to the Company's Executive Board and Chief Executive and
Operating Officers for 2010 and 2011 to date and continuing when available. Please
include within your response a paper copy of any slides and notes used in such
presentations.
RESPONSE TO REQUEST NO. 110: The Idaho Power board structure does not
include an Executive Board. The Company's board structure consists of the Board of
Directors and four standing committees of the Board: The Audit Committee,
Compensation Committee, Corporate Governance Committee, and Executive
Committee. The Company Board of Directors, Audit Committee, and Compensation
Committee Minutes and all presentation materials related to these committees were
requested and reviewed by Staff on August 2, 5, 10 and 12, 2011. The Executive
Committee is authorized to act on behalf of the Board of Directors when the Board is not
in session, except on those matters that require action of the full Board. The Executive
Committee's main function in this regard has been to approve the pricing of Idaho
Power's securities issuances when the full Board of Directors is not available. In
addition, the Executive Committee also assists the Board in overseeing risk
management. The Executive Committee typically meets once per year to review the
Company's risk management activities.
The Company's Chief Executive Officer and Executive Vice President of
Operations do not receive regular presentations on a monthly, quarterly, or annual
basis. Information is provided to the CEO and EVP-Operations from time to time
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 43
related to their work functions and at staff meetings, but no specific schedule is
established for regular written presentations to these individuals.
The response to this Request was prepared by Pat Harrington, Corporate
Secretary, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 44
REQUEST NO. 111: Please provide the Company's monthly operating and
financial reports for each month from January 2010 to date and continuing when
available. These should be in the most detailed format possible and should include all
attached supporting schedules and analysis received by management.
RESPONSE TO REQUEST NO. 111: Please see the monthly management
reports and monthly Idaho Power financial statements through June 30, 2011, provided
on the non-confidential CD. Although the monthly management reports were labeled as
confidential at the time they were created, the results have now been publicly reported
and are no longer confidentiaL.
The response to this Request was prepared by Mark Annis, Manager, Financial
Reporting and Accounting Research, Idaho Power Company, in consultation with Lisa
D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 45
REQUEST NO. 112: Please provide a copy of each adjusting journal entry
proposed by the Company's independent auditors in the two (2) most recent audits of
the Company. Please include within your response the documentation supporting these
adjustments and documentation supporting any items that were "passed upon" and not
reflected in the Company's financial records and/or financial statements.
RESPONSE TO REQUEST NO. 112: The Company made two entries based on
findings by the Company's independent auditor, Deloitte & Touche ("Deloitte"), during
the 2009 audit and one during the 2010 audit. Documentation for these entries is
provided on the non-confidential CD. The entries were to:
. December 2009
o Reverse the incorrect and re-enter the correct mark-to-market
amounts for electricity swaps.
o Reclassify the long-term portion of a receivable from an insurance
provider for workers' compensation claims that Idaho Power had paid to the claimant
and was covered under an insurance policy.
These entries had only a balance sheet impact.
. December 2010
o Gross up the income statement to show Oregon demand-side
management rider activity as revenues and expenses, which matches the presentation
for Idaho.
Also provided on the non-confidential CD is a "schedule of estimates and
misstatements" showing corrections "passed upon" for the 2009 audit that were above
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 46
the auditots de minimis amount, and explanations of the three items on this schedule.
There were no "passed upon" items above the auditots de minimis amount in 2010.
The response to this Request was prepared by Mark Annis, Manager, Financial
Reporting and Accounting Research, Idaho Power Company, in consultation with Lisa
D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 47
REQUEST NO. 113: Please provide a current organization chart showing
names of employees and their titles that includes all managers and executives. Please
include within your response how this organization chart changed or is expected to
change during 2010 and 2011. For each offcer of the Company, please provide the
following:
a) Total dollar amount of remuneration for 2010 and 2011 with the amounts
separated by salary, incentive pay, options, benefis and other.
b) The percentages of his or her total remuneration that is allocated to other
subsidiaries along with the basis for that allocation.
c) Please provide all offcers' salaries for 2008 through 2011 for each officer
by month, and please itemize by base salary, bonuses, and benefits, along with the
amount included in test year and the amount paid for by shareholders.
RESPONSE TO REQUEST NO. 113: The Company-wide organization chart
contains competitive data that is proprietary and confidentiaL. It wil be made available
for Staff audit at Idaho Power's corporate headquarters. Please contact Doug Jones at
[phone] or Camila Victoria at [phone] to arrange a time to review the
requested materiaL.
With regard to organizational changes since 2010, a significant change involved
assembling project teams to support the Smart Grid grant that was awarded to Idaho
Power by the United States Department of Energy. This resulted in the addition of 52
temporary employees that are either participating in the project or back-fillng for
existing regular full-time Idaho Power employees involved in Smart Grid projects or
other related-funded activities. The majority of the temporary employees will be
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 48
released at the end of the project in 2013. Another organizational change since early
2010 and into 2011 was the elimination of 40 metering positions associated with the
AMI implementation. Of those 40 positions, most employees either left the Company or
found other positions within Idaho Power. However, Idaho Power had four employees
to date that had to be involuntarily severed from the Company because of the AMI
project. In addition to these changes, Idaho Power also hired 11 employees in 2011 for
the start-up of the new combined-cycle gas power plant being constructed at Langley
Gulch.
a) The requested competitive information is proprietary and confidentiaL. It
will be made available for Staff audit at Idaho Powets corporate headquarters. Please
contact Doug Jones at [phone] or Camila Victoria at [phone] to arrange
a time to review the requested materiaL.
b) Please see the Excel file on the non-confidential CD for a schedule
showing the percentages of officer remuneration that is allocated to other subsidiaries.
Idaho Power does not apply an allocation methodology to charge labor costs out of
Idaho Power to IDACORP, Inc. The Company uses a combination of direct and
allocation methods.
Officers generally use the direct method to charge hours attributable to
IDACORP affiliates. Hours are recorded using a PassPort work order. The benefit load
rate is applied to those hours, along with a fixed overhead charge. The result is biled to
IDACORP and labor costs are transferred out of Idaho Power.
In some cases, where services cannot be identified as work performed for a
specific entity, an allocation factor is used. This allocation factor is updated annually
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 49
using a 3-prong methodology. The allocation percentage takes the average of the
following:
1 . Percent of earnings to total earnings;
2. Percent of assets to total assets; and
3. Percent of headcount to total head count.
The resulting allocation is applied to labor hours and multiplied by their benefit
load labor rate along with a fixed overhead charge. The result is billed to IDACORP and
labor costs are transferred out of Idaho Power.
Executive benefits not allocated though the benefit load rate also follow the same
labor split between Idaho Power and IDACORP.
c) The requested competitive information is proprietary and confidentiaL. It
wil be made available for Staff audit at Idaho Powets corporate headquarters. Please
contact Doug Jones at [phone] or Camila Victoria at [phone] to arrange
a time to review the requested materiaL.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 50
REQUEST NO. 114: Please provide the total number of employees and
employee expenses by account and in total for the last two (2) years as well as the
budgeted amounts for 2011.
RESPONSE TO REQUEST NO. 114: Please see employee counts and
employee expenses for the requested periods in the Excel file included on the
confidential CD provided to those parties that have executed the Protective Agreement
in this matter.
The response to this Request was prepared by Jerry McCabe, Corporate Budget
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 51
REQUEST NO. 115: Please provide both federal and state quarterly and annual
payroll tax reports for the year ending 2010.
RESPONSE TO REQUEST NO. 115: Please see the documents provided on
the non-confidential CD.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefis, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 52
REQUEST NO. 116: Please provide all documents supporting budgeted and
actual wage increases for all employees during 2009 through 2011 by year. Please
include within your response the number of employees (budgeted and actual) to which
these wage increases applied and their associated salaries pre and post wage increase.
RESPONSE TO REQUEST NO. 116: Please see the documents provided on
the confidential CD which include wage adjustment data, as well as supporting
documentation for the general wage adjustments as presented to the Company's
Compensation Committee of the Board of Directors. The confidential CD wil be
provided to those parties that have executed the Protective Agreement in this matter.
As can be seen on the provided summary information, the Company performs a
comprehensive evaluation of the wage adjustments implemented by its neighboring
utilties and a sampling of local companies prior to determining the wage adjustments
for its own employees. According to the summary data, Idaho Power's wage
adjustments of 3.0 percent in 2009, 2.5 percent in 2010, and 2.0 percent in 2011
represent modest increases that are at or below the average of those implemented by
the sample group.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 53
REQUEST NO. 117: Please provide the annualized O&M salary as of December
31, 2009 and December 31 , 2010.
RESPONSE TO REQUEST NO. 117: Please see the Excel file provided on the
non-confidential CD.
The response to this Request was prepared by Jerry McCabe, Corporate Budget
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 54
REQUEST NO. 118: Please provide all offcers' employee numbers, names, job
titles, detailed job descriptions, responsibilities, base salaries, and other compensation
by year since 2008.
RESPONSE TO REQUEST NO. 118: The requested competitive information is
proprietary and confidentiaL. It wil be made available for Staff audit at Idaho Powets
corporate headquarters. Please contact Doug Jones at [phone] or Camila
Victoria at(208) 388-5821 to arrange a time to review the requested materiaL.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 55
REQUEST NO. 119: Please explain the basis for all officers' salary increases
from the 2010 level to the 2011 level. Also, please provide all documents that are
relevant to this inquiry.
RESPONSE TO REQUEST NO. 119: Officer salary levels are determined by the
Compensation Committee of the Board of Directors. The key steps the Committee
follows in setting executive compensation are to:
· Review the components of executive compensation, including base
salary, bonus, short-term incentive compensation, long-term incentive compensation,
retirement benefits, and other benefits;
· Analyze executive compensation market data to ensure competitive
compensation;
· Review total compensation structure and allocation of compensation;
and
· Review executive officer performance, responsibilty, and experience
to determine individual compensation levels.
Additional details about the Company's officer compensation philosophy, as well
as an overview of the survey data used and companies included in the survey can be
found in the 2011 IDACORP, Inc., proxy statement.
The requested 2010 survey data was reviewed by Staff at the Company's
corporate headquarters during the week of August 8.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefis, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 56
REQUEST NO. 120: Please provide a copy of all Company policies and other
relevant materials provided as an "employee handbook" for the Company's employees.
If the employee handbook is only available on the Company's intranet, please provide
access to the Company's employee handbook on the company intranet.
RESPONSE TO REQUEST NO. 120: The Company's Employee Standards
Manual ("ESM") is maintained in electronic form only on the Company's intranet. The
ESM is considered a proprietary internal document. The Company intranet can be
accessed on-site by employees only. The Company wil provide access to the ESM on-
site upon request. Please contact Doug Jones at [phone] or Camila Victoria at
[phone] to arrange a time to review the requested materiaL.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation and Benefits, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 57
REQUEST NO. 121: Please provide a copy of the Company's P-card policy.
Please highlight any changes to the policy that have occurred since the last general rate
case.
RESPONSE TO REQUEST NO. 121: The Purchasing Card Policy that was in
affect during the last general rate case is provided on the non-confidential CD. In
addition, the current Purchasing Card Standard, which replaced the previous policy, is
also provided on the non-confidential CD. The Company has highlighted major
changes to the Purchasing Card Standard.
The response to this Request was prepared by Steven R. Keen, Vice President
Finance and Treasurer, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 58
REQUEST NO. 122: Please provide a schedule showing all P-card purchases,
advances and other charges, by FERC account for the years 2010, and 2011 to date.
RESPONSE TO REQUEST NO. 122: Please see the Excel files provided on the
non-confidential CD.
The response to this Request was prepared by Steven R. Keen, Vice President
Finance and Treasurer, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 59
REQUEST NO. 123: Please provide the total dollar amount of P-card
purchases, advances and other charges for 2008 and 2009.
RESPONSE TO REQUEST NO. 123: Total P-card purchases, advances, and
other charges for 2008 was $10,275,054.16. Total P-card purchases, advances, and
other charges for 2009 was $7,283,784.42.
The response to this Request was prepared by Steven R. Keen, Vice President
Finance and Treasurer, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 60
REQUEST NO. 124: Please provide access to the documentation for all P-card
purchases, advances, and other charges to the P-card for the year 2010.
RESPONSE TO REQUEST NO. 124: The voluminous information is available
upon request at Idaho Power's corporate headquarters. Please contact Doug Jones at
[phone] or Camila Victoria at [phone] to arrange a time to review the
requested materiaL.
The response to this Request was prepared by Steven R. Keen, Vice President
Finance and Treasurer, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 61
REQUEST NO. 125: Please provide the total amount spent on food, meals,
snacks, coffee, and bottled water for the year 2010 and 2011 to date. Please provide
this information by month, by FERC account, and by category, such as coffee, meals,
bottled water, meeting snacks, etc.
RESPONSE TO REQUEST NO. 125: Please see the summary provided on the
non-confidential CD which attempts to identify bottled water, coffee, and meals by
month and FERC account. Generally, all of these are recorded in the same manner.
This listing of expenses does not segregate costs between operating and non-operating
accounts and thus includes items that have not been included in this rate proceeding.
There is also no sorting by distinction in the meal category regarding purpose, such as
meals while traveling for work-related issues, business meetings, service awards, etc.
Meeting snacks are very rare and the Company does not have a way of separating
them from the meals category if they do occur. Please see the Excel file provided on
the non-confidential CD for the summary and detail data. The detailed data includes the
business purpose of each expenditure.
The response to this Request was prepared by Steven R. Keen, Vice President
Finance and Treasurer, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 62
REQUEST NO. 126: Please provide copies of the employee newsletters issued
during 2010, and 2011 to date.
RESPONSE TO REQUEST NO. 126: Please see the employee newsletters
issued during 2010 and 2011 to date provided on the non-confidential CD.
The response to this Request was prepared by Michael Foley, Director of
Corporate Communications, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 63
REQUEST NO. 127: Please provide a listing of all penalties and fines included
in the test year, citing the account it is located in, the payee, and the amount.
RESPONSE TO REQUEST NO. 127: Penalties and fines incurred by Idaho
Power are recorded in FERC Account 426.300 (Penalties). No penalties or fines were
included for the test year.
Penalties and fines are recorded below the line, and costs are borne by
shareholders.
The response to this Request was prepared by Darrell Berg, Team Leader
Financial Accounting, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 64
REQUEST NO. 128: Please provide a listing of any costs included in the test
year related to sporting or entertainment events, including but not limited to season
tickets or sky boxes. Provide the accounts where these costs are booked and if above
the line and not already removed in this filing, please include any and all explanations
as to the business purpose.
RESPONSE TO REQUEST NO. 128: Please see the Excel file provided on the
non-confidential CD. The Excel file contains a list of P-card charges for 2010 that
match the criteria requested. Charges that were reimbursed by employees, below the
line, or adjusted for in the filing have been removed. The business purpose for each
charge is contained in column i of the Excel worksheet.
The response to this Request was prepared by Steven R. Keen, Vice President
Finance and Treasurer, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 65
REQUEST NO. 129: Please provide a listing of all charitable contributions,
including names, amounts and account numbers included in the test year. Please
include all accounts other than account 930, where charitable contributions are also
booked.
RESPONSE TO REQUEST NO. 129: Charitable contributions are removed in
their entirety from the test year. Please see the Direct Testimony of Douglas N. Jones,
pp. 13-14, and Exhibit No. 15, pp. 2-3.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 66
REQUEST NO. 130: Please provide a listing of licenses paid for by the
Company, such as PE, CPA, Legal, etc. included in the test year by FERC account and
sub-account included in the test year.
RESPONSE TO REQUEST NO. 130: Licenses are included in various accounts
and identified by detail cost element ("DCE") 535, which includes: personal
memberships, dues, registrations for professional associations, conferences, and
seminars. However, without a review of individual invoices, the Company is unable to
identify which specific charges are for professional licenses. Please see the Excel file
provided on the non-confidential CD which includes all charges to DCE 535.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 67
REQUEST NO. 131: Please provide the audit workpapers from the external
auditors for 2010.
RESPONSE TO REQUEST NO. 131: Deloitte's workpapers are Deloitte's
property and not under the Company's control. However, the Company has discussed
this Request with Deloitte and they have agreed to provide access to the Staff to
conduct its review of Deloitte's workpapers pursuant to Deloitte's workpaper policies
and the guidance provided in the standards of the American Institute of Certified Public
Accountants. Please contact Doug Jones at [phone] or Camila Victoria at (208)
388-5821 to make arrangements for viewing Deloitte's workpapers.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 68
REQUEST NO. 132: Please provide the Board of Director minutes, including all
material distributed and/or discussed at the meetings, including but not limited to
external reports, committee reports, handouts, charts, etc. for the years 2010 and 2011
to date.
RESPONSE TO REQUEST NO. 132: The requested information is voluminous,
confidential, and may be subject to both attorney-client and accountant-client privilege.
Notwithstanding the foregoing, Idaho Power is willing to make the requested information
available to Staff at its corporate headquarters. Please note that Idaho Powets Board
of Directors meeting minutes and reports were made available for review in response to
Staffs Audit Request No.8, and Staff reviewed the requested information on August 2,
3, 5, 10, and 12, 2011. Please contact Doug Jones at [phone] or Camìla
Victoria at [phone] to schedule a time to review the materiaL.
The response to this Request was prepared by Pat Harrington, Corporate
Secretary, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 69
REQUEST NO. 133: Please provide a schedule showing 2009, 2010, and 2011
to date monthly balances for the materials and supplies subaccounts. Please include
within your response the descriptions of the accounts, the amounts in each account and
the turnover ratios for each account.
RESPONSE TO REQUEST NO. 133: Please see the Excel file provided on the
non-confidential CD.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 70
REQUEST NO. 134: Please provide a list of all leased items in 2010 and to date
in 2011. Please separately identify those leases historically accounted for as capital
leases and operating leases. Please include within your response the dates, terms,
amounts and accounts used for each lease.
RESPONSE TO REQUEST NO. 134: Idaho Power does not have capital
leases. Please see the Excel file provided on the non-confidential CD for a summary of
operating leases. The operating lease summary does not include easements or month-
to-month construction equipment rentals.
The response to this Request was prepared by Sandy Kowalls, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 71
REQUEST NO. 135: Please provide copies of the Company's most recent cost
allocation manuals.
RESPONSE TO REQUEST NO. 135: The cost allocation manual used in this
case was the National Association of Regulatory Utiity Commissioner's Electric Utilty
Cost Allocation Manual. If the Idaho Public Utilties Commission does not have a copy
of this manual, upon request, the Company wil make a copy available for review at
Idaho Powets corporate headquarters. Please contact Doug Jones at [phone]
or Camila Victoria at [phone] to schedule a time to review the materiaL.
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.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 72
REQUEST NO. 136: For each of the plant additions listed on Witness Noe's
Exhibit No. 22 (Major Plant Additions Annualized for 2011), please provide the following
information separately for each project: invoice number, description of payment, vendor
name, date posted and amount, for inception of project to date.
RESPONSE TO REQUEST NO. 136: Due to the large volume of data, the
information requested is summarized at the work order/project level in the Excel file
provided on the non-confidential CD. Detailed transaction information wil be provided
for specific work orders/projects if requested.
The response to this Request was prepared by Shelby Leforgee, Finance Team
Lead, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 73
REQUEST NO. 137: Please provide an updated Exhibit No. 22 using month end
June 2011 information.
RESPONSE TO REQUEST NO. 137: Please see the Excel file provided on the
non-confidential CD.
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.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 74
REQUEST NO. 138: Please identify the costs included within the filng that are
associated with any projects that have been abandoned. Please include within your
response the amount and accounts posted along with the applicable allocation factors.
RESPONSE TO REQUEST NO. 138: There were no costs included within the
filng that are associated with any projects that have been abandoned.
The response to this Request was prepared by Jerry McCabe, Corporate Budget
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 75
REQUEST NO. 139: Please provide a list showing a summary of all consultants
and attorneys (internal and external) who performed services for the Company or who
were paid by the Company for 2010 that are included in the test year. For all attorneys,
show services performed, amounts paid, and accounts charged. If services were
performed in support of a docketed federal/state court or regulatory agency action,
please identify the case name, case number and jurisdiction. If studies were the result
of any of these payments, please provide a copy of those studies.
RESPONSE TO REQUEST NO. 139: Please see the Excel file provided on the
non-confidential CD for non-attorney consultants who performed services for the
Company or were paid in 2010 that are included in the test year.
For attorney-related information, the requested information is voluminous,
confidential, and may be subject to both attorney-client and accountant-client privilege.
Notwithstanding the foregoing, Idaho Power is willing to make the requested information
available to Staff at its corporate headquarters. Please contact Doug Jones at (208)
388-2615 or Camilla Victoria at [phone] to arrange a time to review the
requested materiaL.
The response to this Request was prepared under the direction of Doug Jones,
Finance Team Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 18th day of August 2011.
ce.Q~~
LISA D. NORDSROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 76
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of August 2011 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH
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
-2 Email Don.Howell~puc.idaho.gov
Karl. Kleincæpuc. 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
-2 Email petercærichardsonandoleary.com
greg~richardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email drcæbenjohnsonassociates.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
-2 Email elocæracinelaw.net
Anthony Yankel
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email tony~yankel.net
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 77
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
-l Email kboehmcæBKLlawfirm.com
jrhCâbattfisher.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email khigginsCâenergystrat.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email myorkcæhollandhart.com
tnelsonCâholland hart. com
madavidsonCâhollandhart.com
fschmidtCâhollandhart.com
In buchananCâholland hart. com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email remalmgrenCâmicron.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email Arthur.bruderCâhq.doe.gov
Steven. portercæhq.doe.gov
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email detheridgeCâexeterassociates.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 78
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 bmpurdycæhotmail.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 bottocæidahoconservation.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((snakeriverallance.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((nwenergy.org
Ó(¿J)tf~J
Lisa D. Nordstro
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 79