20080604IPUC Motion to Admit Exhibits.pdf

UNITED STATES OF AMERICA
S. DEPARTMENT OF ENERGY
BEFORE THE
BONNEVILLE POWER ADMINISTRATION
2007 SUPPLEMENTAL WHOLESALE
POWER RATE ADJUSTMENT PROCEEDING ) BP A DOCKET WP-07 SUPP
MOTION OF THE IDAHO PUC TO ADMIT
TWO BP A DEEMER SPREADSHEETS INTO EVIDENCE
COMES NOW the Idaho Public Utilities Commission ("Idaho PUC") and
respectively moves the Hearing Officer for an Order admitting two exhibits into the record. The
two exhibits are portions of the BP A workpapers (printed Excel spreadsheets) prepared by BP
for its calculation of the purported deemer balances for Idaho Power Company and A vista
(formerly known as "Washington Water Power ). The following two exhibits have been marked
and filed on the BP A website:
WP-07-ID-4 is the Idaho Power deemer balance spreadsheets (for the
jurisdictions of Idaho, Oregon, and Nevada) and a one-page summary. The
Excel spreadsheets were prepared by BP A and included on a CD-ROM
created by BP A. This exhibit has 28 pages.
WP-07-ID-5 is the Avista deemer balance spreadsheets (for the jurisdictions
of Idaho and Washington) and a one-page summary. The Excel spreadsheets
were prepared by BPA and included on a CD-ROM created by BPA. This
exhibit has 16 pages.
WP-07-ID-4 and WP-07-ID-5 are portions of Excel spreadsheets that are
contained on the same CD-ROM. The CD-ROM is entitled "Bonneville Power Administration
2007 Supplemental Whole Power Rate Adjustment Proceeding(:J Revised Initial Proposal
Workpapers, Errata, and BPA's Responses to Data Requests PP-BPA-31 and JPG-BPA-41('J
March 20 2008." The two portions of spreadsheets marked as WP-07-ID-4 and WP-07-ID-
MOTION TO ADMIT INTO EVIDENCE
TWO BP A SPREADSHEETS WP-07-ID-
5 may be found on the CD-ROM by clicking on "Revised Initial Proposal CD " then "Work
Papers " and finally "Lookback" (D:\Revised Initial Proposed CD\Work Papers\Lookback). The
CD-ROM was distributed to the parties at the WP-07 "no surprises" workshop.
These exhibits were the subject of cross-examination to BP A panels 52, 62, 44, and
76. WP-07-TE (Vol. I, pp. 80-85-135-169). At the hearing, no party objected to their
admission into the record. WP-07-TE (Vol. I, pp. 172-, ll. 24-16). The Hearing Officer
indicated he was inclined to grant the Motion. Id. at p. 173.
For the foregoing reasons, the Hearing Officer should grant this Motion to Admit the
BP A workpapers regarding the calculations of the Idaho Power and A vista deemer balances
(WP-07-ID-4 and WP-07-ID-, respectively) into evidence and the administrative record in
this proceeding.
Respectfully submitted this fJ-day of June 2008.
FOR THE IDAHO PUBLIC UTILITIES COMMISSION
Donald L. Ho , II
Deputy Attorney General
PO Box 83720
472 W. Washington Street (83702-5918)
Boise, ID 83720-0074
Idaho State Bar No. 3366
Telephone No. [phone]
E-mail: don.howell~puc.idaho.gov
N:BPA- WPO7-Supp_dh2 Motion to Admit
MOTION TO ADMIT INTO EVIDENCE
TWO BP A SPREADSHEETS WP-07-ID-