20120409Micron 1-71 to IPC.pdf

HOLLAND&HART-P 41h, Phone [phone]
Pamela S. Howland
Fax [phone]
[e-mail]
April 9, 2012 6
rn —>- o

I C) C) Jean D. Jewell, Commission Secretary -01 rn
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074 Z' CID
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 First 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
Pamela S. Howland, No. 6177
Attorney for Micron Technology, Inc.
Enclosures
55 18214_i .DOCX
Holland & Hartu.p Attorneys at Law
Phone [phone] Fax [phone] www.hoIlmndhart.com
U.S. Bank Plaza 101 South Capitol Blvd Suite 1400 Boise, ID 83702-7714 Mailing Address P.O. Box 2527 Boise, ID 83701-2527
Aspen Billings Boise Boulder Carson City Cheyenne Colorado Springs Denver Denver Tech Center Jackson Hole Las Vegas Reno Salt Lake City Santa Fe Washington, D.C.
RECEIVED
Pamela S. Howland, ISB No. 6177
Brian T. Hansen, ISB No. 6087
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]
7U12 MR -g 1M 3 57
1;'T mmiSSION
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]
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 ) FIRST PRODUCTION REQUEST
RATES DUE TO REVISED DEPRECIATION ) OF MICRON TECHNOLOGY,
RATES FOR ELECTRIC PLANT-IN- ) INC. TO IDAHO POWER
SERVICE. ) 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
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
THURSDAY, APRIL 19,2012.
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 First
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 will also file a second set of
production requests ("Second Production Request") tomorrow, April 10, 2012; it requests that
the Company respond to this First Production Request as soon as possible before addressing
Micron's Second Production Request.
This First 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 hits behalf may later obtain that will augment the documents or information
produced.
. PRODUCTION REQUEST NO. 1: [Production Life] - Please provide the most recent
copy of the Company's integrated resource plan and generation expansion plan, as well
as any other studies that address future projections of life spans for the Company.
• PRODUCTION REQUEST NO. 2: [Production Life] - Please provide all support and
justification for why the Valmy Units 1 and 2 can not last as long as the 60-year life span
for Jim Bridger.
2
• PRODUCTION REQUEST NO. 3: [Production Life] - Please identify prior instances
where Gannett Fleming has recommended different life spans for jointly owned units in
different jurisdictions.
• PRODUCTION REQUEST NO. 4: [Production Life] - Please provide all support and
justification for any claim that the Company will not undertake capital expenditures to
keep Valmy Units 1 and 2 in operation as long as such future expected capital
expenditures are economical. To the extent the Company claims that future capital
expenditures necessary to keep the units operational will not be economical, provide all
support and justification for such a position.
• PRODUCTION REQUEST NO. 5: [Production Life] - Please provide the following
as it pertains to each of the Company's steam production plant generating units:
a.Megawatt size
b.Annual heat rate for the past 10 years
c.The number of cold starts for the past 10 years
d.The availability factor for the past 10 years
e.The scheduled outage rate for the past 10 years
f.The fixed outage rate for the past 10 years
g.The capacity factor for the past 10 years
h.The operating temperature and pressure
i.The capital expenditures for the past 10 years
j.The projected capital expenditures
• PRODUCTION REQUEST NO. 6: [Production Life] - Please provide the detailed
analysis that supports the proposed life spans for each of the Company's steam
3
generating units. The response should include all workpapers, assumptions,
considerations, and material reviewed and or relied upon, in sufficient detail to permit
verification of each proposed life span.
• PRODUCTION REQUEST NO. 7: [Production Life] - Please provide all documents
that support the proposed early termination of the Boardman generating station.
• PRODUCTION REQUEST NO. 8: [Production Life] - Please provide the life span
reflected in all Gannett Fleming depreciation studies for coal fired generating units during
the past 5 years. For each study, identify the utility, the year of the study, the specific
unit, and whether the life spans reflected in the study were ultimately adopted by the
utility's regulator and if so, the relevant jurisdiction as well as the corresponding docket
number.
• PRODUCTION REQUEST NO. 9: [Production Life] - Regarding the statement on
page 11-27 of Exhibit No. 11, that the life span estimates for the thermal, base load units is
40-60 years, please provide a listing of each coal fired unit that Gannett Fleming believes
currently has a 40-year life span. For each such instance, identify the utility, and
generating unit, when the 40-year life span was established, and the jurisdiction and
corresponding docket number where such life span was adopted by the utility's regulator.
The response should include copies of any documents necessary to verify any claim
regarding a 40-year life span for coal fired generating units.
• PRODUCTION REQUEST NO. 10: [Hydro] - Regarding the statement on page 11-27
of Exhibit No. 1, that the 75-114-year life spans for the hydraulic production facilities are
within the typical range, please identify and fully justify the specific typical range
All references to Exhibit No. 1 herein refer to Exhibit No. I to the Direct Testimony of John J. Spanos filed by the
Company in this proceeding.
4
referenced. Further, provide the life spans for all hydro generating units reflected in
Gannett Fleming depreciation studies during the past 5 years, specifically identifying the
utility, the jurisdiction, and name of the facility, the size of the facility, and the location
of the facility and whether such life spans have been specifically adopted by the
referenced utility's regulator and if so, identify the jurisdiction and the docket number.
• PRODUCTION REQUEST NO. 11: IHydrol - Regarding the statement on page 11-27
of Exhibit No. 1, that life spans for hydro facilities are determined by condition and
license dates, please provide the following:
a.Any specific issue associated with condition of any of the Company's hydro
generating units which limits the life expectancy of each unit to less than 100
years.
b.Each license application for renewal of a hydro facility that Gannett Fleming
and/or the Company are aware of that was denied for a hydro facility associated
with any utility, specifically identifying the utility, hydro facility, date of denial,
reason for denial, and Docket number.
c.Each instance that the Company and/or Gannett Fleming are aware of where a
hydro license was renewed or extended for Idaho Power Company.
d.A listing of each instance that the Company and/or Gannett Fleming are aware of
that a hydro license was renewed or extended for other utilities during the past 20
years, specifically identifying the utility and hydro generating facility, as well as
the date of the renewal or extension.
e.All specific studies, analysis, reports, etc. that specifically address the probable
retirement year for each of the Company's hydro generating facilities.
5
For each subpart above, please provide all workpapers, assumptions, considerations, and
material reviewed and/or relied upon in sufficient detail to permit verification of the
response.
. PRODUCTION REQUEST NO. 12: IHydrol -Please explain and fully justify why the
Company believes it can obtain 1 00-year or longer life spans for certain of its hydro
generating facilities yet proposes life spans short of 100 years for many of its hydro
generating facilities. The response should specifically address all factors that prohibit
those hydro generating facilities with life spans of less than 100 years of being able to
obtain 100 years of service or longer. The response should provide all workpapers,
assumptions, considerations, and material reviewed and/or relied upon in sufficient detail
to permit verification of the reasonableness of the response of information.
. PRODUCTION REQUEST NO. 13: [Other Production] - Please provide the
following for each of the Company's Other Production generating units:
a.The Megawatt size
b.Type of unit, including manufacturer and model number
c.The number of annual hours of operations since 2000
d.The number of annual starts since 2000
e.The heat rate by year
f.The forced outage rate by year since 2000
g.The availability factor by year since 2000
h.The manufacturer's recommended maintenance schedule
i.All information from the manufacturer regarding the number of hours of
operation that can be obtained from each type of unit
1 6
• PRODUCTION REQUEST NO. 14: [Other Production] - Please identify the life
spans utilized by Gannett Fleming in each of its depreciation studies during the past 5
years as it relates to Other Production generating units, identifying the type of unit, the
megawatt size, the utility, the name of the unit, and the location of the unit. Further,
provide the operating characteristics of the unit (i.e., base load, intermediate, peaking,
reserve, etc.).
• PRODUCTION REQUEST NO. 15: [Production] - Please identify all operating or
maintenance characteristics of the Company that would result in a situation where the life
expectancy for its generating units would be shorter than the life expectations of similar
units operated by other utilities. For each item, policy, practice, etc. identified, provide all
support and justification for the Company's decision to operate in such a manner and the
resulting expected life shortening impact that each such situation produces. Further,
provide all underlying support and justification for the Company's response.
• PRODUCTION REQUEST NO. 16: [Combined Cycle] - Please identify the life span
utilized by other utilities for combined cycle generating units that the Company and/or
Gannett Fleming are aware of. For each other combined cycle unit, provide the name of
the unit, the owner of the unit, the location of the unit, and the type of unit, including
manufacturer and model number, as well as all documentation and support of the
Company's response.
• PRODUCTION REQUEST NO. 17: [Combined Cycle] - Please provide any life
expectation information provided by the manufacturer of the Langley Gulch combined
cycle unit.
VA
. PRODUCTION REQUEST NO. 18: [Combined Cycle] - Please provide the
underlying economic analyses utilized by the Company to support the decision to
construct the Langley Gulch combined cycle facility.
. PRODUCTION REQUEST NO. 19: [Other Production] - Please provide all studies,
reports, analyses, etc. developed by or on behalf of the Company that supports the
proposed life spans for the Company's Other Production generating facilities. The
response should include all analyses of current practices and expected practices as well as
current utilization and expected demands on each of the generating facilities.
. PRODUCTION REQUEST NO. 20: [Production Life] - Please identify the type of
major environmental systems at each of the Company's coal fired generating facilities
(e.g., scrubbers, bag houses, etc.). Further, indicate if such systems were placed in service
when the units initially became operational or have been retrofitted, and if retrofitted,
state when the retrofit occurred. Finally, identify all current plans to place any new major
environmental systems into operation for each of the Company's generating facilities.
. PRODUCTION REQUEST NO. 21: [Hydro] - For each of the Company's hydro
generating facilities, identify the location, the body of water associated with each hydro
facility, the megawatt size, and any identifiable major problems associated with any
major component of each hydro facility.
I • PRODUCTION REQUEST NO. 22: [Data] - As it relates to references that service life
and net salvage estimates contained in the Gannett Fleming study are based on informed
judgment which incorporates analysis of historical data, review of Company practices
and outlooks, considerations of current practices in the industry, and knowledge of
estimates used by others, please provide the following:
a.A detailed narrative identifying and justifying each separate practice or outlook of
the Company that had an impact on life estimates, by account.
b.A detailed narrative identifying and justifying each separate practice or outlook of
the Company that had an impact on net salvage estimates, by account
c.A detailed narrative identifying and justifying each current practice in the electric
utility industry that has an impact on life estimates, by account.
d.A detailed narrative identifying and justifying each current practice in the electric
utility industry that has an impact on net salvage estimates, by account.
e.A detailed narrative identifying and justifying estimates used for other electric
utility properties as it relates to the establishment of service life by account.
f.A detailed narrative identifying and justifying estimates used for other electric
utility properties as it relates to net salvage, by account.
For each subpart above, provide all workpapers, assumptions, considerations, and
material reviewed and/or relied upon in sufficient detail to permit verification of the
reasonableness of the response.
• PRODUCTION REQUEST NO. 23: [Data] - Please provide a complete copy of any
internal or external surveys of depreciation parameters in possession of both the
Company and Gannett Fleming as it relates to service life and salvage estimates used by
other electric utilities.
• PRODUCTION REQUEST NO. 24: [Data] - Please provide all interview notes and
site visit notes associated with the development of the current depreciation study
including notes from prior studies that were relied upon for purposes of the current
depreciation study.
• PRODUCTION REQUEST NO. 25: [Net Salvage] - Please provide a detailed
narrative and step-by-step process including the specific inputs and supplemental
information from Company personnel that resulted in each specific net salvage value
proposed by account for Accounts 310 through 356. The response should include all
workpapers, assumptions, considerations, and material reviewed and/or relied upon, by
account, in sufficient detail to demonstrate how each component, item of information,
estimation, or trends, etc. resulted in the specific value proposed in the Gannett Fleming
study.
• PRODUCTION REQUEST NO. 26: [Net Salvage] - Please identify the specific trend
observed and relied upon by Gannett Fleming as referenced at the bottom of page 1-3 of
Exhibit No. 1 as it relates to the development of net salvage estimates for each account.
Further, specifically identify, by account, those accounts where no trend was identified.
• PRODUCTION REQUEST NO. 27: [Net Salvage] - Regarding the statement on page
1-4 of Exhibit No. 1, that an understanding of the function of the plant and information
with respect to reasons for past retirements was obtained, please provide:
a.The specific understanding of the function, by account, and how such specific
understanding of the function resulted in the proposed net salvage value, by
account.
b.Each major or meaningful reason of past retirement, specifically identified by
account and how each specific reason for past retirements impacted the ultimate
proposed level of net salvage, by account.
10
c. Each specific future expectation associated with retirements, by account, and how
each specific expectation impacted the ultimate proposed net salvage value
proposed, by account.
As it relates to the response of each of the subparts above, please provide all workpapers,
assumptions, considerations, and material reviewed and/or relied upon, in sufficient detail
to permit verification of the accuracy of the response.
. PRODUCTION REQUEST NO. 28: [Net Salvage] - Please state whether the historical
data, as reflected in the net salvage analysis, are time synchronized. To the extent the
information is not time synchronized, please identify the minimum and maximum time
periods between when a retirement is recorded and when the corresponding gross salvage
and cost of removal are reported by account. Further, identify the annual level of cost of
removal and gross salvage, by account, during the past 5 years which was not recorded
the same year as the corresponding retirement.
. PRODUCTION REQUEST NO. 29: [Account 3111 -Please explain how a negative
gross salvage for 1996 was recorded for Account 311 as set forth on page 111-175 of
Exhibit No. 1. Further, provide all justification for negative gross salvage values.
. PRODUCTION REQUEST NO. 30: [Account 311] -Please identify what retired and
at what unit in 2010 for Account 311 in the amount of $1.8 million.
. PRODUCTION REQUEST NO. 31: [Data] - Please provide a detailed categorization
of plant investment by account, on electronic medium in Excel readable format.
. PRODUCTION REQUEST NO. 32: [Data] - Please provide a detailed categorization
of what retired by account per year for the past 10 years for all production, transmission,
11
and general plant accounts. The information should be provided on electronic medium in
Excel readable format.
• PRODUCTION REQUEST NO. 33: [Account 3121 - Please identify what retired in
2009 and 2010, separately, for Account 312 as set forth on page 111-176 of Exhibit No. 1.
Further, identify which plant the retirements are associated with as well as what caused
the retirements, and why such type of retirements are considered typical and predictive of
the overall level of net salvage for this account.
• PRODUCTION REQUEST NO. 34: [Account 3141 -Please explain and justify the
negative cost of removal and negative gross salvage in 1999 for Account 314 as set forth
on page 111-178 of Exhibit No. 1.
• PRODUCTION REQUEST NO. 35: [Account 3141 - Please identify, by generating
unit, what retired annually for the years 2006-2010 in Account 316 as set forth on page
111-178 of Exhibit No. 1. Further, state and justify why each separate type of retirement
activity is considered predictive of future expectations for the Company's current
investment in the account.
• PRODUCTION REQUEST NO. 36: [Account 3311 - Please provide a detailed
narrative of what retired in 2009 for Account 331 as set forth on page 111-182 of Exhibit
No. 1. Further, identify why the 218% cost of removal for the retirement in that year is
considered representative of the future expectations for such account. Finally, provide all
workpapers, assumptions, considerations, and material reviewed and/or relied upon in
sufficient detail to permit verification of the accuracy of the response.
• PRODUCTION REQUEST NO. 37: [Account 3321 - Please provide a detailed
narrative of what retired by amount in what year for Account 332 that resulted in the
12
$495,652 cost of removal reported in 1997 as set forth on page 111-185 of Exhibit No. 1.
The response should further fully support and justify why such level of cost of removal is
considered indicative of retirement activity in the future for the remaining investment in
this account. Finally, provide all workpapers, assumptions, considerations, and material
reviewed and/or relied upon in sufficient detail to permit verification of the
reasonableness of the response.
• PRODUCTION REQUEST NO. 38: [Account 3331 - Please provide a detailed
narrative explanation of what retired, by year, and the corresponding dollars of
retirement, by year that resulted in a $236,926 cost of removal in 2010 for Account 333
as set forth on page 111-188 of Exhibit No. 1. Further, provide a detailed narrative that
explains and supports why such level of cost of removal is considered predictive and
reasonable for the remaining investment in the account in the future. Finally, provide all
workpapers, assumptions, considerations, and material reviewed and/or relied upon in
sufficient detail to permit verification of the reasonableness of the response.
• PRODUCTION REQUEST NO. 39: [Net Salvage] - Please identify each generating
unit the Company has retired in the past. For each such generating unit, identify and
provide the name, the megawatt size, the fuel type, the year installed, the year retired, the
reason for retirement, the disposition of the facility, and the specific gain or loss
associated with the retirement, specifically identifying the dollar level of retirement and
the corresponding gross salvage and cost of removal.
• PRODUCTION REQUEST NO. 40: [Net Salvage] - Please identify any plant retired
that was sold where the proceeds associated with the sale were not booked into the
accumulated provision for depreciation since the Company's last fully litigated rate
13
proceeding. The response should identify the amount of retirement and net proceeds
obtained from each such sale, the account to which the plant was set forth prior to
retirement, and whether customers received the benefit of the proceeds of any such sale
and if not, why not.
• PRODUCTION REQUEST NO. 41: [Fully Accrued] - Please identify any account or
sub-account in which the Company ceased the booking of depreciation to the
accumulative provision for depreciation while the corresponding plant dollars were still
in service since the Company's last fully litigated rate proceeding. For each such
instance, identify the depreciation rate in effect immediately prior to the cessation of
booking of depreciation, the plant balance on a monthly basis from that time period
through the present, and any changes in account depreciation rates approved by the
Commission and when such changes in depreciation rates became effective. The
information should be provided on electronic medium in Excel readable format. Further,
provide all support and justification for any decision to cease booking depreciation
expense to the accumulated provision for depreciation without authority from the
Company's regulator.
• PRODUCTION REQUEST NO. 42: [Account 353] - Please fully explain and justify
the negative gross salvage for Account 353, reported in 2009 on page 111-201 of Exhibit
No. 1.
• PRODUCTION REQUEST NO. 43: [Account 3531 - Please identify the number and
size of transformers reflected in Account 353. Further, identify the number and size, of
transformer retired by year during the past 10 years.
1 14
. PRODUCTION REQUEST NO. 44: (Account 3531 - Please identify specifically what
retired in Account 353 during 2005 in the amount of $3 million, and the reason for the
retirement.
. PRODUCTION REQUEST NO. 45: [Net Salvage] - Please identify by account, by
year, those retirements that occurred due to emergency situations for production and
transmission accounts.
. PRODUCTION REQUEST NO. 46: (Account 3551 - Please identify the number, by
type and height, of the various poles in Account 355, along with the corresponding level
of investment by type and height.
. PRODUCTION REQUEST NO. 47: (Account 3551 - Please provide a detailed
narrative of what retired by year and the corresponding dollar amounts that correspond to
the $1.1 million cost of removal reported in 2007 for Account 355 on page 111-206 of
Exhibit No. 1.
. PRODUCTION REQUEST NO. 48: (Account 3551 - Please identify the number of
poles by height and type retired by year during the past 10 years in Account 355.
. PRODUCTION REQUEST NO. 49: (Account 3561 - Please identify the linear feet
and corresponding dollar level of investment in copper overhead conductors in Account
356.
. PRODUCTION REQUEST NO. 50: (Account 3561 - Please identify the linear feet of
conductor retired by type of conductor in Account 356 by year for the past 10 years.
. PRODUCTION REQUEST NO. 51: (Account 3561 - Please identify what retired and
the corresponding dollars of retirement by year that relate to the $1.3 million of cost of
removal reported for Account 356 in 2007 on page 111-209 of Exhibit No. 1.
15
• PRODUCTION REQUEST NO. 52: [Account 3561 - Please provide a detailed
narrative explanation along with all support and justification why similar dollar levels of
retirement activity in Account 356 for 2009 and 2010 produced negative net salvage
values in 2010 more than double the value in 2009. Further, provide all workpapers,
assumptions, considerations, and material reviewed and/or relied upon in sufficient detail
to permit verification of the reasonableness of the response.
• PRODUCTION REQUEST NO. 53: [Account 3111 -Please provide a detailed
narrative supporting and justifying reliance on historical life indications for Account 311
when the observed life table declines to only 94% surviving as set forth on page 111-15 of
Exhibit No. 1. Further, explain and justify why a value of 125 years would not also be
representative based on the historical data.
• PRODUCTION REQUEST NO. 54: [Data] - Please provide the input to each life and
salvage analysis for production and transmission plant accounts on electronic medium in
Excel readable format.
• PRODUCTION REQUEST NO. 55: [Data] - Please provide the output of each life
analysis (i.e., the observed life table) by account for production and transmission
accounts on electronic medium in Excel readable format.
• PRODUCTION REQUEST NO. 56: [Data] - Please provide the annual plant balance
and corresponding dollars of retirement by generating unit by account on electronic
medium in Excel readable format.
• PRODUCTION REQUEST NO. 57: [Account 3121 - Please provide a detailed
narrative identifying what retired and the corresponding dollars of retirement activity by
generating unit, corresponding to the retirement activity in age brackets 1.5, 27.5, 28.5,
16
34.5, and 35.5 years for Account 312, as set forth on page 111-19 of Exhibit No. 1. For
each major item of retirement, specifically state what caused the retirement (e.g.
catastrophic failure, change out of investment to meet new environmental concerns, etc.).
. PRODUCTION REQUEST NO. 58: [Account 3141 - Please provide a detailed
narrative identifying what retired by year and the cause of retirement by generating unit
corresponding to the retirement activity for age brackets 16.5, 23.5, 27.5, and 29.5 years
for Account 314 as set forth on page 111-23 of Exhibit No. 1.
• PRODUCTION REQUEST NO. 59: [Account 3321 - Please state whether other longer
life-curve combinations would also be reasonably representative of the observed life table
for Account 332.20 as reflected on page 111-47 of Exhibit No. 1. To the extent the
proposed 95S4 life curve combination is the best representative predictor of interim
retirements for this account, and that other values that are longer are not also reasonably
representative, provide all support and justification for such claim.
• PRODUCTION REQUEST NO. 60: [Account 3331 - Regarding the graphical
presentation set forth on page 111-54 of Exhibit No. 1, and the corresponding observed life
table numerical data on the following pages, please provide a detailed narrative
explaining and justifying the selection of an 80R3 life-curve combination for Account
333. The response should specifically address why the values beginning at approximately
40 years of age and continuing through 60 years of age, were allowed to deviate to the
extent shown in comparison with an apparent attempt to match the decline in the
observed life table in the mid-60 year age range and older. Further, provide all support
and justification for the response provided.
17
• PRODUCTION REQUEST NO. 61: [Account 3331 - Please state whether the
Company agrees that a longer life-curve combination would also be reasonable if not
superior to the 80R3 life curve combination proposed for Account 333 as set forth on
page 111-54 of Exhibit No. 1. To the extent the Company believes that the 80R3 is the
best curve fit or other longer curve fits are not equivalent or superior, please provide all
support and justification for such position.
• PRODUCTION REQUEST NO. 62: [Account 343] - Please provide a detailed
narrative explaining and justifying the selection of a 40S 1.5 life-curve combination for
Account 343 as set forth on page 111-82 of Exhibit No. 1. Further, state and justify
whether a longer life-curve combination would also be appropriate for this account and if
not, why other longer life-curve combinations would not be reasonable and appropriate.
• PRODUCTION REQUEST NO. 63: [Account 3531 - Please provide a detailed
narrative explaining the curve fitting selection for Account 353 as set forth on page III-
101 of Exhibit No. 1. The response should specifically address the criteria relied upon as
well as all support for such criteria, and specifically why it was acceptable to present a
life-curve combination which begins to deviate from the observed life table at
approximately 45 years of age.
• PRODUCTION REQUEST NO. 64: [Account 3541 - Please provide a detailed
narrative setting forth the specific criteria relied upon to establish a 65S3 life-curve
combination for Account 354 including the curve fit relationship set forth on page 111-105
of Exhibit No. 1. The response should specifically address why a longer life-curve
combination is not more appropriate than the 65S3 as proposed.
18
• PRODUCTION REQUEST NO. 65: [Account 3551 - Please provide a detailed
narrative identifying the process and all criteria employed to establish a 60R2 life-curve
combination for Account 355 as set forth on page 111-108 of Exhibit No. 1. The response
should specifically address why the deviation beginning in the early 40-year age bracket
was considered reasonable and acceptable. The response should include all criteria and
support for criteria relied upon in the curve fitting process.
• PRODUCTION REQUEST NO. 66: [Account 3561 - Please provide a detailed
narrative explaining the curve fitting process and all underlying criteria and support for
such criteria associated with the selection of 65R2 life-curve combination for Account
356 as set forth on page 111-112 of Exhibit No. 1.
• PRODUCTION REQUEST NO. 67: [Account 391.2] - Please provide all support and
justification for the selection of a 5SQ life-curve combination for Account 391.2. The
response should specifically address and explain why a longer life-curve combination or
a different dispersion pattern is not more appropriate given the surviving plant for
account as set forth on page 111-423 of Exhibit No. 1.
• PRODUCTION REQUEST NO. 68: [Account 391.21 - Please provide the dollar level
of retirement for Account 391.2 on a monthly basis subsequent to June 30, 2011. Further,
identify the vintage year of addition associated with each of the retirements.
• PRODUCTION REQUEST NO. 69: [Account 397.21 - Please provide a detailed
narrative identifying and fully supporting the selection of a 15SQ life-curve combination
for Account 397.2. The response should fully address and justify the selection and
relationship of the proposal to the surviving original cost set forth on page 111-439 of
Exhibit No. 1 that exceeds the 15 year service life assumption.
19
. PRODUCTION REQUEST NO. 70: [Data] - Please identify any retirements, gross
salvage, cost of removal or other data considered atypical or unusual in development of
the depreciation study. For each such instance, identify the account, the amount, the type
of transaction, why it was determined or assumed to be atypical or unreasonable and the
action taken in association with such a determination (e.g., removed retirements for
Account 353 in 2006 because it reflected a situation deemed to be unusual because ).
Further, provide all support and justification for any such justification.
. PRODUCTION REQUEST NO. 71: [Combined cycle] - Please provide all input and
corresponding calculations corresponding to the depreciation rates for Langley Gulch
utility as set forth on page 111-10 of Exhibit No. 1.
Dated this 9th day of April, 2012.
HOLLAND & HART LLP
By: I
Pamela S. Howland, ISB No. 6177
Brian T. Hansen, ISB No. 6087
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)
20
HOLLAND & HART LLP
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
sakrundel1ho1landhart.com
Attorneys for Micron Technology, Inc.
21
CERTIFICATE OF SERVICE
I hereby certify that on this 9th day of April, 2012, a true and correct copy of the within
and foregoing FIRST 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 Z Hand Delivery
Idaho Public Utilities Commission U.S. Mail, postage pre-paid
472 W. Washington Street (83720) Facsimile
P0 Box 83720 Z Electronic Mail
Boise, ID 83702
JI.cuI. IIwJu.IuaI1u.0 v
Commission Staff
Donald L. Howell, II, DAG Z Hand Delivery
Karl T. Klein, DAG U.S. Mail, postage pre-paid
Idaho Public Utilities Commission E1 Facsimile
472 W. Washington Street (83720) Z Electronic Mail
P0 Box 83720
Boise, ID 83702
don.howell(puc.idaho.gov
[e-mail]
Idaho Power Company
Lisa D. Nordstrom Hand Delivery
Jason B. Williams U.S. Mail, postage pre-paid
Idaho Power Company Facsimile
1221 W. Idaho St. (83702) Z Electronic Mail
P0 Box 70
Boise, Idaho 83707-0070
[e-mail]
jwilliams@idahoi,ower.com
Idaho Power Company
Courtney Waites
Greg Said
Tim Tatum
Idaho Power Company
1221 W. Idaho St. (83702)
P0 Box 70
Boise, Idaho 83707-0070
[e-mail]
gsaid(idahopower.com
[e-mail]
LI Hand Delivery
LI U.S. Mail, postage pre-paid
LI Facsimile
Electronic Mail
Leah N. Buchanan