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Home My WebLink About20110901IPC to Micron 4.1-4.4.pdfLISA D. NORDSTROM Lead Counsel Inordstromtmidahopower.com esIDA~POR~ An 10ACORP Company 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 Fourth Production Request of Micron Technology, Inc., to Idaho Power Company in the above matter. Also enclosed are three (3) copies of a non-confidential disk containing information being produced in response to Micron's Fourth Production Request. Very truly yours, ¿t~ £).'1 ~~ Lisa D. Nordstrom LDN:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, 10 83707 LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER(lSB 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 Inordstrom~idahopower.com dwalker~idahopower.com jwilliamsayidahopower.com D 2011 AUG 31 PH ll: 17 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 FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY ,- COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the Fourth Production Request of Micron Technology, Inc. to Idaho Power Company dated August 10, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 1 REQUEST NO. 4.1: With respect to Ms. Noe's discussion of the changes in the jurisdictional allocation study for firm transfer customers at Page 12, line 3 through Page 14, line 14, please answer the following: a. Provide the monthly coincident peaks and energy loads for the firm transfer customers for the test year, b. Are the firm transfer customers currently paying only OATT transmission charges, or are there additional revenues collected from the firm transfer customers, c. If there are additional charges for the firm transfer customers, provide those revenues monthly for the test year, d. For the test year itemize all components of revenue requirement and rate base that would have been allocated to firm transfer customers under the old jurisdictional allocation method and are not allocated to those customers under the new, proposed jurisdictional allocation method, e. For all revenue collected, or forecast to be collected from firm transfer customers during the test year, provide that revenue monthly broken down by revenue collected through OA TT charges and revenue collected by other charges, and f. For all revenue collected, or forecast to be collected from firm transfer customers during the test year, specify whether that revenue is credited in the new, proposed jurisdictional allocation method and where in the jurisdictional study that revenue is credited. RESPONSE TO REQUEST NO. 4.1 : a. Please see the attached Excel file for the information requested. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 2 b. Firm transfer customers pay charges under Idaho Powets Open Access Transmission Tariff ("OATT") for transmission demand and ancilary services as part of their OA TT network integration transmission service agreement ("NITSA") contract; however, certain NITSA customers who also use the Company's distribution system to take service also pay an additional charge called a "Distribution Facilities Charge," which is included in their NITSA contracts, but is not part of the OATT. c. The "othet' revenue consisting of the "Distribution Facilties Charge" is not forecast on a monthly basis. The annual amount included in the test year is $685,063. d. Please see the attached Excel file for the information requested. e. Revenue forecast to be collected from firm transfer customers during the test year is only forecast on an annual basis. Monthly information is not available. The annual amount included in the test year for revenues collected through OA TT charges is $4,794,188 and the annual amount included for "othet' charges is $685,063. f. Revenue forecast to be collected from the firm transfer customers during the test year is revenue credited to the state jurisdictions in the jurisdictional separation study ("JSS"), Noe Exhibit No. 26, Table 4, line 389. The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 3 REQUEST NO. 4.2: Provide all minutes, materials, presentations, tapes and workpapers used or developed by the FERC and Regional Regulatory Affairs group regarding the proposed change in the jurisdictional cost study for firm transfer customers and/or used to present to the Company' senior management to support the recommended change. RESPONSE TO REQUEST NO. 4.2: The Federal Energy Regulatory Commission and Regional Regulatory Affairs group reviewed the JSS to determine if the model accurately reflected revenues received from firm transfer customers. There were no minutes, recordings, etc., associated with this review. The final decision from senior management was to adjust the JSS methodology to accurately reflect such revenues, which is ultimately what the Company filed. The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 4 REQUEST NO. 4.3: Provide a jurisdictional cost study for the test year using the existing, approved treatment of firm transfer customers. RESPONSE TO REQUEST NO. 4.3: Please see the Company's response to Staffs Production Request No. 140. The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 5 REQUEST NO. 4.4: For each year 2006-2013, inclusive and forecasted as necessary, please identify and describe all transmission interconnection agreements that resulted, or are expected to result, in the construction or expansion of transmission or interconnection facilties. For all such agreements, please also: a. Indicate the total dollar amount paid per year per project, or expected to be paid per year per project, by the entity requesting interconnection with the Company and the total dollar amount paid per year per project, or expected to be paid per year per project, by the Company. b. Identify and describe any generation resource or resources being interconnected to the Company's network through such agreements including a description of the fuel source and total capacity. c. Please identify and quantify all changes in the Company's rate base or expenses reflected in the Company's test period as filed compared to the test period in the Company's last general rate case that are associated with investments or costs incurred to construct new or expanded transmission or interconnection facilties pursuant to transmission interconnection agreements. RESPONSE TO REQUEST NO. 4.4: a. & b. Please see the attached Excel file that provides the information requested. c. The 2008 rate case involved a forecasted test year, which makes it difficult to specifically identify which of these investments were included. As an alternative, the attached Excel file provides actual investment by year that is or wil be included in the Company's plant accounts. Based on an average annual depreciation IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 6 rate of 2 percent for transmission investment, the estimated annual depreciation on these investments will total approximately $1.4 milion once all of the projects are completed and recorded in the Company's plant accounts. The response to this Request was prepared by Tami White, Manager FERC & Regional Affairs, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 31st day of August 2011. oej)~~LISA D. NORD OM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 7 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 FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. 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 Utilties Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Don.Howell(ipuc.idaho.gov KarL. Klein(ipuc. 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 peter(irichardsonandoleary.com greg(irichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email dr(ibenjohnsonassociates.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 elo(iracinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email tony(iyankel.net IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 8 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 kboehm(iBKLlawfirm.com jrh(ibattisher.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email khiggins(ienergystrat.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email myork(ihollandhart.com tnelson(iholland hart. com madavidson(ihollandhart.com fschmidt(ihollandhart.com Inbuchanan(ihollandhart.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email remalmgren(imicron.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Arthur.bruder(ihg.doe.gov Steven.porter(ihg .doe.gov Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email detheridge(iexeterassociates.com IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 9 Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email bmpurdy(ihotmail.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 botto(iidahoconservation.org Snake River Allance Ken Miller Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email kmiller(isnakeriveralliance.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 nancy(inwenergy.org Hoku Materials, Inc. Dean J. Miller McDEVITT & MILLER LLP 420 East Bannock (83702) P.O. Box 2564 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email joe(imcdevitt-miler.com heather(imcdevitt-miller.com Scott Paul, CEO Hoku Materials, Inc. One Hoku Way Pocatello, Idaho 83204 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email spaul(ihokucorp.com £l)~ Lisa D. Nordstro IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 10