200401131st Request of NW Energy to ID Power.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ill 83701
[phone]
fax: [phone]
billeddie~rmci.net
F~ECEJVEO 7
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2DD~ JAN 13 M.1 11: 54
iLi"JU I ; ICJ rlLiTiES COrit~fISSION
Express Mail:
1320'W. Franklin St.
Boise, ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS INTERIM
AND BASE RATES AND CHARGES FOR
ELECTRIC SERVICE
CASE NO.IPC-03-
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION
Intervenor NW Energy Coalition, by and through counsel, requests that Idaho Power
Company ("Idaho Power" or "Company ) provide the following infoID1ation.
This Production Request is considered to by continuing, and the Company is requested to
provide, by way of supplementary responses, additional documents or information that it or any
person acting on its behalf may later obtain that will augment the information or documents
produced.
In answering each request, please provide the name of the person(s) preparing the
answers , along with the title and function such individual holds with the Company and the
witness who can sponsor the answer at the hearing.
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 1
REQUEST NO.1: For each customer class, how much of the proposed 2003
Test Year revenue requirement represents distribution and customer fixed costs
transmission fixed costs, and generation fixed costs, respectively? For each customer
class, how much of those fixed costs would be recovered from: (1) volumetric energy
charges; (2) demand charges; and (3) fixed charges, respectively? How would the
numbers change if fixed charges were set at existing levels rather than at the company
proposed levels?
REQUEST NO.2: For each customer class, please provide the annual rate
increase or decrease associated with the company s Power Cost Adjustment over each of
the last five years.
REQUEST NO.3: Please provide actual and normalized retail electricity sales
by customer class over each of the past ten years.
REQUEST NO.4: Please provide any work papers supporting the Company
request for a $10 customer charge for the residential customer class.
D~OTT~~T NO
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costs associated with meter reading and billing.
REQUEST NO.6: What components of the Company s fixed costs of service
are covered by the $10 customer charge for the residential class?
REQUEST NO.7: Please provide the number ofIdaho Power residential
customers residing in each of the different types of homes: single family homes, multi-
family buildings, and trailer/mobile home parks.
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 2
REQUEST NO.8: What are the Company s relative distribution and customer
costs incurred in serving different types of residential customers (e.
g.
single family
residence, multi-family buildings , and trailer/mobile home parks)?
REQUEST NO.9: Please provide any studies or information showing the
predicted impact on peak demand of the Company s higher customer charge for
residential customers.
REQUEST NO. 10: Has the Company conducted any surveys of customers to
determine suppOli or opposition to the higher residential customer charge? If the
Company has conducted such surveys, please provide the results.
DATED this 13th day of January, 20p4. G
.' .'
\ il/
William M. Eddie
On behalf ofNW Energy Coalition
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this 13 TH day of January 2004, true and correct copies of
the foregoing FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION were
delivered to the following persons via hand delivery (for Commission and Idaho Power
recipients) and u.S. Mail (for all others):
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W.Washington
Boise, ID 83702
Randall Budge
Eric Olsen
Racine, Olson, et al.
O. Box 1391
Pocatello, ill 83204-1391
Lisa Nordstrom
Weldon Stutzman
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W.Washington
Boise, ID 83702
Anthony Yanke1
29814 Lake Road
Bay Village, OH 44140
Barton Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Lawrence Gollomp
Assistant General Counsel
S. Dept. of Energy
1000 Independence Ave., SW
Washington, DC 20585
Delmis Goins
Potomac Management Group
5801 Westchester St.
Ti"\hn R r..",l",~VL~L~~. '-Ju.L'-'Alexandria, VA 22310-1149
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Dean Miller
McDevitt & Miller
O. Box 2564
Boise, ID 83701Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ID 83703
Jeremiah Healy
UnitedWater-Idaho
O. Box 190420
Boise, ID 83719-0420Don Reading
Ben J ollison Associates
6070 Hill Road
Boise, ID 83703
Conley Ward
Givens Pursley
O. Box 2720
Boise, ID 83701-2720
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 4
Dennis Peseau
Utility Resources
1500 Liberty St, S.
Suite 250
Salem, OR 97302
Thomas Power
Economics Dept.
Liberal Arts Bldg. 407
University of Montana
32 Campus Drive
Missoula, MT 59812Brad Purdy
2019 N. 1 ih St.
Boise, ID 83702 Michael Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
36 E. Seventh St., Suite 2110
Cincinnati, OH 45202(L--
Michael Karp
147 Appaloosa Lane
Bellingham, W A 98229
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 5