20110830IPC to DOE 4.1-4.10.PDF

IHO
PIlIER
An IDACORP Company
!r2O P1 3:6
LISA D.NORDSTROM
Lead Counsel —
lnordstrom(äidahopower.com
August 30,2011
VIA HAND DELIVERY
Jean D.Jewell,Secretary
Idaho Public Utilities 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 U.S.DOE’s Fourth Interrogatories and Production Requests to Idaho
Power Company in the above matter.
Also enclosed are three (3)copies of a confidential disk containing information
being produced in response to the U.S.DOE’s fourth request.
Please handle the enclosed confidential information in accordance with the
Protective Agreement executed in this matter.
Very truly yours,
Lisa D.Nordstrom
LDN:kkt
Enclosures
RO.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 U.S.DOE’S
FOURTH INTERROGATORIES AND
PRODUCTION REQUESTS TO
IDAHO POWER COMPANY
COMES NOW,Idaho Power Company (“Idaho Power”or “Company”),and in
response to the U.S.DOE’s Fourth Interrogatories and Production Requests to Idaho
Power Company dated August 9,2011,herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -1
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REQUEST NO.4-1:Referring to Idaho Power’s response to DOE-i -5(b):
(a)Please provide all studies and analyses conducted by or on behalf of the
Company that empirically demonstrate that the fixed costs of the Company’s thermal
generating plant investments vary with the production of energy from such plants.
(b)Please provide all studies and analyses conducted by or on behalf of the
Company that empirically demonstrate that the fixed costs of the Company’s hydro
generating plant investments vary with the production of energy from such plants.
(b)[sicj Please explain in detail why it is reasonable to assume that the
percentage of Idaho Power’s fixed production plant costs classified as energy-related
changes annually based on changes in Idaho Power’s jurisdictional load factor.
RESPONSE TO REQUEST NO.4-1:
(a)Idaho Power does not claim that the embedded fixed costs of the
Company’s thermal or hydro generating plant investments vary with the production of
energy from such plants and is not in possession of a study that empirically
demonstrates this principle.
(b)Please see the Company’s response to the U.S.Department of Energy’s
(“DOE”)Request No.4-1(a)above.
(b)[sic]Idaho Power does not update its jurisdictional load factor on an
annual basis.At the time of a rate case filing,however,this value is updated to reflect
the Company’s current operating conditions.As described in the Direct Testimony of
Matthew T.Larkin,p.9,II.18-20,in the classification process,“recognition is given to
the way in which the costs are incurred by relating these costs to the way in which the
utility is operated to provide electrical service.”The use of the jurisdictional load factor
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -2
to classify hydro and steam production plant recognizes the way in which these plants
are currently operated to meet customer loads.Failure to update this value at the time
of a general rate filing would result in an outdated allocation basis that potentially does
not reflect current operating conditions.
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 U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -3
REQUEST NO.4-2:In recent class cost-of-service studies filed in rate cases by
Rocky Mountain Power (RMP)before the Idaho Public Utilities Commission (IPUC),
RMP has classified 25 percent of its fixed production plant investment costs as energy-
related costs versus 50-60 percent that Idaho Power classifies as energy-related costs.
The IPUC has approved RMP’s production plant cost classification.
(a)Has Idaho Power conducted any analyses to determine whether it is
reasonable to classify twice as much of the Company’s fixed production plant costs as
energy-related (50-60 percent)compared to RMP’s classification of fixed production
plant costs (25 percent).Please provide any analyses that Idaho Power has conducted.
(b)In the past 3 years,has Idaho Power had any discussions with the
Commission Staff to discuss or review the reasonableness of Idaho Power’s
classification of fixed hydro and thermal plant costs?Please provide the dates of any
such discussions,the names of Idaho Power and Staff participants,and any notes,
emails,reports,or other written documents related to such discussions.
RESPONSE TO REQUEST NO.4-2:
(a)The Company has not performed the analysis described in this Request.
Idaho Power’s use of the 53.88 percent jurisdictional load factor is based on load
characteristics specific to its system;it is the Company’s understanding that the 25
percent energy classification methodology adopted by PacifiCorp was arrived upon
through negotiations as part of the Revised Protocol methodology.As stated by
PacifiCorp’s cost-of-service witness C.Craig Paice,1 the 75/25 classification
methodology was accepted by PacifiCorp because it “falls within the middle range of
1 Utah Public Service Commission,Docket No.07-035-93,Rebuttal Testimony of C.Craig Paice,
p.4,II.87-88.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -4
reasonable approaches.”Because PacifiCorp’s 75/25 classification represents a
negotiated value based on PacifiCorp’s system and a number of different
methodologies,it does not provide a consistent basis for comparison to Idaho Power’s
classification of production plant investment.
(b)The classification methodology used in the Company’s approved
3CP/I2CP class cost-of-service study was thoroughly reviewed by the Idaho Public
Utilities Commission,Staff,and intervening parties in the Company’s last general rate
case,Case No.IPC-E-08-1O.Since that time,the Company has had no further
discussions with Staff regarding the reasonableness of its classification methodology.
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 U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -5
REQUEST NO.4-3:Referring to Idaho Power’s response to DOE-I -7:
(a)Please provide all studies,reports,analyses,or other data and information
that support Idaho Power’s assertion that “[a]s a result of economic dispatch,...hydro
facilities are typically operated on a year-round basis....”
(b)Please provide all studies,reports,analyses,or other data and information
that support Idaho Power’s assertion that “[ajs a result of economic dispatch,...gas-fired
facilities are typically operated only in the high load summer months.”
(c)Please identify and provide Idaho Power’s dispatch protocol or other
written guidelines used to select the dispatch order of its generating fleet and power
Purchases.
RESPONSE TO REQUEST NO.4-3:
(a)Please refer to page 2 of the attached document containing the chart
“Average Monthly MWh Production,2008-2010.”This chart reflects average monthly
megawatt-hour (“MWh”)production by resource type for the years 2008-2010.As
shown by the line labeled “Hydro,”production from this resource type did not drop below
400,000 MWh in any single month,generating more MWh on an annual basis than any
other resource type in the Company’s generation portfolio.
(b)Please refer to page I of the attached document containing the chart
“Average Monthly MWh Production,Gas-Fired Facilities,2008-2010.”This chart
reflects average monthly MWh production for the gas-fired Bennett Mountain and
Danskin facilities for the years 2008-2010.As shown by this chart,the summer month
of August averaged over twice the MWh production of the next highest month of
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -6
September.Four of the five highest months of gas-fired generation fell in the months of
June,July,August,and September.
(c)Idaho Power does not have a dispatch protocol and does not maintain a
document containing “written guidelines used to select the dispatch order of its
generating fleet and power purchases.”Idaho Power operates its resources and enters
into wholesale transactions to serve load in the most compliant,reliable,and prudent
manner possible.
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 U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -7
REQUEST NO.4-4:Referring to Idaho Power’s response to DOE-1-7,the
request did not seek specific hours that were or were not used in the cost study,but
rather witness Larkin’s and Idaho Power’s opinion on what hours would be designated
as “low load or off-peak time period”hours.Please answer the request with this
clarification.
RESPONSE TO REQUEST NO.4-4:As the Company’s cost-of-service witness,
Mr.Larkin does not have an opinion regarding “what hours would be designated as ‘low
load or off-peak time period’hours.”However,for the purposes of valuing demand-side
management programs,Idaho Power does define specific costing periods by hour and
season.These costing periods are provided in the attached document,and are also
included on pages 70 and 71 of Appendix C to the Company’s 2011 Integrated
Resource Plan (“IRP”).It should be noted that these designated time periods were not
used in the preparation of the class cost-of-service study for this filing.The time periods
are identified as follows:
Table Value Costing Period
NSOFP Non-Summer Off-Peak
NSMP Non-Summer Mid-Peak
SOFP Summer Off-Peak
SMP Summer Mid-Peak
SONP Summer On-Peak
The response to this Request was prepared by Matthew T.Larkin,Regulatory
Analyst,Idaho Power Company,in consultation with Lisa D.Nordstrom,Lead Counsel,
Ida ho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -8
REQUEST NO.4-5:Referring to Idaho Power’s response to DOE-1-8,the
request did not seek specific hours that were or were not used in the cost study,but
rather witness Larkin’s and Idaho Power’s opinion on what hours would be designated
as “shoulder hours.”Please answer the request with this clarification.
RESPONSE TO REQUEST NO.4-5:Please see the Company’s response to
the DOE’s Request No.4-4 above.
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 U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -9
REQUEST NO.4-6:Referring to Idaho Power’s response to DOE-1-9,the
request did not seek specific hours that were or were not used in the cost study,but
rather witness Larkin’s and Idaho Power’s opinion on what hours would be designated
as those in which “peak loads...occur during summer afternoons and evenings.”Please
answer the request with this clarification.
RESPONSE TO REQUEST NO.4-6:Please see the Company’s response to
the DOE’s Request No.4-4 above.
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 U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -10
REQUEST NO.4-7:Referring to Idaho Power’s response to DOE-I -1 0:
(a)Please provide all workpapers,studies,analyses,and documents
supporting and/or underlying Idaho Power’s assertion that “[t]he base and intermediate
loads on the Company’s system are typically served by the same generation
resources.”
(b)Please identify the date,hour,and load of the Company’s monthly system
peaks from January 2008 through the current date.
RESPONSE TO REQUEST NO.4-7:
(a)Please refer to page 2 of the attached document containing the chart
“Average Monthly MWh Production,2008-2010,”provided by the Company in its
response to the DOE’s Request No.4-3(a)above.As shown by the line labeled “Coal
and Hydro,”these facilities are operated on a year-round basis at higher levels than any
other generation type in the Company’s resource stack.While the MWh output of
steam and hydro production follows load to an extent,total combined output does not
drop below 1,000,000 MWh in any given month,even during months when the
Company’s system experiences minimum loads.The line on the chart labeled “Natural
Gas”demonstrates the utilization of gas-fired facilities to meet demand during high load
summer months.In non-summer months,average monthly generation from these
facilities drops as low as 4,200 MWh,while the high load summer month of August
shows natural gas production of approximately 79,000 MWh.The shapes provided in
this chart demonstrate that when loads are lower during base and intermediate time
periods,they are served by the same generation resources;i.e.,hydro and steam
production,while gas-fired facilities are used primarily during high load summer months.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -11
(b)Please see the Excel file MonthlySystemPeaks.xlsx provided on the CD
produced by the Company in response to the Idaho Irrigation Pumpers Association,
Inc.’s Data Request No.9.
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 U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -12
REQUEST NO.4-8:Referring to Idaho Power’s response to DOE-i -1 4(c):
(a)The response implies that the listed hydro projects are unable to provide
operating reserves,Is this a correct interpretation of the response?
(b)Regarding the 330 MW of summer 2011 peak load reduction capability
provided by demand response programs,please provide the MW of peak load reduction
capability provided by each available program.
(c)For each supply resource used by Idaho Power to serve retail load,please
identify the position of each resource in the Company’s resource stack.
RESPONSE TO REQUEST NO.4-8:
(a)No.The response does not imply the Brownlee,Oxbow,and Hells
Canyon hydroelectric projects are unable to provide operating reserves.However,at
times when Idaho Power has to rely on the full capacity of these units,they are not able
to provide additional reg-up operating reserves.
(b)For summer 2011,Idaho Power’s 2011 IRP forecast demand response
programs would provide the following amounts of demand reduction:(1)Irrigation Peak
Rewards 250 megawatts (“MW”),(2)FlexPeak Management 35 MW,and (3)AC Cool
Credit 45 MW.
(c)Long-term power purchase agreements that contain “take-or-pay”
provisions are typically dispatched first from the resource stack.Run of river
hydroelectric projects without storage capability are next,followed by hydroelectric
projects with storage capability.In general,the dispatch stack is “stacked”in order of
increasing variable costs of production.Idaho Power’s coal-fired facilities typically
would be in the next group,followed by the Company’s natural gas-fired facilities.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -13
Langley Gulch will be the first natural gas-fired plant to dispatch because of its high
efficiency.The Company’s natural gas-fired peaking resources would come next,and
the Salmon diesel plant would typically be the last of Idaho Power’s Company-owned
generating resources to be dispatched because of its higher cost.
Market purchases are also considered in resource dispatch decisions;however,
where these purchases fall in the stack changes based on the current market price of
energy and whether transmission capacity is available to deliver the energy to load.
Demand response programs are also considered in the resource stack during
periods when the programs are available.Determinations of when to dispatch the
programs are based on forecast load,the availability of other generation resources and
transmission capacity,and any variable cost associated with dispatching the program.
The response to this Request was prepared by M.Mark Stokes,Manager,Power
Supply Planning,Idaho Power Company,in consultation with Lisa D.Nordstrom,Lead
Counsel,Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -14
REQUEST NO.4-9:Referring to Idaho Power’s responses to DOE-1-17(b),1-
18(b),and 1-19(b),are the terms dynamic interchange and static interchange used in
the responses consistent with the NERC National Tagging Standard 1.8 or its
successor.If no,please provide detailed definitions of the terms.
RESPONSE TO REQUEST NO.4-9:The term “dynamic interchange”is
consistent with the term used in the North American Electric Reliability Council
Reliability Standard INT-004-2 and the term “dynamic”as defined in the North American
Energy Standard Board (“NAESB”)Electronic Tagging —Functional Specifications,
Version 1.8.1.
The term “static interchange”is consistent with the term “normal”as defined in
NAESB Electronic Tagging —Functional Specifications,Version 1.8.1.The term “static
interchange”is commonly used in the industry in place of “normal.”
NAESB defines “dynamic”and “normal”as follows:
Dynamic.A dynamic schedule is scheduled using an
expected value but the actual energy transfer is determined
in real time by separate communications external to the e
Tag system.Also included in this type will be regulation
energy schedules and energy imbalance schedules.The e
Tag should contain the expected average energy in the
energy profile and contain the maximum expected energy in
the transmission allocation.Dynamic e-Tags may be
adjusted by the source BA,sink BA,or e-Tag author up to
168 hours in the past using a market adjust to set the actual
interchange value.
Normal.These are the ‘normal energy schedules’and
should be the largest number of schedules.They will
include schedules that use point-to-point,network integrated
transmission service,or grand-fathered service under a
regional tariff.These schedules are included in the IDC and
are subject to TLR curtailment.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIE5 AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -15
The response to this Request was prepared by John Anderson,Power Supply
Operations Manager,Idaho Power Company,in consultation with Lisa D.Nordstrom,
Lead Counsel,Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -16
REQUEST NO.4-10:Referring to Idaho Power’s responses to DOE-I -21:
(a)Please provide in Excel format with working formulas and links intact all
sales and load forecasts for a 12-month period prepared by the Company since August
25,2010.
(b)If the most recent of the forecast provided in response to the previous
subpart was not used as the test-year forecast of customers and kWh sales in the
current rate case,please explain why.
RESPONSE TO REQUEST NO.4-10:
(a)Two updates have been made to the sales and toad forecast since August
25,2010.The first update,finalized on March 3,2011,reflects the removal of a new
large load customer that is no longer expected to take service in the foreseeable future.
The March update also includes an adjustment to expected usage for the Company’s
special contract customer,Hoku Materials,Inc.(“Hoku”),to reflect a revised ramp-up
schedule provided by Hoku representatives.On June 23,2011,a second adjustment
was made to Hoku’s loads to reflect a subsequent revised ramp-up schedule.Updated
loads for the Hoku special contract are provided on the confidential CD.Because this
information is confidential and contains material,non-public information,Idaho Power is
providing this information only to parties that have executed the Protective Agreement in
this mailer.A new sales and load forecast for all other rate classes has not been
prepared since August 25,2010.
(b)As described on pages 3 and 4 of Larkin Exhibit No.27,Hoku loads
included in the Company’s 2011 Test Year reflect normalized annualized usage based
on Hoku’s contract values rather than the estimated ramp-up values from the sales and
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -17
load forecast.The new large load removed as part of the March 3,2011,update was
excluded from the initial 2011 Test Year,so this adjustment had no effect on the sales
and load forecast used in this filing.Sales and load forecast values for all other rate
classes used in the preparation of the 2011 Test Year have not changed since August
25,2010.
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.
DATED at Boise,Idaho,this 30th day of August 2011.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -18
LISA D.
Attorney for Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 30th day of August 2011 I served a true and
correct copy of IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S
FOURTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below,and
addressed to the following:
Commission Staff
____Hand
Delivered
Donald L.Howell,II
____U.S.
Mail
Karl T.Klein
____Overnight
Mail
Deputy Attorneys General
____FAX
Idaho Public Utilities Commission X Email Don.Howe!lcpuc.idaho.cov
472 West Washington (83702)Karl.Kleinpuc.idaho.qov
P.O.Box 83720
Boise,Idaho 83720-0074
Industrial Customers of Idaho Power
____Hand
Delivered
PeterJ.Richardson
____U.S.
Mail
Gregory M.Adams
____Overnight
Mail
RICHARDSON &O’LEARY,PLLC
___FAX
515 North 27th Street (83702)X Email peterrichardsonandoleary.com
P.O.Box 7218 qreqrichardsonandoleary.com
Boise,Idaho 83707
Dr.Don Reading
____Hand
Delivered
Ben Johnson Associates,Inc.
____U.S.
Mail
6070 Hill Road
____Overnight
Mail
Boise,Idaho 83703
____FAX
X Email drcbenjohnsonassociates.com
Idaho Irrigation Pumpers Association,Inc.
____Hand
Delivered
Eric L.Olsen
____U.S.
Mail
RACINE,OLSON,NYE,BUDGE &
___Overnight
Mail
BAILEY,CHARTERED
___FAX
201 East Center X Email eIo(racinelaw.net
P.O.Box 1391
Pocatello,Idaho 83204-1 391
Anthony Yankel
____Hand
Delivered
29814 Lake Road
____U.S.
Mail
Bay Village,Ohio 44140
____Overnight
Mail
___FAX
X Email tony(äyankeLnet
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -19
The Kroger Co.
____Hand
Delivered
Kurt J.Boehm
____U.S.
Mail
BOEHM,KURTZ &LOWRY
___Overnight
Mail
36 East Seventh Street,Suite 1510
____FAX
Cincinnati,Ohio 45202 X Email kboehm(BKLIawfirm.com
irhbattfisher.com
Kevin Higgins
____
Hand Delivered
Energy Strategies,LLC
____U.S.
Mail
215 South State Street,Suite 200
____Overnight
Mail
Salt Lake City,Utah 84111
____FAX
X Email khiins(2enerystrat.com
Micron Technology,Inc.
____Hand
Delivered
Mary V.York
___U.S.
Mail
HOLLAND &HART LLP
___Overnight
Mail
101 South Capital Boulevard,Suite 1400
____FAX
Boise,Idaho 83702 X Email myork(U2hollandhart.com
tneIson(hollandhart.com
madavidsonhollandhart.com
fschmidthollandhart.com
lnbuchananhoIIandhart.com
Richard E.Malmgren
____Hand
Delivered
Senior Assistant General Counsel
____U.S.
Mail
Micron Technology,Inc.
____Overnight
Mail
800 South Federal Way
____FAX
Boise,Idaho 83716 X Email remaImqren(micron.com
The United States Department of Energy
____Hand
Delivered
Arthur Perry Bruder,Attorney-Advisor
____U.S.
Mail
United States Department of Energy
____Overnight
Mail
1000 Independence Avenue SW
____FAX
Washington,DC 20585 X Email Arthur.bruderc2hg.doe.qov
Steven.porter(hg.doe.ciov
Dwight D.Etheridge
____Hand
Delivered
Exeter Associates,Inc.
____U.S.
Mail
10480 Little Patuxent Parkway,Suite 300
____Overnight
Mail
Columbia,Maryland 21044
____FAX
X Email detheridge(exeterassociates.com
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -20
Community Action Partnership
____Hand
Delivered
Association of Idaho U.S.Mail
Brad M.Purdy
____Overnight
Mail
Attorney at Law
____FAX
2019 North 17th Street X Email bmpurdyhotmaiI.com
Boise,Idaho 83702
Idaho Conservation League
____Hand
Delivered
Benjamin J.Otto
____U.S.
Mail
Idaho Conservation League
____Overnight
Mail
710 North Sixth Street (83702)
____FAX
P.O.Box 844 X Email boffo(idahoconservation.org
Boise,Idaho 83701
Snake River Alliance
____Hand
Delivered
Ken Miller
____U.S.
Mail
Snake River Alliance
____Overnight
Mail
P.O.Box1731
___FAX
Boise,Idaho 83701 X Email kmiIIer(äsnakeriveraIIiance.orcj
NW Energy Coalition
____Hand
Delivered
Nancy Hirsh,Policy Director
____U.S.
Mail
NW Energy Coalition
____Overnight
Mail
811 FirstAvenue,Suite 305
___FAX
Seattle,Washington 98104 X Email nancy(änwenerqy.org
Hoku Materials,Inc.
____Hand
Delivered
Dean J.Miller
____U.S.
Mail
McDEVITT &MILLER LLP
____Overnight
Mail
420 East Bannock (83702)
____FAX
P.O.Box 2564 X Email joe(mcdevitt-miIler.com
Boise,Idaho 83701 heathercmcdevitt-miller.com
Scott Paul,CEO
____Hand
Delivered
Hoku Materials,Inc.
____U.S.
Mail
One Hoku Way
____Overnight
Mail
Pocatello,Idaho 83204
____FAX
X Email spauIchokucorp.com
Lisa D.Nordstr
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S FOURTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -21
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E-11-08
IDAHO POWER COMPANY
RESPONSE TO DOE’S REQUEST NO.4-3
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Demand-Side Resource Data Idaho Power Company
Table DSM-3.DSM alternate cost summer pricing periods (June 1—August 31)
Hour Sunday Monday Tuesday Wednesday Thursday Friday Saturday Holiday
1 SOFP 80FF 80FF 80FF 80FF SOFP 80FF 80FF
2 SOFF 50FF 80FF 80FF 50FF 80FF 80FF SOFP
3 50FF SOFP SOFP 80FF SOFP SOFP 50FF 80FF
4 80FF 80FF 80FF 80FF 80FF 80FF 80FF 80FF
5 80FF 80FF 80FF SOFP 80FF 50FF SOFP SOFP
6 80FF 50FF 50FF 80FF 80FF SOFP SOEP 80FF
7 SMP SMP SMP S1F SPF SMP SMP SMP
8 SMP St4’SMP S1F SMP SMP SMP SMP
9 SMP SMP SMP SMP SMP SMP SMP SMP
10 SMP St SMP SMP S SMP SP*’SMP
11 SMP SMP SMP SMP SMP SMP SMP SMP
12 SMP -SMP SMP SMP SMP SMP StvF SMP
13 SMP SONP SONP SONP SONF SONP ,StvW
14 SMP SONP SONP SONP SONP SONP SMP SMP
15 S SQNP SONP SONP S0NP SONP SMP StvU
16 S SQNP SONP SONP SONP SONP St8’SMP
17 SM’SONP SONP SONF SONP SONP SM’SMP
18 SMP SONF SONF SONP SONP SONF SM’SMP
19 SM’SONP SONP SONP SONP SONP SMP SMP
20 SMP SONP SONP SONP SONP SONP SMP SMP
21 SMP SMP SMP SM’SMP SMP SM’SMP
22 :SMP SMP SMP SMP SMP SMP SM’SM’
23 80FF 80FF SOFP 80FF 50FF SOFP SOFP 80FF
24 SOFP 80FF 50FF 50FF 80FF SOFP SOFP 809’
Page 70 2011 Integrated Resource Plan—Appendix C
idaho Power Company Demand-Side Resource Data
Table DSM-4.DSM alternate cost non-summer pncing periods (September 1-May31)
Monday Tuesday Wednesday Thursday
2011 Integrated Resource Plan—Appendix C Page 71