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Home My WebLink About20110826Kroger to IPC Q3.1-Q3.4.pdf,VIA OVERNIGHT MAIL Jean D. Jewell, Secretary Idaho Public Utilties Commission P.O. Box 83720 472 W. Washigton Street Boise, Idaho 83720-0074 In re: Case No. IPC-E-ll-08 Dear Ms. Jewell: BOEHM, KURTZ & lOWRY AlTORNS AT lAW 36 EAT SEV STET SUITE 1510 CINCINNATI, OHIO 45202 TELEPHONE (513) 421.2255 CEIVED ZOiI P;UG 26 Afî 10= 24 TELECOPIER (513) 421.2764 August 25,2011 Enclosed please find the original and (7) copies of the THIR SET OF INTERROGATORIES OF THE KROGER CO. to IDAHO POWER COMPANY to be fied in the above referenced matter. Please place this document of file. Copies have been sered on all parties listed on the attached Cerificate of Serice. KJkew Encl RlØ;J Kurt J. Boehm, Esq. BOEHM, KURTZ & LOWRY G:\WORKIMKIKOGERIIAHOIIC-E-1 I-08\Commission Data Request leter.docx John R. Hammond, Jr., ISB No. 5470 BATT FISHER PUSCH & ALDERM, LLP U.S. Bank Plaza, 5th Floor 101 S. Capitol Boulevard, Suite 500 P.O. Box 1308 Boise, Idaho 83701 Telephone: 208.331.1000 Facsimile: 208.331.2400 E-mail: jrhifbattfisher.com , RECEIVED iOll t:lIG 26 MilO: 24 fl.....ii.) Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 E. Seventh St., Suite 1510 Cincinati, Ohio 45202 Telephone: 513.421.2255 Facsimile: 513.421.2764 E-mail: KBoehmifbkllawfirm.com Attorneys for Kroger Co. BEFORE TH IDAHO PUBLIC UTILITIES COMMSSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPAN FOR ) AUTHORITY TO INCREASE ITS RATES ) AND CHAGES FOR ELECTRIC SERVICE TO ) ITS CUSTOMERS IN THE STATE OF IDAHO ) ) ) Case No. IPC-E-11-08 TI SET OF INERROGATORIS OF KROGER CO. TO IDAHO POWER COMPAN THI SET OF INTERROGATORIS OF THE KROGER CO. TO IDAHO POWER COMPAN August 25, 2011 DEFINIONS 1. "Document" means the original and all copies (regardless of origin and whether or not including additional writing thereon or attched thereto) of memoranda, reports, books, manuals, instrctions, directives, records, forms, notes, letters, notices, confrmations, telegrams, pamphlets, notations of any sort concerning conversations, telephone calls, meetings or other communications, bulletins, trscripts, diaries, analyses, summaries, correspondence investigations, questionnaires, sureys, worksheets, and all drafts, preliminar versions, alterations, modifications, revisions, changes, amendments and written comments concerning the foregoing, in whatever form, stored or contained in or on whatever medium, including computerized memory or magnetic media. 2. "Study" means any written, recorded, transcribed, taped, fimed, or graphic matter, however produced or reproduced, either formally or informally, a paricular issue or sitution, in whatever detail, whether or not the consideration of the issue or situation is in a preliminar stage, and whether or not the consideration was discontinued prior to completion. 3. "Person" means any natual person, corporation, professional corporation, parership, association, joint venture, proprietorship, firm, or the other business enterprise or legal entity. 4. A request to identify a natural person means to state his or her full name and residence address, his or her present last known position and business affiliation at the time in question. 5. A request to identify a document means to state the date or dates, author or originator, subject matter, all addressees and recipients, tye of document (e.g., letter, memorandum, telegram, char etc.), number of code number thereof or other means of identifying it, and its present location and custodian. If any such document was, but is no longer in the Company's possession or subject to its control, state what disposition was made of it. 6. A request to identify a person other than a natual person means to state its full name, the addrss of its principal office, and the tye of entity. 7. "And" and "or" should be considered to be both conjunctive and disjunctive, unless specifically stated otherwise. 8. "Each" and "any" should be considered to be both singular and plural, unless specifically stated otherwise. 9. Words in the past tense should be considered to include the present, and words in the present tense include the past, unless specifically stated otherwise. 10. "You" or "your" means the person whose filed testimony is the subject ofthese interrogatories and, to the extent relevant and necessar to provide full and complete answers to any request, "you" or "your" may be deemed to include any person with information relevant to any interrogatory who is or was employed by or otherwise associated with the witness or who assisted, in any way, in the preparation of the witness' testimony. 11. Idaho Power Co. ("Company") means any of their offcers, directors, employees, or agents who may have knowledge of the paricular matter addressed. INSTRUCTIONS 1. If any matter is evidenced by, referenced to, reflected by, represented by, or recorded in any document, please identify and produce for discovery and inspection each such document. 2. These interrogatories are continuing in natue, and information which the responding par later becomes aware of, or has access to, and which is responsive to any request is to be made available to Fred Meyer Stores, studies, documents, or other subject matter not yet completed that wil be relied upon durng the course of this case should be so identified and provided as soon as they are completed. The Respondent is obliged to change, supplement and correct all answers to interrogatories to conform to available informatiön, including such information as it first becomes available to the Respondent after the answers hereto are served. 3. Unless otherwise expressly provided, each interrogatory should be constred independently and not with reference to any other interrogatory herein for purpose of limitation. 4. The answers provided should first restate the question asked and also identify the person(s) supplying the information. 5. Please answer each designated par of each information request separately. If you do not have complete information with respect to any interrogatory, so state and give as much information as you do have with respect to the matter inquired about, and identify each person whom you believe may have additional information with respect thereto. 6. In the case of multiple witnesses, each interrogatory should be considered to apply to each witness who wil testify to the information requested. Where copies of testimony, transcripts or depositions are requested, each witness should respond individually to the information request. 7. The interrogatories are to be answered under oath by the witness(es) responsible for the answer. THI SET OF INTERROGATORIS OF THE KROGER CO. TO IDAHO POWER COMPAN CASE NO. IPC-E-ll-08 Q3-1. Please refer to Sparks Direct Testimony, page 8, lines 7-10. Mr. Sparks states that: "the rate design proposal for Schedule 9 Secondar Service is included on page 2 of Exhibit No. 47 and targets the proposed class revenue increase of 14.85 percent shown on page 9 of Mr. Larkin's Exhibit No. 38. " However, on the actual Exhibit No. 47, page 2, the proposed percent increase is 6.46 percent. This number is also reflected in Mr. Larkin's Exhibit No. 38, page 9. Please confirm that the language in Mr. Spark's testimony is incorrect. Oterwise, please explain. Q3-2. Please prepare a class cost of service study, similar in all respects to the cost of service sumarized in IPC witness Mr. Larkin's Exhibit 35 (as corrected in response to Staf DR No. 31), except treat classes 9S and 9P as a single, consolidated class. Please provide this cost of service study in electronic format with formulas intact. Q3-3. Please identify the inputs to the corrected cost of service model that require modification to assess the treatment of 9S and 9P customers as a single, consolidated class. Q3-4. Please provide any workpapers (in Excel with formulas intact) that differ from those provided in support of IPC's fied cost of service study summarized in Mr. Larkin's Exhibit 35 (and corrected in response to Staffs DR No. 31) that support Kroger's request above for assessing the cost of service results of a consolidated Schedule 9. Please provide your responses to our consultat at the address listed below. Kevin Higgins Energy Strategies, LLC Parkside Towers 215 South State Street, Suite 200 Salt Lake City, Uta 84111 khigginsifenergystrat.com r~laiur J. oehm, Esq. BOEHM, KUTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinati, Ohio 45202 Ph: (513) 421-2255 Fax: (513) 421-2764 E-mail: kboehmifBKLlawfirm.com CERTIFICATE OF SERVICE I hereby certify that true copy of the foregoing was served by electronic mail (when available) and regular u.s. mail, unless otherwise noted, this 25th day of August, 2011 to tl¡, e 0 wing', V" IDAHO POWER COMPANY Lisa D. Nordstrom Donovan E. Walker Jason B. Wiliams Idaho Power Company 1221 W. Idaho St. (83702) Boise, ID 83707-0070 E-mail: Inordstrom(iidahopower.com dwalker(iidahopower.com iwiliams(iidahopower.com (Via Overnight Mail) Anthony Yanicel 29814 Lake Road Bay Village, OH 44140 E-mail: tony(yanke1.net Gregory W. Said Vice President, Regulatory Affairs Idaho Power Company 1221 W. Idaho St. (83702) PO Box 70 Boise, ID 83707-0070 E-mail: gsaid(iidahopower.com INDUSTRIAL CUSTOMERS OF IDAHO POWER: Peter 1. Richardson Gregory M. Adams Richardson & O'Leary, PLLC 515 N. 77th Street PO Box 7218 Boise, ID 83702 E-mail: peter(lrichardsonandolear.com greg(lrichardsonandolearv.com Don Reading 6070 Hil Road Boise, ID 83703 E-mail: dreading(lmindspring.com COMMISSION STAFF: Donald L. Howell, II Karl Klein Deputy Attorneys General Idaho Public Utilities Commission 472 W, Washington (83702) PO Box 83720 Boise, ID 83720-0074 E-mail: don.howell(ipuc.idaho.gov karl.k1ein(ipuc.idaho.gov THE UNITED STATES DEPARTMENT OF ENERGY: Arhur Perr Bruder Attorney-Advisor United States Department of Energy 1000 Independence Ave., SW Washington, DC 20585 Email: Arhur.bruder(lhg.doe.gov IDAHO IRRGATION PUMPERS ASSOCIATION, INC: Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chartered 201 E. Center PO Box 1391 Pocatello, ID 83204-1391 E-mail: elo(l.racinelaw.net Dwight Etheridge Exeter Associates, Inc. 5565 Sterrett Place Suite 310 Columbia, MD 21044 Email: detheridge(iexeterassociates.com G:\WORK\MLK\KROGER\IDAHO\IPC-E- I 1-08\Commission Data Request letter.docx Steven A. Porter Assistant General Counsel Electricity and Fossil Energy United State Department of Energy E-mail: steven.porter(Whq.doe.gov COMMY ACTION PARTNERSHIP ASSOCIATION OF IDAHO: Brad M. Pudy, Attorney at Law 2019 N. 17th St. Boise, ID 83702 E-mail: bmpurdwyhotmail.com MICRON TECHNOLOGY, INC: Richard E. Malmgren Sr. Asst. General Counsel Micron Technology, Inc. 800 South Federal Way Boise, ID 83716 E-mail: remalmgrenßYmicron.com MaryV. York Thorvald A. Nelson Mark A. Davidson Holland & Hart, LLP 6800 S. Fiddlers Green Circle Suite 500 Greenwood Vilage, CO 80111 Email: myorkßYhollandhrt.com tne1sonØlollandhart.com madavidsonCihollandhart.com IDAHO CONSERVATION LEAGUE: Benjamin 1. Otto Idaho Conservation League 710 N. Sixth Street PO Box 844 Boise,ID 83701 Email: bottoCiidahoconservation.org SNAK RIVER ALLIANCE: Ken Miler Snake River Alliance PO Box 1731 Boise, ID 83701 Email: kmillerCisnakeriveralliance.org G:\WORK\MLK\KROGER\IDAHO\IPC-E-II-Q8\Commission Data Request letter.doex