20110825IPC to ICIP 37-44.pdf

REC D
*SIDA~POR~
An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
Inordstromcmidahopower.com
August 24, 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 filing are an original and one (1) copy of Idaho Power Company's
Response to the Fourth Requests for Production of the Industrial Customers of Idaho
Power to Idaho Power Company in the above matter.
Also enclosed are three (3) copies of a non-confidential disk and three (3) copies of
a confidential disk containing information being produced in response to this production
request.
Please handle the enclosed confidential information in accordance with the
Protective Agreement executed in this matter.
Very truly yours,
¡2~ l)'1(f~
Lisa D. Nordstro~
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: [phone]
Facsimile: [phone]
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Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC )SERVICE IN IDAHO. )
)
)
)
)
CASE NO. IPC-E-11-08
IDAHO POWER COMPANY'S
RESPONSE TO THE FOURTH
REQUESTS FOR PRODUCTION OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Fourth Requests for Production of the Industrial Customers of Idaho
Power dated July 27, 2011, and e-mailed on August 3, 2011, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 37: Reference Direct Testimony of Scott
Sparks, p. 38, lines 12-13 (stating that the "Book Depreciation" component of the
facilities charge uses "a straight line annual depreciation of assets based on a levelized
31 year basis"). For Schedules 9, 19, 24 and Special Contract Customers, please
separately provide:
(a) the original asset value of all facilities currently subject the facilties charge
(Le. the "Company's investment" referenced in the charge's calculation set forth in the
tariffs);
(b) the average age of the individual pieces of equipment currently subject to
the facilities charge;
(c) the average dollar weighted age of the individual pieces of equipment
currently subject to the facilties charge; and
(d) remaining book value of the equipment subject to the facilities charge (Le.
assuming straight line 31-year depreciation from the amounts provided in response to
item (a)).
RESPONSE TO REQUEST FOR PRODUCTION NO. 37:
(a) Idaho Power objects to this Request as it is overly broad and unduly
burdensome and seeks information related to thousands of facilities and would require
an extraordinary amount of time to produce. Notwithstanding, the Company has
included in the attached Excel file the original asset value of facilities for a sample of
Schedule 9 and 19 facilties charge customers and one Special Contract customer. The
sample includes three Schedule 9 customers and three Schedule 19 customers. For
each schedule, the sample includes one customer from each of the Company's three
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
geographic regions (Canyon-West, Capital, and South-East). There are currently no
customers taking service under Schedule 24, Transmission Service.
(b) The average age of the individual pieces of equipment currently subject to
the facilities charge is approximately 17 years for Schedule 9 customers, 19 years for
Schedule 19 customers, and 24 years for Schedule 29 Special Contract customers.
There are currently no customers taking service under Schedule 24, Transmission
Service.
(c) The Company does not calculate the average dollar weighted age of the
individual pieces of equipment currently subject to the facilities charge.
(d) Idaho Power objects to this Request as it is overly broad and unduly
burdensome and seeks information related to thousands of facilities and would require
an extraordinary amount of time to produce. Notwithstanding, the Company has
included in the attached Excel file the remaining estimated net book value of the
equipment subject to the facilities charge from the amounts provided as a sample in
response to Request for Production No. 37(a).
The response to this Request was prepared under the direction of Scott D.
Sparks, Senior Regulatory Analyst, Idaho Power Company, in consultation with Jason
B. Wiliams, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 38: Reference the table set forth in the
Direct Testimony of Matthew Larkin on p. 25.
(a) Please provide the values for the Other Expense item labeled "Fuel,"
organized by generation facility. Please include identification of each generation facility
as either a "Peaking Unit" or a "Generation and Steam Production Unit," as those terms
are used in the cost of service study.
(b) Please explain why the cost of Fuel used for Peaking Plants is allocated
100% to Energy and not 100% to Demand consistent with the allocation of Peaking Unit
costs.
(c) Please explain why the cost of Fuel used for Generation and Steam
Production Units is not allocated 53.88% Energy and 46.12% Demand, consistent with
the allocation of Generation and Steam Production Unit costs.
(d) Does Idaho Power agree that it would be logical to allocate the costs of
fuel consistent with the allocation of the generation facilty using the fuel? Please
explain the response.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38:
(a) Please see the attached PDF file containing fuel expenses by generating
facilty as approved in Case No. IPC-E-10-01, Order No. 31042. As described in the
Direct Testimony of Timothy E. Tatum, Accounts 501 and 547 were held at the level
approved in the above-referenced case. Account 501 contains fuel expenses
associated with the coal-fired Valmy, Jim Bridger, and Boardman generating facilties.
Account 547 contains fuel expenses associated with the gas-fired Danskin and Bennett
Mountain generating facilities.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
(b) As stated on page 10 of the Direct Testimony of Matthew T. Larkin, lines
9-12, "In order to classify a particular cost by component, primary attention is given to
whether the cost varies as a result of changes in the number of customers, changes in
demand imposed by the customers, or changes in energy used by the customers." The
amount of fuel consumed at the Company's generating plants is directly related to the
amount of energy produced by these plants. Because fuel costs are driven by customer
energy usage, they are classified as energy-related. This classification is consistent
with the methods outlined in the Electric Utility Cost Allocation Manual, published
January 1992, by the National Association of Regulatory Utility Commissioners, which is
used as the basis for the Company's 3CP/12CP cost-of-service study. As stated on
page 35 of this manual, "Variable production costs change with the amount of energy
produced, delivered, or purchased and are classified as energy-related."
(c) Please see the Company's response to the Industrial Customers of Idaho
Power's ("ICIP") Production Request No. 38(b).
(d) No. It would not be logical to allocate variable fuel costs in a manner
consistent with fixed generation investment. Variable fuel costs and fixed generation
costs are two different categories of investment with differing cost drivers. Allocating
fuel in the same manner as fixed investment in generation resources would disconnect
cost allocation from cost causation, resulting in a class cost-of-service study that would
misalign these components of the revenue requirement with incorrect allocation bases.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 39: Please provide all work papers,
documentation, and a complete explanation of the development of the normalized
values found in Wright Exhibit 18 in spreadsheet labeled, "Test Year 2011,
Cogeneration and Small Power Production, Rate Department Normalized Information,"
and explain how those values flow from the FERC Account 555.2 data supplied the
Company's Response to DOE's Data Request No. 1-13. Please include explanation
why the values in Wright Exhibit 18 are higher than those found in the Company's
Response to DOE's Data Request No. 1-13.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39: Please see the Excel
spreadsheet provided on the confidential CD that contains the confidential financial and
Public Utilty Regulatory Policies Act of 1978 ("PURPA") project information that
supports Wright Exhibit No. 18.
The method used to derive the Federal Energy Regulatory Commission ("FERC")
Account 555.2 (PURPA Expense) information in Wright Exhibit No. 18 is consistent with
that approved by the Idaho Public Utilities Commission ("Commission") in prior revenue
requirement proceedings, including Case No. IPC-E-10-01 (Final Order No. 31042),
which established the current base level PURPA Expense included in base rates.
The method used to create Wright Exhibit No. 18 is as follows:
. Only Commission-approved agreements were included in Exhibit No. 18.
. Estimated generation based on a rollng 5-year average of actual output,
or less than five years if the project does not have five years of history.
. If a project is new, 100 percent of the contract estimated generation was
used.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
· If a project on-line date or estimated on-line date occurs in any month of
the year, a full 12 months of estimated data is included for that entire year.
As stated in the Direct Testimony of Scott Wright, on pages 2 and 11, the
variable power supply expenses created for the 2011 Test Year are for information
purposes only; therefore, Wright Exhibit No. 18 was not used for Account 555 for the
2011 Test Year.
The values in Wright Exhibit No. 18 are forecasted values for a 2011 Test Year.
The information provided in the Company's response to the U.S. Department of
Energy's Request No. 1-13 includes historical values.
The response to this Request was prepared by Scott Wright, Regulatory Analyst,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 40: The Company requests a load change
adjustment rate (LCAR) of $19.28/MWh for all customers (Larkin DI, p. 38 and Exhibit
39), and a fixed cost adjustment (FCA) of .1218 cents/kWh for residential customers
and to 0.2273 cents/kWh for Small Commercial customers (Cavanaugh (sic) DI, Exhibit
42). Please fully explain why this is not allowing the Company to be over-compensated
for reduced power sales attributable to a decline in the economy and/or the Company's
demand side management efforts. Please include explanation of the steps taken by the
Company to ensure that effects of LCAR and the FCA wil not result in double recovery
for declining loads.
RESPONSE TO REQUEST FOR PRODUCTION NO. 40: The proposed load
change adjustment rate ("LCAR") of $19.28/megawatt-hours ("MWh") was derived
according to the methodology approved by the Commission in Order No. 32206. Under
the currently approved methodology, the LCAR represents the amount of variable
generation-related cost recovery that is included in the Company's base rates. In
periods of load growth, the LCAR eliminates the double recovery of variable generation-
related costs. In periods of load decline, the LCAR is consistently applied to ensure that
customers are not provided a double benefit related to reduced variable generation-
related costs. That is, once through base rates and again through the Power Cost
Adjustment ("PCA). Therefore, the LCAR mechanism does not result in any over-
compensation for Idaho Power. The Commission acknowledged this fact in Order No.
32206 when it made the following statement regarding the LCAR: "This approach stil
allows the utility to recover its variable energy costs incurred to reliably serve its
customers, while limiting the utility's recovery of lost revenue in periods of declining
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
load. We continue to find that a symmetrical approach for growing and declining loads
is just and reasonable to both the utilty and its customers."
The Fixed Cost Adjustment ("FCA") rates shown in Ralph Cavanagh Exhibit No.
42 as proposed 2010 rates of 0.1801 cents/kilowatt-hours ("kWh") for Residential
customers (not 0.1218 cents/kWh as stated in the request) and 0.2273 cents/kWh for
Small Commercial customers were approved in Order No. 32251 and are in effect June
1, 2011, through May 31, 2012. The FCA is a mechanism that allows the Company to
recover its currently authorized level of fixed costs per customer for Residential Service
and Small General Service. This does not represent over-compensation but rather
collection of fixed costs authorized for recovery by the Commission.
The LCAR derivation methodology approved by Order No. 32206 ensures that
effects of the LCAR and the FCA wil not result in double recovery for declining loads.
In Order No. 32206 the Commission stated that the currently approved LCAR
methodology "eliminates the possibility of double recovery of demand classified
embedded production revenue requirement that Idaho Power recovers through its Fixed
Cost Adjustment (FCA) mechanism."
The response to this Request was prepared by Timothy E. Tatum, Senior
Manager of Cost of Service, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 41: Reference Commission Order No.
32206, p. 2 (stating that the proposed LCAR rate for Idaho Power would be
$15.43/MWh on March 15, 2011). Please explain the factors that have increased the
load change adjustment rate to $19.28/MWh as set forth Exhibit 49 to the Direct
Testimony of Matthew Larkin. Include explanation of what has caused the energy
classified portion of embedded production revenue requirement to increase over 25%
since March 2011. Wil the LCAR result in a increased or decreased rates this year?
RESPONSE TO REQUEST FOR PRODUCTION NO. 41: The LCAR of
$15.43/MWh was based on the 2008 test year used in the Company's most currently
approved class cost-of-service study in Case No. IPC-E-08-10 ("2008 Rate Case"),
while the $19.28/MWh rate is based on the 2011 Test Year used in the class cost-of-
service study filed in the current proceeding, Case No. IPC-E-11-08 ("2011 Rate Case").
Therefore, the change from $15.43/MWh to $19.28/MWh does not reflect an increase of
over 25 percent to the energy classified portion of embedded production revenue
requirement between March 2011 and June 2011, but rather the difference between
2008 test year costs approved in the 2008 Rate Case and 2011 Test Year costs filed in
the 2011 Rate Case. It should also be noted that the current effective LCAR, approved
in the June 1, 2011, Errata to Order No. 32250, is $19.67/MWh. The proposed
$19.28/MWh rate reflects a decrease from the current effective rate.
The primary driver of change between the $15.43/MWh rate and the
$19.28/MWh rate is the update of net power supply expenses resulting from Case No.
IPC-E-1 0-01, Order No. 31042. The class cost-of-service study in the 2008 Rate Case
identified $321,035,222 as embedded energy-related production expenses, while the
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 10
class cost-of-service study in the 2011 Rate Case identifies $376,827,588 as embedded
energy-related production expenses. This accounts for an increase of approximately
$56 million to the energy-related portion of embedded production revenue requirement,
which is responsible for the majority of the increase to the final calculated LCAR.
Idaho Power cannot speculate as to whether the proposed LCAR will have a
positive or negative impact on rates this year. The dollar impact of the LCAR is
calculated by applying the approved per MWh rate to the amount of actual energy
usage that deviates from normalized test year loads used to determine current base
rates. This adjustment is calculated and applied to the PCA deferral balance on a
monthly basis for the April through March PCA year, and the cumulative dollar impact
on rates cannot be determined until all months have been calculated. Consequently,
the Company cannot determine the effect of the proposed LCAR at this time.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11
REQUEST FOR PRODUCTION NO. 42: Reference Rebuttal Testimony of the
Conservation Parties, Nancy Hirsh, IPC-E-10-25, pp. 3-4, stating:
The A-J effect argues that utiities have an incentive to put
large capital projects into their rate base if the allowable rate
of return exceeds the cost of capital. I emphasize this
second clause because this is essential to understanding if
the A-J effect applies to Idaho Power. The incentive occurs
because given a fixed rate of return that exceeds the cost of
capital; shareholders earn more on a $1 million investment
than a $1 investment. But as explained by Steve Kihm in
When Revenue Decoupling Wil Work. . .and When it Won't:
"If a regulator keeps allowed rates of return close to a utilty's
cost of capital, increasing the earned rate of return wil be
the primary driver of the utilty's stock price." See Kihm at 1,
Attachment 1. ICIPs "discussion" of the A-J effect neglects
to provide this full explanation and does not attempt to
examine Idaho Power's rate of return relative to their cost of
capitaL.
(a) Does Idaho Power agree with this assessment of the A-J effect and cost
of capital?
(b) Does Ralph Cavanagh agree with this assessment of the A-J effect and
cost of capital?
(c) Please explain how Idaho Powets cost of capital is close to Idaho Power's
authorized rate of return? If Idaho Power's explanation is different from Mr. Cavanagh's
please explain.
(d) If Idaho Powets cost of capital is not close to its authorized rate of return,
please explain how continuation of the fixed cost adjustment wil overcome the A-J
effect for Idaho Power without a corresponding reduction in the Company's authorized
rate of return.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
RESPONSE TO REQUEST FOR PRODUCTION NO. 42: Idaho Power objects
to subparts (a) and (b) of this Request on the grounds that the Request calls for a
statement of opinion proscribed by RP 225.01. Subject to and without waiving the
foregoing objection, Idaho Power responds as follows:
(a) Idaho Power agrees with Nancy Hirsh's assessment that ICIP's
"discussion" of the A-J effect neglects to provide a full explanation and does not
attempt to examine Idaho Power's rate of return relative to its cost of capitaL.
Idaho Power's rate of return is equal to its overall average cost of capital;
therefore, the A-J effect, by definition, would not apply to Idaho Power. The A-J
effect assumes that resource plans are developed in a vacuum and the Company
is guaranteed its authorized rate of return on investment and not subject to
intense prudency review. The Company's Integrated Resource Plan planning
process is open and takes into account many different factors and inputs from a
number of constituents, not just the Company's profitability.
(b) Ralph Cavanagh agrees that regulators would give utiities an
incentive to deploy capital by providing an allowed rate of return in excess of the
cost of capital, and he also agrees that utilities are motivated generally to
increase their earned rate of return (whether or not regulators keep allowed rates
close to utilities' costs of capital).
(c) Idaho Powets requested cost of capital is equal to its requested
rate of return.
(d) Not applicable. Please see the Company's response to Production
Request No. 42(c) above.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13
The response to this Request was prepared by Mike Youngblood, Manager of
Rate Design, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 14
REQUEST FOR PRODUCTION NO. 43: Reference the Direct Testimony of
Ralph Cavanaugh (sic), p. 8, lines 10-13 and Exhibit 42. Please explain why the fixed
cost adjustment has increased each year since its inception. If made permanent, wil
the FCA continue to increase each year?
RESPONSE TO REQUEST FOR PRODUCTION NO. 43: While FCA rates have
increased in each of the last three years, it is also important to note that the FCA rates
have been both positive and negative since its inception. As pointed out in the cited
testimony of Mr. Cavanagh, p. 8, II. 10-13, as well as in Exhibit No. 42, the impact to
customer bils resulting from FCA adjustments has been both an increase as well as a
decrease.
The FCA has increased in the last three years simply because the average use
per customer has decreased relative to the usage levels at the time when the
authorized fixed costs recovered through the energy charge were established in a
preceding general rate case. However, in the first year of the pilot, the average use per
customer was greater than the usage level when the authorized fixed cost recovery was
first set, and resulted in a credit back to the customer. The FCA, as designed, wil
recover no more and no less than the authorized level of fixed costs included in the
energy charge.
The Company's proposal for the permanent FCA is the same mechanism that
has existed throughout the 5-year pilot period. If the FCA is made permanent, it would
continue to recover no more than and no less than the authorized level of fixed costs
established in a general rate case being recovered through the volumetric energy
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 15
charge. Each yeats adjustment could stil be either positive or negative, resulting in
either an increase or a decrease to a customets bilL.
The response to this Request was prepared by Mike Youngblood, Manager of
Rate Design, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 16
REQUEST FOR PRODUCTION NO. 44: Reference the Direct Testimony of
Ralph Cavanaugh (sic), p. 12, lines 3-9.
(a) Please explain why the FCA has not reduced Idaho Power's financial
risks.
(b) Please explain how the LCAR authorizing recovery through the PCA for
lost revenue for the energy classified portion of embedded production revenue
requirement has not reduced Idaho Power's financial risks.
(c) Please explain how the Company considered its reduced risk from these
combined mechanisms in its analysis of its necessary rate of return in this case. If the
Company did not consider these two risk reduction factors, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 44:
(a) Idaho Powets FCA is designed to remove the financial disincentive for the
Company's investment and acquisition of demand-side management ("DSM")
resources. Since the implementation of the FCA, the Company's expenditures in DSM
resources have increased significantly. This large investment of capital is subject to
increased scrutiny through the annual DSM prudency review, yet it currently does not
earn a rate of return as do the Company's other investments into resources. The
financial risks associated with the FCA and related energy efficiency activities were
considered in the Company's requested cost of capitaL.
(b) The LCAR does not authorize the recovery of "lost revenue" through the
PCA. Under the currently approved methodology, the LCAR represents the amount of
variable generation-related cost recovery that is included in the Company's base rates.
In periods of load growth, the LCAR eliminates the double recovery of variable
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 17
generation-related costs. In periods of load decline, the LCAR is consistently applied to
ensure that customers are not provided a double benefit related to reduced variable
generation-related costs, once through base rates and again through the PCA.
(c) In general, the Company would say such mechanisms are viewed as
supportive from a regulatory perspective. Return on equity recommendations in this
case were made with the expectation that the mechanisms wil continue to exist.
Elimination of these mechanisms or reductions to the regulatory support they provide
could elevate risk and cause return on equity recommendations to rise.
The response to this Request was prepared by Mike Youngblood, Manager of
Rate Design, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 24th day of August 2011.
vOø/p:. J). ;~
LISA D. NORDSli OM
Attorney for Idaho ower Company
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 18
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24th day of August 2011 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH
REQUESTS FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Donald L. Howell, II
Karl T. Klein
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
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FAX
-- Email Don.Howelicæpuc.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
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-- Email petercærichardsonandoleary.com
gregcærichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hill Road
Boise, Idaho 83703
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-- Email dr(gbenjohnsonassociates.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
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-- Email elo(gracinelaw.net
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
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-- Email tony(gyankel.net
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 19
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
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-2 Email detheridge(êexeterassociates.com
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 20
Community Action Partnership
Association of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1ih Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email bmpurdyCãhotmail.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 bottoCãidahoconservation.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 kmillerßRsnakeriverallance.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 nancyßRnwenergy.org
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IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH REQUESTS
FOR PRODUCTION OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 21