20011120Staff 1-7 to IPC.pdf

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E}nSCOTT WOODBI.]RY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
BAR NO. 1895
Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPAI\Y FOR APPROVAL
OF A NEW SCHEDI]LE 84 - NET METERING.
CASE NO.IPC.E.O1.39
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER
COMPAI\"Y
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Scott Woodbury Deputy Attomey General, requests that Idaho Power Company (Company; IPC)
provide the following documents and information on or before FRIDAY, DECEMBER 7, 2001.
This Production Request is to be considered as continuing, and Idaho Power 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 produced.
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person(s) and the witness who can sponsor the answer at hearing.
Request No. 1: Please explain why the Company is proposing to restrict Schedule 84
eligibility to Schedule 1 and Schedule 7 customers only.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 NOVEMBER 20, 2OO1
Request No. 2: Would any kWh credits remaining or unused at the end of a calendar
year be granted to the Company without compensation to the customer-generator, or could kWh
credits be carried by the customer-generator indefinitely? Under what conditions would Idaho
Power provide cash compensation for customer generation?
Request No. 3: Please explain how kWh credits would be determined under the current
block rate design for Schedule I customers. For example, will kWh credits be calculated at the
average rate for the residential class or at one or more of the three rates in the block rate design?
Please clariff using examples as appropriate.
Request No. 4: Please confirm whether existing Schedule 86 customers would be
moved to the new Schedule 84. Will Schedule 86 customers be required to execute a new
Schedule 84 contract?
Request No. 5: Because Idaho Power intends to use only one meter for net metering
customers, only the net difference between customer generation and usage will be read each
month. Consequently, for Schedule 1 customers, Staff assumes that generation will be credited
first against usage in the highest rate block and last against usage in the lowest rate block. Is
Staff s assumption correct? If not, please explain.
Request No. 6: Does Idaho Power believe that by crediting customer generation at full
retail rates, net metering customers will be paid more than the actual value of their generation? If
so, what is the justification for payng full retail rates?
Request No. 7: If a net metering customer fully offsets his monthly usage with his own
generation, will Idaho Power be able to fully recover its cost of providing service with only
revenue from the customer charge?
DATED at Boise, Idaho, ,^, $day of November 2OOl.
Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
SW:RPS/umisc/prdreqVipce0 1.39swrps
FIRST PRODUCTION REQUEST
TO IDAHO POWER
2 NOVEMBER 20, 2OO1
CERTIFICATE OF SERVICE
I IIEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF NOVEMBER 2001,
SERVED TIIE FOREGOING FIRST PRODUCTION REQTIEST OF THE
COMIVtrSSION STAFT TO IDAIIO POWER COMPAI\IY, IN CASE NO. IPC-E-OI.
39, BY MAILING A COPY TIIEREOF, POSTAGE PREPAID, TO TIIE FOLLOWING:
BARTON L KLINE
SEMORATTORNEY
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
MAGGIE BRILZ
DIRECTOR OF PRICING
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
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CERTMICATE OF SERVICE