20170111IPC to Micron 1-3.pdf

An IOACORP company
LISA D. NORDSTROM
Lead Counsel
[e-mail]
January 10, 2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-16-23
Revised Depreciation Rates for Electric Plant-In-Service
Dear Ms. Jewell:
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Enclosed for filing are an original and three (3) copies of Idaho Power Company's
Response to Request Nos. 1-1 through 1-3 of Micron Technology, lnc.'s First Data
Request to Idaho Power Company in the above matter.
Also enclosed are four ( 4) copies of a non-confidential disk containing information
being produced in response to Micron's Request Nos. 1-2 and 1-3.
If you have any questions about the enclosed documents, please do not hesitate to
contact me.
LDN/kkt
Enclosures
Very truly yours,
of~ilf(~
Lisa D. Nordstrom
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Idaho Power Company
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES )
DUE TO REVISED DEPRECIATION RA TES )
FOR ELECTRIC PLANT-IN-SERVICE. )
)
) ___________ )
CASE NO. IPC-E-16-23
IDAHO POWER COMPANY'S
RESPONSES TO REQUEST NOS.
1-1 THROUGH 1-3 OF THE FIRST
DATA REQUEST OF MICRON
TECHNOLOGY, INC. TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to Request Nos. 1-1 through 1-3 of the First Data Request of Micron
Technology, Inc. to Idaho Power Company dated January 3, 2017, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSES TO REQUEST NOS. 1-1 THROUGH 1-3 OF THE
FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 1
REQUEST NO. 1-1: Provide all data requests and responses received from or
sent to other parties in this proceeding. This is an ongoing request.
RESPONSE TO REQUEST NO. 1-1: To date, Idaho Power has not received
any data requests from any other parties in this proceeding. As a matter of course,
copies of Idaho Power's responses to discovery requests in this case will be provided to
all intervening parties. Please note that the language of each request precedes Idaho
Power's response.
The response to this Request is sponsored by Kimberly Towell, Executive
Assistant, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO REQUEST NOS. 1-1 THROUGH 1-3 OF THE
FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 2
REQUEST NO. 1-2 Please provide all property data utilized in the depreciation
study, including additions, retirements, cost of removal, and salvage data. Please
provide this data by account, placement, and experience year since the date of
inception. Please include all transaction codes and a description of each transaction
code. This data should allow for the reconstruction of the analysis and calculations
performed as part of the depreciation study. Please provide this information in Excel
format with formulae intact.
RESPONSE TO REQUEST NO. 1-2: Please see Attachment Nos. 1-3 on the
enclosed CD for the data Idaho Power Company used to develop the depreciation
rates.
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO REQUEST NOS. 1-1 THROUGH 1-3 OF THE
FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 3
REQUEST NO. 1-3: Please provide all workpapers, schedules, tables, and
exhibits used in the depreciation study or relied upon in conducting the depreciation
study in Excel format with formulae intact where applicable.
RESPONSE TO REQUEST NO. 1-3: Please see Attachment Nos. 1-5 on the
enclosed CD for the data Idaho Power Company used to develop the depreciation
rates.
The response to this Request is sponsored by Donna Wheeler, Finance T earn
Leader, Idaho Power Company.
DATED at Boise, Idaho, this 1 otti day of January 2017.
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSES TO REQUEST NOS. 1-1 THROUGH 1-3 OF THE
FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY GERTI FY that on the 10th day of January, 2017, I served a true and
correct copy to IDAHO POWER COMPANY'S RESPONSES TO REQUEST NOS. 1-1
THROUGH 1-3 OF THE FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC.
TO IDAHO POWER COMPANY the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Micron Technology, Inc.
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Brian T. Hansen
HOLLAND & HART, LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, Colorado 80111
Pete Bennett
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
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IDAHO POWER COMPANY'S RESPONSES TO REQUEST NOS. 1-1 THROUGH 1-3 OF THE
FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 5
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
United States Department of Energy and
Federal Executive Agencies
Steven Porter
Office of the General Counsel (GC-76)
The United States Department of Energy
1000 Independence Avenue, SW (Room 6D-033)
Washington, D.C. 20585
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IDAHO POWER COMPANY'S RESPONSES TO REQUEST NOS. 1-1 THROUGH 1-3 OF THE
FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER COMPANY - 6