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iiili g[{l _3 [:i.! tr: h3LISA D. NORDSTROM
Lead Counsellnordstrom@idahopower.com - :
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December 3,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-20
ldaho Power Company's Base Level NPSE - ldaho Power Company's
Response to the First Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the First Production Request of the Commission Staff
("Staff') to ldaho Power Company. Also, enclosed are four (4) copies of a confidential
disk containing information responsive to Staffs Production Request Nos. 2 and 3. Please
handle the confidential information in accordance with the Protective Agreement executed
in this matter.
Also, enclosed are four (4) copies of a non-confidential disk containing information
responsive to Staffs Production Request Nos. 1, 4, and 5.
Sincerely,
1221 W. ldaho St. (83702)
P.O..Box 70
Boise, lD 83707
fi--n-?0/",,*
Lisa D. Nordstrom
LDN:evp
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702')
P.O. Box 70
Boise, ldaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388-6936
I nord strom@idahopower. co m
irei n hardt@ idahooower. co m
Attorneys for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH A NEW
BASE LEVEL OF NET POWER
SUPPLY EXPENSE.
CASE NO. IPC-E-13-20
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW, ldaho Power Company ("ldaho Powed' or "Company"), and in
response to the First Production Request of the Commission Staff ("Staff') to ldaho
Power Company dated November 12,2013, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. 1
REQUEST NO. 1: Please provide a copy of all the AUROM input and output
files that ldaho Power used to determine the base level of Net Power Supply Expense
(NPSE) as discussed in Scott Wright's testimony. Please provide the files electronically
in an AURORA-compatible or Excelformat as appropriate.
RESPONSE TO REQUEST NO. 1: The AURORA input and output files are
included as Attachments 1-5 on the non-confidential CD.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst
ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please provide a copy of all workpapers used to determine
the amount of PURPA costs, which ldaho Power proposes be included in base NPSE.
RESPONSE TO REQUEST NO. 2: The confidential Excel file contains the
Public Utility Regulatory Policies Act of 1978 (PURPA) costs and energy. The
attachment provided in response to this Request is confidential and will be provided on
the confidential CD to those parties that have signed the Protective Agreement in this
matter.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst
ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: Please provide workpapers and any related documentation to
determine the amount of Water for Power (Account 536) costs, which ldaho Power
proposes be included in base NPSE.
RESPONSE TO REQUEST NO. 3: The confidential attachments (Attachments
1-3) contain the documentation that supports the water for power expenses (Account
536). The attachments provided in response to this Request are confidential and will be
provided on the confidential CD to those parties that have signed the Protective
Agreement in this matter.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst
ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 4: Please provide workpapers that support the calculation of the
new LCAR rate shown in Exhibit No. 3.
RESPONSE TO REQUEST NO. 4: Please see the non-confidential CD for
Exhibit No. 4 from Case No. IPC-E-12-14 in which the $261 ,437,727 number found in
column A of Exhibit No. 3 was determined. There are no additional workpapers
regarding values in columns B-E.
The response to this Request is sponsored by Timothy E. Tatum, Senior
Manager of Cost of Service, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 5: Please provide workpapers supporting the calculation of
proposed 2013 base transmission costs (Account 565) of $5,455,955.
RESPONSE TO REQUEST NO. 5: Please see the non-confidential CD for the
Excel file supporting the calculation for the proposed 2013 base transmission costs
(Account 565) of $5,455,955.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst
!!, ldaho Power Company.
DATED at Boise, ldaho, this 3'd day of December 2013.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
Attorney for ldaho Power Company
CERTIFIGATE OF SERVICE
I HEREBY CERTIFY that on this 3'd day of December 20131 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Karl T. Klein
Deputy Attomey General
!daho Public Utilities Commission
47 2 W est Washington (83702 )
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
X Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email karl.klein@puc.idaho.qov
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email peter@richardsonadams.com
greq@richardsonadams.com
_Hand DeliveredX U.S. Mail
Overnight Mail
FAXX Email dreadinq@mindsprino.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. T
CERTIFICATE OF ATTORNEY
ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURING THE
COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDING
ARE PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-13-20
The undersigned attorney, in accordance with RP 233, hereby certifies that the
attachments provided in ldaho Power Company's responses to the ldaho Public Utilities
Commission Staffs Production Request Nos. 2 and 3 contain information that is a trade
secret or privileged or confidential as described in ldaho Code S 9-340, ef seg., and $
48-801, ef seg., and as such are exempt from public inspection, examination, or
copying.
DATED this 3'd day of December 2013.
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