20150414Staff 1-2 to IPC.pdf

KARL T. KLEIN , ..-' ,, i. ' I
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES coMMISSIoN ?l li I i'il I i frti lil' 0 I
PO BOX 83720 ,r j,., ,
BOISE, IDAHO 83720-0074 ,,-i ll, I'i , r;'"' i. ' ' .': i ' '
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702.5918
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF rDAHO POWER )
coMpANy's APPLICATION FOR APPROVAL ) CASE NO. IPC-E-15-13
OF SPECIAL CONTRACT AND TARIFF )
SCHEDULE 32 TO PROVIDE ELECTRIC ) rIRSr pRODUCTION
SERVICE TO J. R. SIMPLOT COMPANY'S ) pTQUEST OF THE
CALDWELL FACILITY. ) COvTMISSION STAFF TO
) TUA.UO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Company) provide the following documents and information as soon as possible, by FRIDAY,
APRIL 24,2015.1
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 APRIL I4,2OI5
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: In Commission Order No. 33038, the Commission directed the
parties to use the Company's most recent cost-of-service study as the starting point for
determining an appropriate rate. Please provide workpapers and calculations showing the figures
extracted from the 2011 Cost of Service Study, and how they were used in deriving the rates
shown in the contract. Also, please provide workpapers showing how any changes that have
occurred since the 2011 Rate Case were accounted for in deriving the contract rates presented in
Schedule 32.
REQUEST NO.2: How did the Company arrive at allocation factors used to determine
rates shown in the Schedule 32? Inparticular, how did the Company determine the 3CP/l2CP
and l2CP allocators used to allocate transmission and production demand costs?
DATED at Boise, Idaho, this I tt L day of April2015.
Karl T. Klein
Deputy Attorney General
Technical Staff: Mike Morrison
i:umisc:prodreq/ipcel 5. l3kkmm prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY APzuL 14,2OI5
I HEREBY CERTIFY THAT I
SERVED THE FOREGOING FIRST
COMMISSION STAFF TO IDAHO
IPC-E-I5-13, BY MAILING A COPY
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE tD 83707-0070
E-mail: [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail : [e-mail]
sre sfarichard sonadams. com
CERTIFICATE OF SERVICE
HAVE THIS I4TH DAY OF APRIL 2015,
PRODUCTION REQUEST OF THE
POWER COMPANY, N CASE NO.
THEREOF, POSTAGE PREPAID, TO THE
MICHAEL YOUNGBLOOD
TDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
DON STURTEVANT
DIR-ENERGY PURCHASING
JR SIMPLOT COMPANY
PO BOX 27
BOISE ID 83707-0027
EMAIL: [e-mail]
CERTIFICATE OF SERVICE