20110912IPC to DOE 6.1-6.6.pdf

HOPIVER®
An IDACORP Company
21SEP 12 F1 Lt:35
JASON B WILLIAMS -
Corporate Counsel —LL .
jwiIIiamsidahopower.com
September 12,2011
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 Sixth Interrogatories and Production Requests to Idaho
Power Company in the above matter.
Also enclosed are three (3)copies of a non-confidential disk and three (3)copies of
a confidential disk containing information being produced in response to the U.S.DOE’s
sixth request.
Please handle the enclosed confidential information in accordance with the
Protective Agreement executed in this matter.
Very truly yours,
son B.Williams
JBW:kkt
Enclosures
1221 W.Idaho St.(83702)
RO.Box 70
Boise,ID 83707
F.E CE tLISAD.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]
lnordstromidahopower.com
dwalkeridahopower.com
211s:?12 P1 L1:35
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jwiIIiams(idahopower.com
Afforneys 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.
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)
)
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CASE NO.IPC-E-11-08
IDAHO POWER COMPANY’S
RESPONSE TO THE U.S.DOE’S
SIXTH INTERROGATORIES AND
PRODUCTION REQUESTS TO
IDAHO POWER COMPANY
COMES NOW,Idaho Power Company (“Idaho Power”or “Company”),and in
response to the U.S.Department of Energy’s Sixth Interrogatories and Production
Requests to Idaho Power Company dated August 22,2011,herewith submits the
following information:
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -1
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REQUEST NO.6-1:Idaho Power charges Idaho National Laboratory a monthly
“Use of Facilities”charge.Please respond to the following regarding that Use of
Facilities 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?
RESPONSE TO REQUEST NO.6-1:
(a)Idaho Power first assessed the “Use of Facilities”charge to the Idaho
National Laboratory (“INL”)IU.S.Department of Energy (“DOE”)in November of 1989
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -2
under the provisions of the Antelope Substation Capacity Entitlement,Operations and
Maintenance Agreement dated October 17,1989.
(b)INL receives the right to receive the benefit related to the facilities located
in the Antelope substation which are needed to provide electric service to INL.
(c)Idaho Power uses PacifiCorp facilities in the Antelope substation to serve
INL and incurs a use of facilities charge payable to PacifiCorp in the amount of $6,152.
PacifiCorp uses INL/DOE-owned facilities that are located in the Antelope substation
and incurs a use of facilities charge in the amount of $4,843.Each month PacifiCorp
invoices Idaho Power for the difference between the amount Idaho Power owes
PacifiCorp and the amount that PacifiCorp owes INL/DOE.Idaho Power then pays the
net amount of this charge ($1 ,309)to PacifiCorp and invoices INL/DOE for the same
amount.
(d)Idaho Power’s class cost-of-service study addresses the “Use of Facilities”
charge revenues in Account 456 under “Other Operating Revenues.”The first step in
crediting “Other Operating Revenues”to customer groups is to classify and functionalize
each subaccount.As shown on lines 289-298 of Larkin Exhibit No.31,each
subaccount that comprises Account 456 is classified as being either customer-related,
demand-related,or energy-related,and further identified with one or more of the
Company’s operating functions,such as production and/or transmission.Once each
subaccount has been classified and functionalized as shown in Larkin Exhibit No.31,
the segmented revenues are transferred to the “Other Revenues”summary table,
provided as page 3 of Larkin Exhibit No.32.This table compiles revenues from
Accounts 415,451,454,and 456 by classification and functional category in order to
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -3
align the various components of each account with the appropriate allocation factors.
After these revenues have been compiled by classification and functional category,they
are allocated to rate classes as shown on pages 25 and 26 of Larkin Exhibit No.33.
Finally,class-allocated revenues are summed on line 18 of Larkin Exhibit No.35,
serving as a credit to each class in the development of final class-specific revenue
requirements.
(e)Please see the Company’s response to (d)above.
(f)No.
The response to this Request was prepared by Scott D.Sparks,Senior
Regulatory Analyst,Idaho Power Company,in consultation with Jason B.Williams,
Corporate Counsel,Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -4
REQUEST NO.6-2:Idaho Power periodically 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.
(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 part of this
proceeding?If so,please explain how those charges will be calculated prospectively.
RESPONSE TO REQUEST NO.6-2:
(a)Idaho Power first assessed the O&M charges associated with the
Antelope substation in December 2005.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -5
(b)The O&M services provided to INL are for INL-owned equipment located
inside PacifiCorp’s Antelope substation.The operation and maintenance of this
equipment is performed by Idaho Power and includes inspections,preventive
maintenance,and corrective maintenance on relays,transformers,breakers,etc.
(c)The charges are calculated using the Company’s current year’s billing rate
for each charge to the respective work order in the quarter being billed.Labor is billed
at 2.5 times the current wages for senior technicians/line workers and is applied to the
actual hours of the work performed.Vehicle rates,meals,and lodging are billed at 1.3
times the actual cost.Materials from Idaho Power’s inventory are billed at the unit price
plus the following overheads for each year:2008 —29.5 percent,2009 and 2010 —31
percent,and 2011 —29.3 percent.Materials purchased directly from a vendor are billed
at the actual cost plus 10 percent.Please see the Excel file on the non-confidential CD
for calculations of charges for the period 2008 through present.
(d)Idaho Power’s class cost-of-service study addresses operations and
maintenance expenses associated with the Antelope substation revenues in Account
415 under “Other Operating Revenues.”The first step in crediting “Other Operating
Revenues”to customer groups is to classify and functionalize each subaccount.As
shown on line 273 of Larkin Exhibit No.31,Account 415 is classified as being either
customer-related,demand-related,or energy-related,and further identified with one or
more of the Company’s operating functions,such as production and/or transmission.
Once each subaccount has been classified and functionalized as shown in Larkin
Exhibit No.31,the segmented revenues are transferred to the “Other Revenues”
summary table,provided as page 3 of Larkin Exhibit No.32.This table compiles
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -6
revenues from Accounts 415,451,454,and 456 by classification and functional
category in order to align the various components of each account with the appropriate
allocation factors.After these revenues have been compiled by classification and
functional category,they are allocated to rate classes as shown on pages 25 and 26 of
Larkin Exhibit No.33.Finally,class-allocated revenues are summed on line 18 of
Larkin Exhibit No.35,serving as a credit to each class in the development of final class-
specific revenue requirements.
(e)Please see the Company’s response to (d)above.
(f)No.
The response to this Request was prepared by Scott D.Sparks,Senior
Regulatory Analyst,Idaho Power Company,in consultation with Jason B.Williams,
Corporate Counsel,Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -7
REQUEST NO.6-3:Idaho Power charges Mountain Home Air Force Base a
monthly “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 part 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 COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -8
RESPONSE TO REQUEST NO.6-3:
(a)Idaho Power first assessed the monthly facilities charge to Mountain
Home Air Force Base in January 1976.
(b)Under the facilities charge provisions outlined in the Company’s tariff,
Idaho Power designs,installs,owns,operates,and maintains customer-dedicated
facilities installed beyond the Company’s point of delivery.The Company also provides
readily available utility grade equipment inventories,tools,manpower,response
services,and electrical knowledge and experience.
(c)Please see the Company’s response to the Industrial Customer’s of Idaho
Power’s (“ICIP”)Request for Production No.5.
(d)Idaho Power’s class cost-of-service study addresses facilities charge
revenues in Account 454 under “Other Operating Revenues.”The first step in crediting
“Other Operating Revenues”to customer groups is to classify and functionalize each
subaccount.As shown on lines 277-287 of Larkin Exhibit No.31,each subaccount that
comprises Account 454 is classified as being either customer-related,demand-related,
or energy-related,and further identified with one or more of the Company’s operating
functions,such as production and/or transmission.Once each subaccount has been
classified and functionalized as shown in Larkin Exhibit No.31,the segmented
revenues are transferred to the “Other Revenues”summary table,provided as page 3 of
Larkin Exhibit No.32.This table compiles revenues from Accounts 415,451,454,and
456 by classification and functional category in order to align the various components of
each account with the appropriate allocation factors.After these revenues have been
compiled by classification and functional category,they are allocated to rate classes as
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -9
shown on pages 25 and 26 of Larkin Exhibit No.33.Finally,class-allocated revenues
are summed on line 18 of Larkin Exhibit No.35,serving as a credit to each class in the
development of final class-specific revenue requirements.
(e)In addition to the references described above,the following references
address facilities charge revenues in this proceeding:Scott D.Sparks’direct testimony
discusses the proposed updates to facilities charges and the impact on revenues
generated from facilities charges on pages 34-41;page 5,lines 6-13 of Douglas N.
Jones’direct testimony discusses an adjustment to “Other Operating Revenues”and
line 9 of Jones Exhibit No.14 shows the adjustment to facilities charges;page 4 of
Tatum Exhibit No.20 discusses the Company’s proposed update to the facilities charge
rates and the resulting decrease in revenues generated from facilities charges;line 285
of Larkin Exhibit No.31 shows the functionalization and classification of facilities charge
revenues;and line 177 of Larkin Exhibit No.32 shows where the segmented revenues
from Larkin Exhibit No.31 are transferred to “Other Revenues”in the Summary of
Functionalize Costs table.
(f)Idaho Power is proposing to update the monthly facilities charge rate for
Schedules 9,19,and 24 from 1.7 percent to 1.41 percent.If approved,the proposed
monthly facilities charge for Mountain Home Air Force Base (Schedule 19)will equal
1.41 percent times the Company’s investment in facilities installed beyond the
Company’s point of delivery at Mountain Home Air Force Base.See the Company’s
response to ICIP’s Request for Production No.4 for documentation showing how the
1.41 percent was calculated.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -10
The response to this Request was prepared by Scott D.Sparks,Senior
Regulatory Analyst,Idaho Power Company,in consultation with Jason B.Williams,
Corporate Counsel,Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -11
REQUEST NO.6-4:Idaho Power lists projected monthly 2011 test year billing
determinants for DOE’s Idaho National Laboratory in Larkin’s Exhibit No.29
workpapers.Please provide the historical data and calculations used by Idaho Power to
develop the monthly billing demands for Idaho National Laboratory that sum to 398,604
kilowatts for the test year.Please explain Idaho Power’s rationale for utilizing the
calculations it used to develop those projected monthly billing demands.
RESPONSE TO REQUEST NO.6-4:The monthly billing demands for INL are
forecast via 12 individual regression equations,one equation for each month of the
year.The dependent variable in these equations is monthly peak demand.INL monthly
peak demand (measured in megawatts(”MW”))is assumed to be a function of monthly
INL electricity sales (independent or explanatory variable)measured in average MW.
Dummy variables are used in a number of the monthly regression models to help
explain changes in the relationship between billing demand and the key explanatory
variable,average load over time.
Please see the Excel files provided on the confidential CD containing the
modeling variables,associated coefficients,and statistical results of the regression
analyses for each monthly regression model.The confidential CD will be provided to
those parties that have executed the Protective Agreement in this matter.The following
table describes the information contained in each of these workbooks:
Tab Name Description
Data Historical/forecast data by variable
Corr Correlation between variables
Coef Coefficients and associated descriptive statistics for each variable
MStat Descriptive statistics for entire model
Elas Elasticity statistics of each explanatory variable
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -12
The Excel file Summary.xlsx combines the estimated coefficients from the 12
monthly regression models with the INL sales forecast for 2011.The equations result in
an estimation of monthly INL billing demand in MW for the test year.This Excel file is
also confidential and will be provided to those parties that have executed the Protective
Agreement in this matter.
As demonstrated by the descriptive statistics in the Excel files provided on the
confidential CD,average loads have proven to be statistically significant with respect to
corresponding billing demands.The regression analysis provided in this response
represents the Company’s best estimate of future loads at the INL service point based
on historical behavior and future expectations.
The response to this Request was prepared by Matthew T.Larkin,Regulatory
Analyst,Idaho Power Company,in consultation with Jason B.Williams,Corporate
Counsel,Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -13
REQUEST NO.6-5: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 January 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.
RESPONSE TO REQUEST NO.6-5:Idaho Power identifies monthly system
peaks based on hourly system load values.Load Research uses and maintains interval
data at the same granularity,aggregated at the hourly level.In the instance when
interval data for a customer is at a lower granularity than hourly,the 30-and/or 15-
minute usage are used to calculate the aggregated hourly level usage which was used
in the analysis.
The requested 30-and 15-minute data is contained in files INL_2010.xlsx and
INL_2011_JanToJun.xlsx which are provided on the confidential CD.The confidential
CD will be provided to those parties that have executed the Protective Agreement in this
matter.Dates and times in the sub-hourly extract files are shown as extracted,without
“/“or “:“in the formats,and with the time at the specified interval (military time).The
dates and times provided correspond to reported monthly system peaks through
aggregation of the intervals to the hour.
For example,the reported monthly system peak in July of 2010 was on July 17,
2010,for the hour ending 7:00 p.m.In the 2010 Excel data file,the July monthly tab
titled “Jul 2010,”on the date listed “71710,”the intervals “1830”and “1900”can be
averaged to obtain the hourly demand at the system peak for this customer.Those two
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -14
REQUEST NO.6-6: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 participating in these programs for the period January
2008 through the present.
RESPONSE TO REQUEST NO.6-6:Idaho Power does not have any
agreements with INL regarding its peak reduction programs.Idaho Power offers the
FlexPeak Management program under contract with EnerNOC,Inc.,(“EnerNOC”)a
demand response aggregator.FlexPeak Management is a demand response program
offered through EnerNOC to large commercial and industrial customers.FlexPeak
Management was first offered in 2009 and reduced Idaho Power’s peak load by 19.3
MW and 47.5 MW in 2009 and 2010,respectively.The demand reduction for 2011 is
not yet finalized and will be available after Idaho Power and EnerNOC reconcile the
reduction amounts by year-end 2011.INL participated in FlexPeak Management in
2010 and 2011 and contributed an average of 0.5889 MW of hourly load reduction in
2010,as 2011 data is not yet available.Idaho Power does not know the compensation
DOE received under contract with EnerNOC to participate in the FlexPeak Management
program.
The response to this Request was prepared by Pete Pengilly,Research and
Analysis Leader,Idaho Power Company,in consultation with Jason B.Williams,
Corporate Counsel,Idaho Power Company.
DATED at Boise,Idaho,this 12tF day of September 2011.
J N B.WILLIAMS
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -16
Intervals would correspond at an aggregate level to the peak hour 19(7:00 p.m.)on July
17,2010.
In the 2010 data,all Intervals are lIsted at the 30-mInute Interval level.In the
2011 data,January and February are reported at the 30-mInute interval level and March
through June are reported at the 15-mInute Interval level.
This response to this Request was prepared by Mary Graesch,Load Research
Leader,Idaho Power Company,In consultation with Matthew T.Larldn,Regulatory
Analyst,Idaho Power Company,and Jason B.Williams,Corporate Counsel,Idaho
Power Company.
IDAHO POWER COMPANY’S RESPONSE TO ThE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTiON REQUESTS TO IDAHO POWER COMPANY -15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2h day of September 20111 served a true and
correct copy of IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
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.Howell(puc.idaho.qov
472 West Washington (83702)KarI.KIein2puc.idaho.pov
P.O.Box 83720
Boise,Idaho 83720-0074
Industrial Customers of Idaho Power
____Hand
Delivered
PeterJ.Richardson
____U.S.
Mail
Gregory M.Adams
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Mail
RICHARDSON &O’LEARY,PLLC
___FAX
515 North Street (83702)X Email peter(2richardsonandoIeary.com
P.O.Box 7218 greqrichardsonandoIeary.com
Boise,Idaho 83707
Dr.Don Reading
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Ben Johnson Associates,Inc.
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Mail
6070 Hill Road
____Overnight
Mail
Boise,Idaho 83703
____FAX
X Email dr(benjohnsonassociates.com
Idaho Irrigation Pumpers Association,Inc.
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Eric L.Olsen
____U.S.
Mail
RACINE,OLSON,NYE,BUDGE &
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BAILEY,CHARTERED
___FAX
201 East Center X Email eIo(racineIaw.net
P.O.Box 1391
Pocatello,Idaho 83204-1 391
Anthony Yankel
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29814 Lake Road
____U.S.
Mail
Bay Village,Ohio 44140
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Mail
___FAX
X Email tony2yankeLnet
IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
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The Kroger Co.
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Kurt J.Boehm
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Mail
BOEHM,KURTZ &LOWRY
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36 East Seventh Street,Suite 1510
____FAX
Cincinnati,Ohio 45202 X Email kboehmBKLlawfirm.com
jrh(battfisher.com
Kevin Higgins
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Energy Strategies,LLC
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Mail
215 South State Street,Suite 200
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Mail
Salt Lake City,Utah 84111
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X Email khiqqinsenerqystrat.corn
Micron Technology,Inc.
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Mary V.York
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HOLLAND &HART LLP
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101 South Capital Boulevard,Suite 1400
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Boise,Idaho 83702 X Email myorkcholIandhart.com
tnelso nc hoI land hart.corn
madavidsonchollandhart.com
fschmidt(hoIlandhart.com
In buchananho I land hart.corn
Richard E.Malmgren
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Senior Assistant General Counsel
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Micron Technology,Inc.
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800 South Federal Way
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Boise,Idaho 83716 X Email remaImgrenmicron.com
The United States Department of Energy
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Arthur Perry Bruder,Attorney-Advisor
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United States Department of Energy
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Steven.porter(hg.doe.qov
Dwight D.Etheridge
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Exeter Associates,Inc.
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10480 Little Patuxent Parkway,Suite 300
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Columbia,Maryland 21044
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IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -18
Community Action Partnership
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Association of Idaho
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Brad M.Purdy
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Attorney at Law
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2019 North 17th Street X Email bmpurdyhotmail.com
Boise,Idaho 83702
Idaho Conservation League
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Benjamin J.Otto
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Idaho Conservation League
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710 North Sixth Street (83702)
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P.O.Box 844 X Email boffocidahoconservation.org
Boise,Idaho 83701
Snake River Alliance
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Ken Miller
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Snake River Alliance
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P.O.Box 1731
___FAX
Boise,Idaho 83701 X Email kmilIer2snakeriveralliance.orq
NW Energy Coalition
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Nancy Hirsh,Policy Director
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NW Energy Coalition
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Hoku Materials,Inc.
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Dean J.Miller
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McDEVITT &MILLER LLP
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420 East Bannock (83702)
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P.O.Box 2564 X Email joemcdevitt-milIer.com
Boise,Idaho 83701 heathemcdevitt-miIIer.com
Scott Paul,CEO
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Hoku Materials,Inc.
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One Hoku Way
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Pocatello,Idaho 83204
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IDAHO POWER COMPANY’S RESPONSE TO THE U.S.DOE’S SIXTH
INTERROGATORIES AND PRODUCTION REQUESTS TO IDAHO POWER COMPANY -19