20110829DOE to IPC 5.1-5.3.pdf

Department of Energy
Washington, DC 20585
~:- .1- \,/rO¥vi: ,,'::
ZUL I 2a 8: 27
Ms. Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
August 17,2011
Re: Case No. IPC-E-II-08
Dear Ms. Jewell:
Two copies of the United States Department of Energy's fifth requests for information and
production of documents in the above-captioned proceeding are enclosed herewith for filing.
Than you for your kind attention.
Very truly yours,~~-- ..
Arthur Perry Brude~
Attorney for
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
arhur.bruder~hq .doe.gov
phone: [phone]
cell: [phone]
fax: [phone]
RECEIVED
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
f ~11G 29 AM 8= 27
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE TO ITS )
CUSTOMERS IN THE STATE OF IDAHO. )
)
CASE NO. IPC-E-11-08
U.S. DOE's Fifth Interrogatories
and Production Requests
to Idaho Power Company
The United States Deparment of Energy, by and through its attorney of record,
Arthur Perr Bruder, hereby requests that Idaho Power Company ("the Company" or
"Idaho Power") provide the following documents and information as soon as possible,
but no later than MONDAY, AUGUST 22, 2011.
As per the Commission's Rules of Procedure, responses must include the name(s)
and phone number of the person(s) who prepared the document, and the name(s), job
title(s), location(s) and phone number(s) of the record holder(s) and, if different, the
witness( es) who can sponsor the answer at hearing if need be.
These Interrogatories and Production Requests are to be considered as continuing,
and the Company is requested to provide, by way of supplementar responses, additional
documents that it or any person acting on its behalf may later obtain that constitute
relevant augmentation of the documents produced.
Please provide answers to each question, supporting workpapers that provide
detail or are the source of information used in calculations, and the name, job title and
telephone number of the person preparng the documents.
Please provide all Excel and electronic files on CD with formulas activated.
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIFTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-5-1.The Company has provided the parties with various documents that list the
date and time of Idaho Power's system peak. The timing of the system
peak conflcts in several of these documents. Please respond as quickly as
possible to the following clarification questions regarding the timing of
hourly loads and resources shown in documents previously provided by
the Company to the paries.
(a) In response to lIPA No.9, the Company provided the magnitude and
date and time of the system peak for the period Januar 2006 through
May 2011. For example, the Company listed its system peak às 2,215
MW on January 8, 2010 at 8 am, and as 2,914 MW on July 17,2010
at 7 pm. (Both of these times are consistent with the system peaks
reported on page 401b ofIdaho Power Company's 2010 FERC Form
1.) However, in response to DOE l-11(a), the Company provided
information that shows its system peak on Janua 8, 2010 as 2,215
MW at "HR 7", not 8 am. In that same response, the Company shows
its July 17,2010 system peak as 2,914 MW at "HRI8", or 6 pm, not 7
pm. Please reconcile the apparent conflct between the information
provided in response to DOE 1-11(a) and lIPA NO.9.
(b) Please explain how to correctly interpret the times associated with all
hourly information provided in response to DOE 1-11, including
hourly system loads and all hourly sources of supply provided in
Idaho Power's response.
(c) Please explain exactly how Idaho Power accounted for daylight
savings time in the information provided in response to DOE 1-11.
(d) In response to lIPA No.8, the Company provided hourly system loads
and hourly sources of supply for the years 2008 through the present.
The system peak listed in Attachment 3 (cell AF1277) for Januar 8,
2010 is 2,215 MW at "HR7". This conflcts with Idaho Power's
representation in lIPA No.9, where that peak is listed as having
occurred at 8 am. The system peak listed in Attachment 3 (cell
AQ1340) for July 17, 2010 is 2,914 MW at "HRI8", or 6 pm. This
too conflcts with Idaho Power's representation in LIP A NO.9. Please
explain how to correctly interpret the times associated with all
information provided in response to lIPA Nos. 8 and 9.
2
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIFTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(e) In response to DOE 3.4, Idaho Power provided information that shows
that the system load for the first hour of the day on Januar 8, 2010
was 1,706 MW, and that it occured between midnight and 1 am that
morning. However, in response to LIP A No.8, Idaho Power lists a
system load of 1,706 MW occurng in the last hour on Januar 7,
2010, and a load of 1,700 MW occurng in the firs(hour on Januar
8,2010. Please explain the apparent conflct between the information
provided in response to DOE 3.4 and lIPA NO.8.
(f) Please explain exactly how to correctly match the hourly customer
load information Idaho Power provided in response to DOE 3.9 with
hourly system loads provided in response to lIPA No.8 and DOE 1-
11 given the conflct between information presented by Idaho Power
in response to lIPA No. 8 and DOE 1.11 with the information
provided in response to LIP A No.9 and DOE 3.4.
DOE-5-2.In response to DOE 3.9, the Company provided hourly customer load
information for multiple customers. The magnitude of loads shown in
Attachment 4 to that response does not appear to be correct. It is many
times lower than the magnitude of loads shown in other documents,
including Idaho Power's response to lIPA No.3, for example. Please
provide a corrected response to DOE 3.9 Attachment 4, or please reconcile
the information provided with that shown in the Company's response to
lIPA No.3.
DOE-5-3.Please provide corrected responses, if necessar, to any data requests Idaho
Power has responded to in this case involving the dates and times of
system peaks or hourly loads or hourly sources of supply, and please
respond as quickly as possible.
At Washington, D.C., this 1 ih day of August, 2011.
~r3~
Attorney for the United States
Deparment of Energy
Phone: [phone]
Fax: [phone]
Arhur.Bruder~hq.doe.gov
3
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIFTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
CERTIFICATE OF SERVICE
I hereby certify that, this 1 ih day of August, 2011, I served the foregoing fifth production
request of the United States Departent of Energy in Case No. IPC-E-11-08, by:
(1) mailng two (2) copies of it, postage prepaid, to:
Ms. Jean Jewell, Secretar
Idaho Public Utilties Commission
472 West Washington St.
P.O. Box 83720
Boise, ID 83720-0074;
(2) electronically transmitting it as an attachment to an email, to the following persons at
the email addresses shown:
Idaho Power Company (Exh. Nos. 001-100)
Lisa Nordstrom, Gregory Said, Donovan E. Walker, Jason B. Wiliams
1221 W. Idaho St. 83702
PO Box 70
Boise, ID 83707-0070
Inordstrom(fidahopower.com; dwalker~idahopower.com
jwillams(fidahopower.com; gsaid~dahopower.com
Idaho Public Utilties Commission (Exh. Nos. 101-200)
Deputy Attorneys General Donald L. Howell, II, Karl Klein
472 W, Washington (83702)
PO Box 83720
Boise, ID 83720-0074
don.howell(fpuc,idaho.gov; karl.klein~puc.idaho.gov
Idaho Irrigation Pumpers Association (Exh. Nos. 201-300)
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Charered
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
elo~racinelaw.net
4
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIFTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
Anthony Yanel
29814 Lake Road
Bay Vilage, OH 44140
tony~yanel.net
Industrial Customers of Idaho Power (Exh. Nos. 301-400)(Simplot and Rate 19 Group)
Peter J. Richardson, Gregory M. Adams
Richardson & O'Lear, PLLC
515 N. 2ih Street
PO Box 7218
Boise, ID 83702
peter~richardsonandolear.com
greg~richardsonandolear.com
Don Reading
6070 Hil Road
Boise, ID 83703
dreading~mindspring.com
United States Department of Energy (Exh. Nos. 401-500)
Dwight Etheridge
Exeter Associates, Inc.
10480 Little Patuxent Pkwy
Suite 300
Columbia, MD 21044
detheridge(fexeterassociates.com; dgoinsPM G(fverizon.net
Steven A. Porter
Assistat General Counsel
Electricity and Fossil Energy
United State Deparment of Energy
steven.porter~hq.doe.gov
The Kroger Company. (Exh. Nos. 501-600)
Kur J. Boehm
Boehm, Kurz & Lowery
36 E. Seventh St., Suite 1510
Cincinnati, OH 45202
kboehm~bkllawfrr.com
Kevin Higgins
5
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIFTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
Energy Strategies
2155. State St., Suite 200
Salt Lake City, UT 84111
mail:khiggins~energystrat.com
John R. Hamond, Jr.
Batt Fisher Pusch & Alderman, LLP
U.S. Ban Plaza, 5th Floor
1015. Capitol Blvd., Suite 500 (83702)
PO Box 1308
Boise, iD 83701
jrh~battfisher .com
Community Action Partnership Association of Idaho (Exh. Nos. 601-700)
Brad M. Purdy, Attorney at Law
2019 N.l7 St.
Boise, iD 83702
brnpurdy~hotmail.com
Micron Technology Inc. (Exh. Nos. 701-800)
MarV. York
Holland & Har, LLP
101 S. Capital Blvd., Suite 1400
Boise, ID 83702
myork~hollandhart.com
Richard E. Malmgren
Sr. Asst. General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, ID 83716
rernalmgren~micron.com
Thorvald A. Nelson
Mark A. Davidson
Fred Schmidt
Holland & Har, LLP
6380 S. Fiddlers Green Circle
Suite 500
Greenwood Vilage, CO 80111
tnelson(fhollandhar.com; madavidson(fhollandhart.com;
fschmidt(fhollandhar.com; inbuchanan~hollandhart.com
dennytempc!ahoo.com; gccarer~ur-inc.com
6
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIFTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
Idaho Conservation League (Exh. Nos. 801-900)
Benjamin J. Otto
710 N. Sixth Street 83702
PO Box 844
Boise, ID 83701
botto~idahoconservation.org
Snake River Allance (Exh. Nos. 901-1000)
Ken Miler
PO Box 1731
Boise, ID 83701
kmiler~snakeriverallance.org
NW Energy Coalition (Exh. Nos. 1001-1100)
Nancy Hirsh, Policy Direètor
811 1st Ave. Suite 305
Seattle, W A 98104
nancy(fnwenergy.org
~;;~)
Attorney for the United States
Deparment of Energy
Phone: [phone]
Fax: [phone]
Arthur.Bruder(fhg .doe.gov
August 17,2011
7