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HomeMy WebLinkAbouthuntington-ipc_cc2.doc VIA FED EX December 29, 1999 Mary Ann Huntington Morgan, Lewis & Bockius, LLP 1800 M Street N.W. Washington, D.C. 20036-5869 RE: IPUC Discovery Responses to Arizona Public Service Co. Dear Mary Ann, Enclosed are the IPUC discovery responses to APS/IPUC-1 through APS/IPUC-9. I apologize for initially overlooking your request. It apparently was faxed as part of your discovery requests to Idaho Power and not discovered until your call. After reviewing our files, I determined that we never received a hard copy. I am continuing to review our files to ensure that all the documents are provided. I believe that I have found all of them. Sincerely, Cheri C. Copsey Deputy Attorney General cc: Honorable H. Peter Young All parties L:\huntington-ipc_cc2 IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC-1 Prepared by: Keith Hessing – IPUC Engineering Section Request: List all of Idaho’s retail customers that have non-firm loads and the MW amount of such loads. Response: The IPUC is unaware of any Idaho Power retail customers that have non-firm loads. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC-2 Prepared by: Keith Hessing – IPUC Engineering Section Request: List all of Idaho’s retail customers that have interruptible loads and the MW amount of such loads. Response: The IPUC is unaware of any Idaho Power retail customers that have interruptible loads. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC -3 Prepared by: Keith Hessing – IPUC Engineering Section Request: List all of Idaho’s retail customers that have curtailable loads and the MW amount of such loads. Response: When there are resource deficiencies in Idaho Power’s system, all retail loads are subject to the IPUC ordering curtailment. However, the IPUC understands the FMC-Idaho Power contract to allow Idaho Power to temporarily shed all of FMC’s load except for 17 MW (250 MW total load) without additional IPUC action only during emergency conditions to avert system-wide problems on Idaho Power’s transmission system or to maintain system integrity. The IPUC also understands this contract to impose an obligation on Idaho Power to restore FMC’s load as soon as possible. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC -4 Prepared by: Lynn Anderson – IPUC Policy Analyst Request: Does Idaho have any customers under a demand side management program? If so, list all such customers and the MW amount of the associated load. Response: While Idaho Power has had a number of programs designed to reduce energy consumption through conservation, it has not utilized any programs that allow it to change its underlying obligation to provide service by interrupting that service in an effort to reduce energy load. In addition, Idaho law does not require Idaho Power to provide the IPUC with lists of customer who take advantage of various conservation programs. Therefore, the IPUC does not have any such lists. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC-5 Prepared by: Keith Hessing – IPUC Engineering Section Request: Provide copies of all documents relating to Idaho Power Company’s service to FMC, including but not limited to all existing and previous agreements for the provisions of electric service. Response: Attached are the documents requested with the exception of certain quarterly reports more particularly described below which the IPUC asserts it is prohibited by Idaho law from disclosing. In Order No.  27463, the Commission ordered Idaho Power to file quarterly reports designed to monitor revenue generated from FMC’s purchase of its second block of power to determine its impact on Idaho Power revenue sharing. Those reports began being filed on September 30, 1998. The reports are filed as Confidential-Proprietary documents and contain proprietary revenue information. The IPUC asserts that this information is proprietary and confidential and under Idaho law, Idaho Code §9-340, exempt from disclosure. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC-6 Prepared by: Keith Hessing – IPUC Engineering Section Request: Provide copies of all documents relating to the Idaho Power Company’s service to interruptible or curtailable customers. Response: See responses to APS/IPUC-2 and APS/IPUC-3 and the data responses to APS/IPUC-5. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC-7 Prepared by: Keith Hessing – IPUC Engineering Section Request: Provide copies of all documents relating to resource plans for Idaho Power Company, including but not limited to Idaho Power Company’s most recent integrated resource plan. Response: Attached are the documents requested. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC-8 Prepared by: Keith Hessing – IPUC Engineering Section Request: Provide copies of all documents relating to the Idaho Power Company’s load projections and forecasts. Response: To the extent that the IPUC has these documents, they are contained in the documents attached in response to APS/IPUC-7. IDAHO PUBLIC UTILITIES RESPONSE TO DATA REQUEST APS/IPUC-9 Prepared by: Keith Hessing – IPUC Engineering Section Request: Provide a copy of Idaho Power Company’s 1999 Long-term Financial Sales and Load Report. Response: On August 27, 1999, the IPUC granted a request by Idaho Power to waive its 1999 filing and to allow it to file its new IRP in 2000. Order No.  27700. Attached are copies of that case file – Case No. IPC-E-99-11.