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Home My WebLink About20110901IPC to DOE 5.1-5.3.pdfREf"!=I\li:r¡f .... \,1 \\ t't :;.~. t~.. isIDA~POR~ An IDACORP Company JASON B. WILLIAMS Corporate Counsel iwilliamscæidahopower.com August 31, 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 Fifth Interrogatories and Production Requests to Idaho Power Company in the above matter.\ Very truly yours,~ø~ ~~s~n B. Willams ;- JBW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 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: (208) 388-5825 Facsimile: (208) 388-6936 Inordstromcæidahopower.com dwalkercæidahopower.com jwilliamscæidahopower.com RECEI 0 1011 AUG 31 PM 4: 15 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 FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the U.S. Department of Energy's ("DOE") Fifth Interrogatories and Production Requests to Idaho Power Company dated August 17, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST NO. 5-1: The Company has provided the parties with various documents that list the date and time of Idaho Powets system peak. The timing of the system peak conflicts 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 parties. (a) In response to IIPA No.9, the Company provided the magnitude and date and time of the system peak for the period January 2006 through May 2011. For example, the Company listed its system peak as 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 401 b of Idaho Power Company's 2010 FERC Form 1.) However, in response to DOE 1-11(a), the Company provided information that shows its system peak on January 8, 2010 as 2,215 MW at "HR7", not 8 am. In that same response, the Company shows its July 17, 2010 system peak as 2,914 MW at "HR18", or 6 pm, not 7 pm. Please reconcile the apparent conflict between the information provided in response to DOE 1-11 (a) and IIPA 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 IIPA 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 January 8, 2010 is 2,215 MW at "HR7". This conflicts with Idaho Powets representation in IIPA No.9, where that peak is listed as having occurred at 8 am. The system peak listed in Attachment 3 (cell AQ1340) for July IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 2 17, 2010 is 2,914 MW at "HR18", or 6 pm. This too conflicts with Idaho Powets representation in IIPA No.9. Please explain how to correctly interpret the times associated with all information provided in response to IIPA Nos. 8 and 9. (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 January 8, 2010 was 1,706 MW, and that it occurred between midnight and 1 am that morning. However, in response to IIPA No. 8, Idaho Power lists a system load of 1,706 MW occurring in the last hour on January 7, 2010, and a load of 1,700 MW occurring in the first hour on January 8, 2010. Please explain the apparent conflict between the information provided in response to DOE 3.4 and IIPA 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 IIPA No.8 and DOE 1-11 given the conflict between information presented by Idaho Power in response to IIPA No.8 and DOE 1.11 with the information provided in response to IIPA No.9 and DOE 3.4. RESPONSE TO REQUEST NO. 5-1: This Request was resolved through a telephone conversation with the U.S. Department of Energy's ("DOE") consultant Mr. Dwight Etheridge on August 29,2011. During this conversation, Idaho Power explained that the perceived discrepancies in data provided by the Company were caused by the use of Pacific Prevailng Time for various reporting purposes and Mountain Prevailng Time for load research purposes. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST NO. 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 IIPA 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 IIPA No.3. RESPONSE TO REQUEST NO. 5-2: This Request was resolved through a telephone conversation with the DOE's consultant Mr. Dwight Etheridge on August 29, 2011. Also, please see the Company's response to Micron Technology, Inc.'s Request No. 5-1. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 4 REQUEST NO. 5-3: Please provide corrected responses, if necessary, 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. RESPONSE TO REQUEST NO. 5-3: Please see the Company's response to the DOE's Request No. 5-1. To the Company's knowledge, all data regarding system peaks, hourly loads, and hourly sources of supply provided to date is accurate and without error. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. DATED at Boise, Idaho, this 31st day of August 2011. "'~¿;C?ç a- N B. WILLIAMS Attorney for Idaho Power Company " ( IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 31st day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH 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 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 Hand Delivered U.S. Mail _ Overnight Mail 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 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email petercærichardsonandolearv.com gregcærichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hill Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email drcæbenjohnsonassociates.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 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email elocæracinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email tonycæyankel.net IDAHO POWER COMPANY'S RESPONSE TO THE u.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 6 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 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email kboehmcæBKLlawfrm.com jrhcæbattisher.com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email khigginscæenergystrat.com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email myorkcæhollandhart.com tnelsoncæhollandhart.com madavidsoncæhollandhart.com fschmidtcæhollandhart.com Inbuchanancæhollandhart.com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email remalmgrencæmicron.com Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email Arthur.brudercæhq.doe.gov Steven. portercæhq.doe.gov Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email detheridgeayexeterassociates.com IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 7 Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email bmpurdyayhotmail.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 bottoayidahoconservation.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 kmileraysnakeriveralliance.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 nancyaynwenergy.org Hoku Materials, Inc. Dean J. Miler McDEVITT & MILLER LLP 420 East Bannock (83702) P.O. Box 2564 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email joeaymcdevitt-miler.com heatheraymcdevitt-miller.com Scott Paul, CEO Hoku Materials, Inc. One Hoku Way Pocatello, Idaho 83204 Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email spauiayhokucorp.com IDAHO POWER COMPANY'S RESPONSE TO THE U.S. DOE'S FIFTH INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 8