20120410Micron 72-100 to IPC.pdf

HOLLAND &HART. "i.,
Pamela S. Howland
Partner
[e-mail]
April 10, 2012
Jean D. Jewell, Commission Secretary _-C m Idaho Public Utilities Commission -
472 West Washington Street f0 M
P.O.Box 83720
Boise, Idaho 83720-0074
C) ca)
Re: CASE NO. IPC-E-12-08
IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY
FOR AUTHORITY TO INCREASE ITS RATES DUE TO REVISED
DEPRECIATION RATES FOR ELECTRIC PLANT-IN-SERVICE
Dear Ms. Jewell:
Please find enclosed for filing an original and three (3) copies of the Second Production
Request of Micron Technology, Inc. to Idaho Power Company.
If you have any questions, please do not hesitate to contact me at [phone].
Very truly yours,
Holland & Hart LLP
LP Pamela S. Howland, ISB No. 6177
Attorney for Micron Technology, Inc.
Enclosures
5518433_i .DOCX
Holland & Hart .. Attorneys at Law
Phone [phone] Fax [phone] www.holIandbart.com
555 17th Street Suite 3200 Denver, CO 80202-3979 Mailing Address Post Office Box 8749 Denver, CO 80201-8749
Aspen Billings Bose Boulder Carson City Cheyenne Colorado Springs Denver Denver Tech Center Jackson flde Las Vegas Reno Sat Lake City Santa Fe Washington, D.C.
Brian T. Hansen, ISB No. 6087
Pamela S. Howland, ISB No. 6177
HOLLAND & HART LLP
Suite 1400, U.S. Bank Plaza
101 South Capitol Boulevard
P.O. Box 2527
Boise, Idaho 83701-2527
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Thorvald A. Nelson (pro hac vice pending)
Frederick J. Schmidt (pro hac vice pending)
Sara K. Rundell (pro hac vice pending)
HOLLAND & HART LLP
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
RECEtvE:D
2012 APR 10 P11 2:03
-• ii c..' i *L
Attorneys for Micron Technology, Inc.
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-12-08
OF IDAHO POWER COMPANY )
FOR AUTHORITY TO INCREASE ITS ) SECOND PRODUCTION
RATES DUE TO REVISED DEPRECIATION ) REQUEST OF MICRON
RATES FOR ELECTRIC PLANT-IN- ) TECHNOLOGY, INC. TO IDAHO
SERVICE. ) POWER COMPANY
PURSUANT TO Rule 225 of the Rules of Procedure of the Idaho Public Utilities
Commission (the "Commission"), IDAPA 31.01.01.225, Micron Technology, Inc. ("Micron") by
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
1
and through its attorneys, respectfully requests that Idaho Power Company (the "Company")
provide the following documents and information as soon as possible, but no later than
FRIDAY, APRIL 20, 2012.
In accordance with an informal understanding among the Commission and the parties to
this proceeding, Micron respectfully requests that the Company provide its responses to this
Second Production Request within 10 days, rather than 14 days, so that Micron can review the
responses prior to a settlement meeting scheduled for April 23, 2012. Micron has also filed a
first set of production requests ("First Production Request"); it requests that the Company
respond to the First Production Request as soon as possible before addressing this Second
Production Request.
This Second Production Request is to be considered as continuing, and the Company is
requested to provide supplementary responses, including additional documents, that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
. PRODUCTION REQUEST NO. 72: [Account 3101 - Please state if there are any
specific expiration dates to any of the Company's land and water rights set forth in
Account 310. To the extent there any expiration dates associated with land and water
rights, identify the amount, the in service date, the expiration date, and the basis for the
expiration date for each.
. PRODUCTION REQUEST NO. 73: [Account 3101 - Please identify the quantity of
water rights (e.g., 10,000 acre feet, etc.) owned by the Company, or for which the
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
2
I Company has control and can sell. Further, provide all indications of water right values in
the general region from which the water rights are obtained.
• PRODUCTION REQUEST NO. 74: [Account 3161 - Please provide all basis and
support for the selection of a -2% net salvage for Account 316, specifically including
reference to the net salvage summary set forth on page 111-80 of Exhibit No. 11.
• PRODUCTION REQUEST NO. 75: [Account 3361 - Please provide all support and
justification for the assumed 75R3 life-curve combination for Account 336, specifically
addressing the observed life table and graphical presentation set forth on page 111-75
through 111-77 of Exhibit No. 1.
. PRODUCTION REQUEST NO. 76: [Account 3441 - Please provide all support and
justification for the proposed 45S2 life-curve combination for Account 344 specifically
addressing the graphical presentation on page 111-84 of Exhibit No. 1 and the fact that no
retirement activity has been recorded for this account.
. PRODUCTION REQUEST NO. 77: [Other Production] - Please provide all support
and justification for the assumed zero level of net salvage for Other Production
investment. The response should specifically reference why the Company believes it
cannot sell any portion of any of its Other Production generating facilities as usable
equipment at the time of retirement.
• PRODUCTION REQUEST NO. 78: [Account 350.21 - Please state whether the land
rights and easements set forth in Account 350.2 have a specific expiration date. To the
1 All references to Exhibit No. lherein refer to Exhibit No. 1 to the Direct Testimony of John J. Spanos filed by the
Company in this proceeding.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
3
extent any of the land rights and easements have a specific expiration date, identify the
original cost of the land right or easement, the in service date and the expiration date.
• PRODUCTION REQUEST NO. 79: [Account 350.2] - Please explain how the
Company can justify relying on a 70R3 life-curve combination for Account 350.2 when
the structures such as towers and fixtures that reside upon such land rights and easements
are assigned a 65-year average service life with a dispersion around the average, implying
that some towers and fixtures will last much longer than 70 years.
• PRODUCTION REQUEST NO. 80: [Account 390] -Please identify the 10 largest
investments in Account 390 structures and improvements and for each provide the
following:
a.The original cost;
b.Whether the facility is owned or leased;
c.The location of the investment;
d.A detailed description of the investment;
e.The current property tax value;
f.The construction type and material associated with the investment;
g.When the property was first placed in service; and
h.Any current plans to retire each property, if any.
• PRODUCTION REQUEST NO. 81: [Account 3521 - Please identify what retired in
2010 for Account 352 in the amount of $220,357. Further, identify the cause of
retirement associated with each of the retirement activities reflected therein.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
ru
• PRODUCTION REQUEST NO. 82: [Account 3521 - Please provide a detailed
narrative and corresponding support for the Company's curve-fitting selection associated
with Account 352 that resulted in a proposed 65R3 life-curve combination. The response
should specifically address the deviation of the proposed life-curve combination with the
observed life table beginning around 35 years of age. Further, specifically state and
justify why a life-curve combination with a longer average service life would not also be
appropriate.
• PRODUCTION REQUEST NO. 83: [Account 390.21 - Please provide a detailed
narrative and corresponding full justification for the proposed 35S3 life-curve
combination for Account 390.2. The response should specifically address which portions
of the observed life table were assigned greater significance in the Company's curve
fitting process as set forth on page 111-164 of Exhibit No. 1. Further, provide all support
and justification for the portion of the observed life table that were assigned greater
significance in the curve fitting process.
• PRODUCTION REQUEST NO. 84: [Account 391.1] - Please provide the dollar
amount of investment in Account 391.1 that has retired subsequent to June 30, 2011.
Specifically identify the date of installation corresponding to the retired property.
• PRODUCTION REQUEST NO. 85: [Account 391.11 - Please provide a detailed
narrative identifying the specific basis for the selection of a 20SQ life-curve combination
for the investment in Account 391.1. Further, provide all support and justification for the
basis employed to develop such life-curve combination
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
5
• PRODUCTION REQUEST NO. 86: [Account 392] - Please provide a detailed
narrative explaining and justifying the determination of a 12L2 life-curve combination
for Accounts 392.1, 392.4, and 392.5.
• PRODUCTION REQUEST NO. 87: [Account 3921 - Please provide a detailed
narrative along with all support and justification for the proposed 20L2 life-curve
combination for Accounts 392.6 and 392.7.
• PRODUCTION REQUEST NO. 88: [Account 3951 - Please provide a detailed
narrative and corresponding support for the selection of a 20SQ life-curve combination
for Account 395.
• PRODUCTION REQUEST NO. 89: [Account 3951 - Please provide the monthly
retirements in Account 395 subsequent to June 2011. For each retirement, identify the
date of installation.
• PRODUCTION REQUEST NO. 90: [Account 3961 - Please provide a detailed
narrative along with full justification of how and why a 2001 life-curve combination was
selected for Account 396.
• PRODUCTION REQUEST NO. 91: [Account 396] - Please provide full support and
justification for the proposed 30% positive net salvage for Account 396. Further, provide
the actual historical activity for this account.
• PRODUCTION REQUEST NO. 92: [Account 3961 - Please provide a detailed
narrative along with all support and justification for not assigning any remaining life to
investment in Account 396 corresponding to vintage years 1994 and earlier as set forth on
page 111-43 6 of Exhibit No. 1.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
6
• PRODUCTION REQUEST NO. 93: [Account 3971 - Please provide all support and
justification along with a detailed narrative of how and why a 15SQ life-curve
combination was proposed the Account 397.2. Further, specifically address the level of
vintage original costs that are still in service after 15 years as set forth on page 111-439 of
Exhibit No. 1 in conjunction with the proposal for a 15SQ life-curve combination.
• PRODUCTION REQUEST NO. 94: [Account 397.2] - Please provide the monthly
level of retirements in Account 397.2 subsequent to June 30, 2011. Further, identify the
corresponding vintage year of addition for each retirement.
• PRODUCTION REQUEST NO. 95: [Account 397.41 - Please provide a detailed
narrative along with all support and justification for the proposed 1 OSQ life-curve
combination for Account 397.4. The response should further address the surviving
balances as set forth on page 111-441 of Exhibit No. 1 for this account. Finally, provide
the dollar level of retirement activities subsequent to June 30, 2011 for this account along
with the vintage year of addition corresponding to the retirements.
• PRODUCTION REQUEST NO. 96: [Net Salvage] - Please identify each statutory
requirement the Company has to actually demolish any of its production plant facilities.
Further, identify if any statutory requirements exist for restoring the site after demolition
to any pre-existing status.
• PRODUCTION REQUEST NO. 97: [Reserve] - Please state if the accumulative
provision for depreciation is maintained on an account-by-account basis or if the values
are allocated in any manner. To the extent the account values are allocated, provide the
basis for such allocation along with all support for such allocation.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
7
• PRODUCTION REQUEST NO. 98: [Net Salvage] - Please identify the per univscrap
price obtained for scrap metal sales by year for the past 10 years. Further, identify the
accounts to which the amounts pertain.
• PRODUCTION REQUEST NO. 99: [Net Salvage] - Please provide the level of
overtime costs reflected in cost of removal by year by account for the past 10 years.
• PRODUCTION REQUEST NO. 100: [Account 311] - Please provide Exhibit No. 1 on
electronic medium in Excel readable format with all formulas intact.
Dated this 10th day of April, 2012.
HOLLAND & HART LLP
By: ~&~- - Pamela S. Howland, ISB No. 6177
Brian T. Hansen, ISB No. 6087
HOLLAND & HART LU'
Suite 1400, U.S. Bank Plaza
101 South Capitol Boulevard
P.O. Box 2527
Boise, Idaho 83701-2527
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Thorvald A. Nelson (pro hac vice pending)
Frederick J. Schmidt (pro hac vice pending)
Sara K. Rundell (pro hac vice pending)
HOLLAND & HART LLP
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
8
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08
9
CERTIFICATE OF SERVICE
I hereby certify that on this 10th day of April, 2012, a true and correct copy of the within
and foregoing SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO
IDAHO POWER COMPANY in CASE NO. IPC-E-12-08 was served in the manner shown to:
Commission Staff
Jean Jewell, Commission Secretary
Donald L. Howell, II, DAG
Karl T. Klein, DAG
Idaho Public Utilities Commission
472 W. Washington Street (83720)
P0 Box 83720
Boise, ID 83702
[e-mail]
[e-mail]
karl.klein(puc.idaho.gov
Idaho Power Company
Lisa D. Nordstrom
Jason B. Williams
Idaho Power Company
1221 W. Idaho St. (83702)
P0 Box 70
Boise, Idaho 83707-0070
[e-mail]
[e-mail]
Idaho Power Comany
Courtney Waites
Greg Said
Tim Tatum
Idaho Power Company
1221 W. Idaho St. (83702)
P0 Box 70
Boise, Idaho 83707-0070
[e-mail]
gsaid(idthopower.com
[e-mail]
Hand Delivery
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Electronic Mail
/s/ Leah N Buchanan
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY
IPC-E- 12-08