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Home My WebLink About20111024IPC 1-17 to ICIP.pdfJASON B. WILLIAMS Corporate Counsel iwilliams~idahopower.com esIDA~POR~ An IDACORP Company October 21 , 2011 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-11-08 General Rate Case Dear Ms. Jewell: Enclosed for filng are an original and one (1) copy of Idaho Power Company's First Production Request to the Industrial Customers of Idaho Power in the above matter. Very truly yours, '\~~ A:so~ ~. Willams JBW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, 10 83707 LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) JASON B. WILLIAMS (ISB No. 8718) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 InordstromCäidahopower.com dwalkerCäidahopower.com jwilliamsaRidahopower.com RECEIVED ZUII OCT 21 PM~: 53 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 FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), by and through its attorneys, and hereby requests that the Industrial Customers of Idaho Power ("ICIP") answer the following production requests and provide the following information and documents in accordance with the Idaho Public Utilties Commission's ("Commission") Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1 To allow the Company to utilze these responses in preparing its rebuttal testimony, it is necessary that the responses to these production requests be provided as soon as possible, but no later than November 11, 2011. This production request is to be deemed continuing in nature and ICIP is requested to provide, through supplementation, additional documents or information that are responsive to this request that it, or any person acting on its behalf, may later come into possession or become aware of. REQUEST FOR PRODUCTION NO.1: Please provide the names of the members of the ICIP. REQUEST FOR PRODUCTION NO.2: Of the ICIP members listed in response to Request for Production NO.1, please list the ICIP members that are among the parties that are actively participating in Case No. IPC-E-11-08. REQUEST FOR PRODUCTION NO.3: Of the ICIP members listed in response to Request for Production NO.1, please provide a list of ICIP members that are currently paying a facilities charge to Idaho Power. REQUEST FOR PRODUCTION NO.4: Of the ICIP members listed in response to Request for Production NO.1, please list which members support the modification to the current Commission-approved facilties charge methodology. REQUEST FOR PRODUCTION NO.5: Of the ICIP members listed in response to Request for Production NO.1, please list which members would agree to purchase facilties owned by Idaho Power that are currently subject to the facilties charge if Idaho Power agreed to sell those facilties but if Idaho Power did not offer to maintain those facilities. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2 REQUEST FOR PRODUCTION NO.6: Please describe the ICIP's decision making process generally in proceedings before the Commission, and in particular, ICIP's decision making process among the members actively involved in Case No. IPC- E-11-08. REQUEST FOR PRODUCTION NO.7: (a) Please describe whether J.R. Simplot ("Simplot") has removed Idaho Power-owned equipment from any Simplot location and replaced those facilties with Simplot-owned equipment. (b) If the response to Request for Production No. 7(a) is yes, please list the date, piece of equipment, and Simplot location for each piece of equipment removed by Simplot. REQUEST FOR PRODUCTION NO.8: Please describe your understanding of how a change to the current Commission-approved facilities charge methodology or a change in property ownership of facilities subject to the facilties charge would impact Idaho Power's total revenue requirement per paragraph 11 of the Stipulation signed by ICIP and submitted to the Commission in Case No. IPC-E-11-08. REQUEST FOR PRODUCTION NO.9: Please describe your understanding of whether paragraph 11 of the Stipulation submitted in Case No. IPC-E-11-08 would require an increase to the rates and/or a direct charge to other Schedule 19 customers if Idaho Power were to experience a revenue loss in the event it reduced the amount of the facilties charge for Simplot and/or relinquished ownership to Simplot of Idaho Power owned facilities that were subject to the facilities charge. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 10: Please describe how ICIP envisions implementation of its proposed changes to Idaho Powets facilties charge provisions. Specifically address ownership of facilties, the monthly facilties charge rates, and any variations between plant locations/equipment/rate classes, replacement of failed equipment, customer-requested installation of new or additional equipment, and operation and maintenance responsibilities. Please produce any and all workpapers supporting this implementation plan. REQUEST FOR PRODUCTION NO. 11: Please describe in detail how ICIP proposes to calculate each cost component of the facilties charge based on its recommendations provided in the case. Please provide all workpapers, including electronic spreadsheets, of all such calculations. REQUEST FOR PRODUCTION NO. 12: Is ICIP aware of any discrepancies between its customers and the Company concerning mixed ownership of facilties that are installed beyond the Company's point of delivery? If so, please explain the nature of each of those discrepancies; Le., tracking, accounting, ownership, removal, and replacement. Please provide all workpapers showing these discrepancies. REQUEST FOR PRODUCTION NO. 13: If Idaho Power were to sell Company- owned facilities installed beyond its point of delivery, please explain ICIP's recommendation for determining a sales price that satisfies the requirements of Idaho Code § 61-328. Specifically, describe how ICIP's sales price recommendation is: (1) in the public interest, (2) that the costs and rates for supplying service wil not increase by reason of such transaction, and (3) that the acquiring customer has both the intent and IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4 ability to operate and maintain the utilty assets. Please provide all files and workpapers supporting your recommendation. REQUEST FOR PRODUCTION NO. 14: Does ICIP believe that Idaho Power's decision whether or not to provide maintenance on customer-owned equipment is a regulated business activity subject to the rules of the Commission? REQUEST FOR PRODUCTION NO. 15: If the ICIP's answer is "yes" to Request for Production No. 14, please provide all statutory and/or Commission rules supporting this answer. REQUEST FOR PRODUCTION NO. 16: Please describe your understanding as to whether all revenue Idaho Power receives in the form of facilties charge revenue is credited back to non-facilities charge customers and thus reducing the Company's total revenue requirement. REQUEST FOR PRODUCTION NO. 17: Please describe whether your proposal to modify the facilties charge methodology should be applicable to only Schedule 19 customers. If you believe the methodology should be changed for other customer classes, please identify those classes. DATED at Boise, Idaho, this 21 st day of October 2011.\ C' CV£- ~ c= B. WILLIAMS ey for Idaho Power Company f" IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 21st day of October 2011 I served a true and correct copy of IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, " 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.HowellaRpuc.idaho.gov Karl. KleinaRpuc. idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 2th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email peteraRrichardsonandoleary.com gregaRrichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email draRbenjohnsonassociates.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 eloaRracinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email tonYaRyankel.net IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 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 kboehmaRBKLlawfirm.com jrhaRbattfisher.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email khigginsaRenergystrat.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email myorkaRhollandhart.com tnelsonaRhollandhart.com madavidsonaRhollandhart.com fschmidtaRhollandhart.com InbuchananaRhollandhart.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email remalmgrenaRmicron.com Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Arthur.bruderaRhq.doe.gov Steven. porteraRhq.doe.gov Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email detheridgeaRexeterassociates.com IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7 Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 1 th Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email bmpurdYaRhotmail.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 bottoaRidahoconservation.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 kmileraRsnakeriverallance.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 nancYaRnwenergy.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 joeaRmcdevitt-miller.com heatheraRmcdevitt-miller.com Scott Paul, CEO Hoku Materials, Inc. One Hoku Way Pocatello, Idaho 83204 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email spaulaRhokucorp.com \ ~g~šõB. Willams " e IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8