20140320IPC to Staff 1-4.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
March 20,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-23
Approval of Special Contract with J. R. Simplot Company - 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 to
ldaho Power Company.
ln addition, enclosed are four (4) copies of a confidential disk containing
information responsive to Staffs production requests. Please handle the confidential
information in accordance with the Protective Agreement executed in this matter.
Sincerely,
X-,- C (,^ua.r--t
Lisa D. Nordstrdm
LDN:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
Idaho Powercompany iiiir, :'.::,;.:. i=,, .-.-,:: liJ-1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ idahopower. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF THE APPLICATION )oF IDAHO POWER COMPANY FOR ) CASE NO. rpC-E-13-23
APPROVAL OF A SPECIAL CONTRACT )
wrTH J.R. STMPLOT COMPANY. ) IDAHO POWER COMpANy',S
) RESPONSE TO THE FIRST
) PRODUCTTON REQUEST OF THE) coMMrssroN STAFF To IDAHO
) POWER COMPANY
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compaov"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated February 27,2014, 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 the actual load factors for 2011,2012 and
2013 by month for Schedule 19, Micron, Simplot (Pocatello) and DOE. Provide them in
a format similar to the load factor calculations on the "usage" tab in file "Schedule 33
Rate Design.xlsx" that the Company provided to Simplot.
RESPONSE TO REQUEST NO. 1: Please see the confidential Excel fib
provided on the confidential CD containing monthly historical load factors for the
requested customer classes for 2011 through 2013. Load factors were calculated
utilizing actual non-normalized historical loads at the customer level. The load factors
calculated for Schedule 19 reflect only those customers taking service at the primary
voltage level. Because the Company's historica! peak responsibility model identifies
non-coincident peak values for each rate schedule by voltage level (i.e., transmission,
primary, secondary), historical non-coincident peak values for the aggregated Schedule
19 rate class are not readily available. Consequently, ldaho Power calculated Schedule
19 load factors using only primary service level customers due to the number of
customers taking service at this voltage (approximately 100 customers) relative to
transmission voltage (2 customers) and secondary voltage (1 customer).
Because the Exce! file contains confidential customer information, it will only be
provided to those parties that have executed the Protective Agreement in place in this
matter.
The response to this Request is sponsored by Mike Youngblood, Regulatory
Projects Manager, 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 load factors for the same time period and in
the same format for the three plants that Simplot intends to close.
RESPONSE TO REQUEST NO. 2: Please see the confidential Excel file
provided on the confidential CD containing monthly historical load factors for J. R.
Simplot Company's ("Simplot") plants in Nampa, Aberdeen, and the previous plant in
Caldwell tor 2011 through 2013. Load factors were calculated utilizing actual non-
normalized historical loads at the customer level.
Because the Excel file contains confidential customer information, it will only be
provided to those parties that have executed the Protective Agreement in place in this
matter.
The response to this Request is sponsored by Mike Youngblood, Regulatory
Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: What have the loads and load factors been at the new facility
in Caldwell since it began operations? Provide the information in the format specified in
Production Request No. 1.
RESPONSE TO REQUEST NO. 3: Please see the confidential Excel file
provided on the confidential CD containing monthly historical load factors for the new
Simplot facility in Caldwell for the months of January through February 2014. Load
factors were calculated utilizing actual non-normalized historical loads at the customer
leve!.
Because the Excel file contains confidential customer information, it will only be
provided to those parties that have executed the Protective Agreement in place in this
matter.
The response to this Request is sponsored by Mike Youngblood, Regulatory
Projects Manager, 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: When is the load at the new facility expected to exceed 20
MW?
RESPONSE TO REQUEST NO. 4: ldaho Power does not know when Simplot's
total electric load for the new Simplot facility in Caldwell might exceed 20 megawatts.
However, based upon Simplot's request for additional capacity to be available by
January 31,2014, ldaho Power completed the facilities needed to provide the requested
capacity on January 8,2014.
The response to this Request is sponsored by Mike Youngblood, Regulatory
Projects Manager, ldaho Power Company.
DATED at Boise, ldaho, this 20h day of March 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
Attomey for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20th day of March 2014 I 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
Kristine A. Sasser
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
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Christa Bearry, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.6