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Home My WebLink About20110829DOE to IPC 6.1-6.6.pdfDepartment of Energy Washington, DC 20585 F~E(~El 'in! I t\lj~ 2ri a'i.,d 8= 24"',' hwll :: £, I j/" '~¡i,.. Ms. Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 August 22, 2011 Re:Case No. IPC-E-ll-08 Dear Ms. Jewell: Two copies of the United States Deparment of Energy's sixth 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,~~,.~ .. Arhur Perr B~er Attorney for United States Deparment of Energy 1000 Independence Avenue SW Washington, DC 20585 arhur.bruderêhq.doe.gov phone: (202) 586-3409 cell: (202) 329-4966 fax: (202) 586-7479 f1F-i~t"Jt ¡.r~l". "., ~.. '.' .... ! )\¡¡,..i¡;..i it ~'h_ BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION 201 I AUG 29 AM 8: 21+ 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. ) ) lDll.r~C) UTILITIES CASE NO. IPC-E-ll-08 U.S. DOE's Sixth 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, SEPTEMBER 12,2011. 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 preparing the documents. Please provide all Excel and electronic fies on CD with formulas activated. IDAHO POWER COMPANY CASE No. IPC-E-ll-08 DOE's SIXTII REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS DOE-6-1. DOE-6-2. Idaho Power charges Idaho National Laboratory a monthly "Use of Facilties" charge. Please respond to the following regarding that Use of Facilties charge. (a) When did Idaho Power first assess that charge to Idaho National Laboratory? (b) What services does Idaho National Laboratory receive for that charge? (c) How was that charge originally calculated? Please provide those calculations. Please also provide an explanation for each step performed in those calculations. (d) Please provide a reference to each location within Idaho Power's class cost of service study in this proceeding where the revenues from that charge are directly or indirectly addressed. For each referenced location, explain how the revenues from that charge were addressed. (e) Please provide a reference to any Idaho Power testimony, exhibits, or workpapers in this proceeding where the revenues from that charge are directly or indirectly addressed. For each referenced location, explain how the revenues from that charge were addressed. (f) Is Idaho Power proposing a change in that charge as part of this proceeding? If so, what is the amount of the monthly Use of Facilities charge that Idaho Power is proposing for Idaho National Laboratory, and provide the documentation showing how that charge was calculated? Idaho Power peri9dically charges Idaho National Laboratory for operations and maintenance ("O&M") expenses associated with the Antelope Substation. Please respond to the following regarding those O&M charges. (a) When did Idaho Power first assess those charges to Idaho National Laboratory? (b) What services does Idaho National Laboratory receive for those charges? (c) How are those charges calculated? Please provide those calculations for the period 2008 through the present. Please also provide an explanation for each step performed in those calculations. (d) Please provide a reference to each location within Idaho Power's class cost of service study in this proceeding where the revenues from those charges are directly or indirectly addressed. For each referenced location, explain how the revenues from those charges were addressed. 2 IDAHO POWER COMPANY CASE No. IPC-E-ll-08 DOE's SIXTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS DOE-6-3. DOE-6-4. (e) Please provide a reference to any Idaho Power testimony, exhibits, or workpapers in this proceeding where the revenues from those charges are directly or indirectly addressed. For each referenced location, explain how the revenues from those charges were addressed. (f) Is Idaho Power proposing a change in those charges as par of this proceeding? If so, please explain how those charges will be calculated prospectively. Idaho Power charges Mountain Home Air Force Base a montWy "Facilities Charge." Please respond to the following regarding that charge. (a) When did Idaho Power first assess that charge to Mountain Home Air Force Base? (b) What services does Mountain Home Air Force Base receive for that charge? (c) How was that charge originally calculated? Please provide those calculations. Please also provide an explanation for each step performed in those calculations. (d) Please provide a reference to each location within Idaho Power's class cost of service study in this proceeding where the revenues from that charge are directly or indirectly addressed. For each referenced location, explain how the revenues from that charge were addressed. (e) Please provide a reference to any Idaho Power testimony, exhibits, or workpapers in this proceeding where the revenues from that charge are directly or indirectly addressed. For each referenced location, explain how the revenues from that charge were addressed. (f) Is Idaho Power proposing a change in that charge as par of this proceeding? If so, what is the amount of the monthly Facilities Charge that Idaho Power is proposing for Mountain Home Air Force Base, and provide the documentation showing how that charge was calculated? Idaho Power lists projected monthly 2011 test year biling determinants for DOE's Idaho National Laboratory in M. Larkin's Exhibit No. 29 workpapers. Please provide the historical data and calculations used by Idaho Power to develop the monthly biling demands for Idaho National Laboratory that sum to 398,604 kilowatts for the test year. Please explain Idaho Power's rationale for utilzing the calculations it used to develop those projected monthly biling demands. 3 IDAHO POWER COMPANY CASE No. IPC-E-ll-08 DOE's SIXTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Please provide all available 30- and 15-minute usage information in Excel format that Idaho Power has collected for DOE's Idaho National Laboratory for the period Januar 1, 2010 through the present. Please explain how the dates and times provided in response to this request correspond to Idaho Power's reported monthly system peaks. This is an ongoing data request. Please describe in detail any peak reduction programs Idaho Power and DOE have agreed to with regard to Idaho National Laboratory. Please provide estimated hourly load reductions associated with these programs and the compensation DOE received for paricipating in these programs for the period January 2008 through the present. DOE-6-5. DOE-6-6. At Washington, D.C., this 22ud day of August, 2011. Arur Perry Bruder Attorney for the United States Deparment of Energy Phone: (202) 586-3409 Fax: (202) 586-4116 Arthur.Bruderêhq.doe.gov 4 IDAHO POWER COMPANY CASE No. IPC-E-ll-08 DOE's SIXTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS CERTIFICATE OF SERVICE I hereby certify that, this 22ud day of August, 2011, I served the foregoing sixth production request of the United States Deparment of Energy in Case No. IPC-E-II-08, by: (l) mailng two (2) copies of it, postage prepaid, to: Ms. Jean Jewell, Secretary Idaho Public Utilties Commission 472 West Washington St. P.O. Box 83720 Boise, ID 83720-0074; (2) electronically transmitting it as an attchment 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 83 707-0070 Lnordstronrgidahopower.com; dwalkerêidahopower.com jwiliarmsrgidahopower .com; gsaidêidahopower .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.howellrgpuc,idaho. gov; karl.k1einêpuc.idaho .gov Idaho Irrigation Pumpers Association (Exh. Nos. 201-300) Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chartered 201 E. Center PO Box 1391 Pocatello, ID 83204-1391 eloêracinelaw.net Anthony Yanel 29814 Lake Road Bay Vilage, OH 44140 tonyêyanel.net 5 IDAHO POWER COMPANY CASE No. IPC-E-ll-08 DOE's SIXTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS 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. 27th Street PO Box 7218 Boise, ID 83702 peterêrichardsonandolear .com gregêrichardsonandoleary.com Don Reading 6070 Hil Road Boise, ID 83703 dreadingêmindspring.com United States Department of Energy (Exh. Nos. 401-500) Dwight Etheridge Exeter Associates, Inc. 10480 Little Patuxent Pkw Suite 300 Columbia, MD 21044 detheridgergexeterassociates.com; dgoinsPMGrgverizon.net Steven A. Porter Assistat General Counsel Electricity and Fossil Energy United State Deparment of Energy steven. porterêhq .doe.gov The Kroger Company. (Exh. Nos. 501-600) Kur J. Boehm Boehm, Kurz & Lowery 36 E. Seventh St., Suite 1510 Cincinnati, OH 45202 kboehrêbkllawfrr.com Kevin Higgins Energy Strategies 2155. State St., Suite 200 Salt Lake City, UT 84111 mail:khgginsêenergystrat.com 6 IDAHO POWER COMPANY CASE No. IPC-E-ll-08 DOE's SIXTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS 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 jrhêbattfisher.com Community Action Partnership Association of Idaho (Exh. Nos. 601-700) Brad M. Purdy, Attorney at Law 2019N.l7 St. Boise, ID 83702 brnpurdyêhotmail.com Micron Technology Inc. (Exh. Nos. 701-800) Richard E. Malmgren Sr. Asst. General Counsel Micron Technology, Inc. 800 South Federal Way Boise, ID 83716 remalmgrenêmicron.com Thorvald A. Nelson Mark A. Davidson Fred Schmidt Holland & Har, LLP 6380 S. Fiddlers Green Circle Suite 500 Greenwood Vilage, CO 80111 tnelsonrghollandhar.com; madavidsonrghollandhar.com; fschmidtrghollandhart.com; lnbuchananêhollandhar.com dennytemprgyahoo.com; gccarerrgur- inc.com Idaho Conservation League (Exh. Nos. 801-900) Benjamin J. Otto 710 N. Sixth Street 83702 PO Box 844 Boise, ID 83701 bottoêidahoconservation.org 7 IDAHO POWER COMPANY CASE No. IPC-E-ll-08 DOE's SIXTH REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS Snake River Allance (Exh. Nos. 901-1000) Ken Miler PO Box 1731 Boise, ID 83701 kmilerêsnakeriverallance.org NW Energy Coalition (Exh. Nos. 1001-1100) Nancy Hirsh, Policy Director 811 1st Ave. Suite 305 Seattle, WA 98104 nancyrgnwenergy.org CQ R ~-=r~ Arhur Perr Brud Attorney for the United States Department of Energy Phone: (202) 586-3409 Fax: (202) 586-4116 Arthur.Bruderrghq.doe. gov August 22, 2011 8