20020425IPC to Conservation Groups Nos. 1-5.pdf

LARRY D.RIPLEY ISB #965IdahoPowerCompany
P.O.Box 70
Boise,Idaho 83707Telephone:[phone]FAXTelephone:[phone]
Attorneyfor Idaho Power Company
Street Address for Express Mail:
1221 West ldaho Street
Boise,Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF IDAHO POWER COMPANY FOR AN )CASE NO.IPC-E-02-02ENERGYCOSTFINANCINGORDERAND)IPC-E-02-03AUTHORITYTOINSTITUTEANENERGY)COSTBONDCHARGE.)
)IDAHO POWER COMPANY'S
)RESPONSE TO FIRSTINTHEMATTEROFTHEAPPLICATION)PRODUCTION REQUESTOFIDAHOPOWERCOMPANYFOR)OF CONSERVATIONGROUPSAUTHORITYTOIMPLEMENTAPOWER)COSTADJUSTMENT(PCA)RATEFOR )ELECTRIC SERVICE FROM MAY 16,2002 )THROUGH MAY 15,2003.)
COMES NOW,Idaho Power Company ("Idaho Power"or "the Company"),
and in response to the First Production Requestof Conservation Groups dated April 18,
2002,herewith submits the following information:
REQUEST NO.1:On July 31,2001,Idaho Power filed a "Compliance
Filing"with the Idaho Public Utilities Commission ("PUC"or "Commission")in the case
of IPC-E-0-13.Does the ComplianceFiling accurately reflect the Company'scurrent
IDAHO POWER COMPANY'S RESPONSE TO FIRSTPRODUCTIONREQUESTOFCONSERVATIONGROUPS,Page 1
position with respect to the implementationof a tariff rider to fund demand-side
management("DSM")programs?If the Compliance Filing does not continue to reflect
the Company'scurrent position with respect to the implementationof a tariff rider to
fund DSM programs,pleaseexplainthe Company's changed position.
Response to Request No.1:Please refer to the testimonyof John R.
Gale filed in this proceeding.Essentially it is the Company'sposition that funding of
DSM activities remains the same as stated in ComplianceFiling,IPC-E-01-13.
The responses to the request for information were obtained from various
individuals within the Companyunder the general guidance of John R.Gale,Vice
President of Regulatory Affairs,and Larry D.Ripley,Senior Attorney,Idaho Power
Company.
REQUEST NO.2:Has the Company conducted or commissioned any
studies or other analyses to determine the amount of cost-effective DSM resources that
are available in its service territory,as expressedin total potentialenergy and/or
capacity savings?As used in this question,the term "cost-effective DSM resources"
means those DSM resources the cost of which is lower than that of the electricity supply
needed in their absence,based on a comparison of total resource cost.
Response to Request No.2:The Companyconducted studies
determiningthe amount of cost-effective DSM resources in its service territory in the
1990s.The Company has relied upon regional studies in the recent past.There are
other organizations in the region that have completedDSM resource studies or are
currently conducting them,some of which are partially funded by the Company.The
Northwest Energy Efficiency Alliance conducts market assessments for a broad array of
IDAHO POWER COMPANY'S RESPONSE TO FIRSTPRODUCTIONREQUESTOFCONSERVATIONGROUPS,Page 2
applicable energy efficiency markets.Also,the Companyis participating with the
Northwest Power Planning Councils to update the DSM resource assessment for the
Pacific Northwest.The Northwest Energy Coalition is currently conducting a regional
study of DSM potential.The Company believes that regional data can be examined and
then appropriately applied to its service territory,allowingcustomer funds to be
expendedin delivering actual DSM programs.
The responses to the request for information were obtained from various
individuals within the Company under the general guidance of John R.Gale,Vice
President of RegulatoryAffairs,and Larry D.Ripley,Senior Attorney,Idaho Power
Company.
REQUEST NO.3:Has the Companyconducted or commissioned any
other study or analysis to determine the extent of DSM resources that are available in
its service territory,as expressedin total potentialenergy and/or capacity savings?
Response to Request No.3:Please see response to RequestNo.2.
The responses to the request for information were obtained from various
individuals within the Company under the general guidance of John R.Gale,Vice
President of RegulatoryAffairs,and Larry D.Ripley,Senior Attorney,Idaho Power
Company.
REQUEST NO.4:In the ComplianceFiling,the Companyproposeda
DSM tariff rider of 0.5%of revenues,or approximately$2.6 million per year.Please
briefly describe the underlying rationale for this proposed DSM funding level.
Response to Request No.4:The Company currently funds DSM
programs at almost .5%of revenues.An additional .5%would representapproximately
IDAHO POWER COMPANY'S RESPONSE TO FIRSTPRODUCTIONREQUESTOFCONSERVATIONGROUPS,Page 3
1%funding of DSM programs.The Companybelieves that acceptance of the DSM
tariff rider will permit the Company to institute DSM programs on a rational and
economic basis.
The responses to the request for information were obtained from various
individuals within the Company under the general guidance of John R.Gale,Vice
President of Regulatory Affairs,and Larry D.Ripley,Senior Attorney,Idaho Power
Company.
REQUEST NO.5:In Order No.28894 ("Order"),at page 8,the
Commission ordered Idaho Power to use the BPA Conservation and Renewables
Discount credit to fund certain energy efficiency programs primarily targetedfor low
income and high energy usage customers.Please briefly describe the Company's
efforts to comply with this aspect of the Order,including by identifying the Company's
expendituresof the BPA Conservation and Renewables Discount credit and other
Company expenditures,and by describing the Company'simplementationof programs
as directed in the Order.
Response to Request No.5:Please see the Company'sresponse to
Requests Nos.7,9,and 13 of the Commission Staff's First Production Requestto Idaho
Power.
The responses to the request for information were obtained from various
individuals within the Company under the general guidance of John R.Gale,Vice
President of RegulatoryAffairs,and Larry D.Ripley,Senior Attorney,Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF CONSERVATION GROUPS,Page 4
Dated at Boise,Idaho,this 25th day of April,2002.
LARRY D.RKEY /
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF CONSERVATION GROUPS,Page 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 25th day of April,2002,I served a true
and correct copy of the above and foregoing IDAHO POWER COMPANY'S
RESPONSE TO FIRST PRODUCTION REQUEST OF CONSERVATION GROUPS
upon the followingnamed parties by the method indicated below,and addressed to the
following:
Lisa D.Nordstrom x Hand DeliveredDeputyAttorneyGeneral_U.S.Mail
Idaho Public Utilities Commission OvernightMail
472 W.Washington Street FAX
P.O.Box 83720
Boise,Idaho 83720-0074
R.Scott Pasley _Hand Delivered
Assistant General Counsel _x_U.S.Mail
J.R.SimplotCompany _OvernightMail
999 Main Street x FAX
P.O.Box 27
Boise,Idaho 83702
David Hawk Hand Delivered
Director,Energy Natural Resources U.S.Mail
J.R.SimplotCompany OvernightMail
999 Main Street x_FAX
P.O.Box 27
Boise,Idaho 83702
Peter J.Richardson Hand Delivered
Richardson &O'Leary,PLLC x U.S.Mail
99 East State Street,Suite 200 _OvernightMail
P.O.Box 1849 x FAX
Eagle,Idaho 83616
William M.Eddie Hand Delivered
Land and Water Fund of the Rockies U.S.Mail
P.O.Box 1612 OvernightMail
Boise,Idaho 83701 x FAX
LARRY D.IP
CERTIFICATE OF SERVICE