200401291st Request of Indus. Customers of Idaho Power to IPC.pdf

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f"l'--APeter J. Richardson
RICHARDSON & O'LEARY PLLC
99 East State Street
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
peter~ri chardsonando I eary. com
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Attorneys for the Industrial Customer of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO PO~R COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE STATE
OF IDAHO
FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL
CUSTOMERS OF IDAHO PO~R
TO IDAHO PO~R COMPANY
CASE NO. IPC-03-
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission ), the Industrial Customers ofIdaho Power (ICIP) , by and through their
attorney of record, Peter J. Richardson, hereby request that Idaho Power Company ("Idaho
Power ) provide the following documents.
This production request is to be considered as continuing, and Idaho Power 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.
Please provide one copy of your answer to Mr. Richardson at the address noted above and
one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703.
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 at hearing who can sponsor the answer.
1 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO.
Please provide any and all IPC data and analyses projecting the monthly billing impact on
each Schedule 19 customer of the proposed mandatory time-of-use rates for a full 12 month
calendar cycle.
REQUEST FOR PRODUCTION NO.
Please provide any and all data and analyses of the benefits, savings and increased
revenues from implementation of mandatory time-of-use rates for Schedule 19 versus other IPC
rate classes.
REQUEST FOR PRODUCTION NO.
Please provide any and all data and analyses of the benefits, savings and increased
revenues from implementation of mandatory time-of-use rates for any other rate class.
REQUEST FOR PRODUCTION NO.
With reference to Request for Production No., if no such analysis was conducted for
any other rate class, please explain why not.
REQUEST FOR PRODUCTION NO.
Please provide any and all data and analyses supporting mandatory time-of use rates for
the Schedule 19 rate class only
REQUEST FOR PRODUCTION NO.
Please provide any and all data and analyses that demonstrate that Schedule 19 customers
are responsible versus other IPC rate classes for IPC's need for new peaking resources.
2 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO.
Please explain IPC's rationale including data and analyses in proposing rates that place
more fixed costs in demand and customer charges rather than keeping them in the energy charge.
REQUEST FOR PRODUCTION NO.
Please provide any and all data and analyses used to determine which distribution
facilities and customer service related expenses do not vary with the amount of energy being used
and are proposed to be removed from the energy charge and placed in the proposed Service
Charge for all IPC rate classes.
REQUEST FOR PRODUCTION NO.
Please provide any and all data and analyses that support IPC's request to change the
Power Factor Adjustment provisions in proposed Schedules 9, 19, and 24 that increases the
minimum power factor from 85% to 90%.
REQUEST FOR PRODUCTION NO.1 0:
By what standard does Ms. Brilz' conclude that a customer power factor between 85%
and 90% is "poor
REQUEST FOR PRODUCTION NO. 11:
Please provide monthly billing records from 1993 to 2003 for all Schedule 19 customers.
REQUEST FOR PRODUCTION NO. 12:
Please provide any and all analyses IPC plans to use to calculate "the amount of capacity
required" at a single point of delivery as stated in Ms. Brilz' testimony regarding changes to Rule
C. Reference Ms. Brilz' testimony at page 31.
3 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 13:
Please provide copies of all records, including Records of Decisions, RODs, connected
load data, Uniform Large Service Agreements, and separate agreements for special arrangements
for service requests for added or new loads from current or new Schedule 19 customers from
1993 through 2003.
REQUEST FOR PRODUCTION NO. 14:
Please provide records that show location and size of service transformers for all
Schedule 19 customers.
REQUEST FOR PRODUCTION NO. 15:
Please provide copies of the SCE, PG&E and CSU pricing schedules as referenced in M.
Brilz' testimony.
REQUEST FOR PRODUCTION NO. 16:
Please provide copies of records of all Contributions-in-Aid-of Construction for
substation and transmission facilities requested by Idaho Power Company from 1993 to 2003.
REQUEST FOR PRODUCTION NO. 17:
Please provide copies of records of all Contributions-in-Aid-of Construction paid by
Idaho Power Company customers from 1993 to 2003.
REQUEST FOR PRODUCTION NO. 18:
Please provide copies of all records of the amount of substation and transmission CIAC
collected from 1993 to 2003 that was allocated to the Schedule 19 rate class.
REQUEST FOR PRODUCTION NO. 19:
Please provide copies of all records of "net plus CIAC" data and analyses. Reference
page 24 of Ms. Brilz testimony.
4 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 20:
Please provide copies of all documents that detail and identify the "non-interruptible
seasonal loads" referenced in Mr. Said's testimony.
REQUEST FOR PRODUCTION NO. 21:
Please provides the anniversary dates of all Schedule 19 customers.
REQUEST FOR PRODUCTION NO. 22:
Please provide a copy of the bill form for the proposed Schedule 19 mandatory time-of-
use rate.
REQUEST FOR PRODUCTION NO. 23:
Please provide data and analyses that document the change in annual system load factor
for each year from 1993 to 2003.
REQUEST FOR PRODUCTION NO. 24:
Please provide data and analyses that document the change in annual load factor for each
rate schedule for each year from 1993 to 2003.
REQUEST FOR PRODUCTION NO. 25:
Please provide all data and analyses for classification of distribution accounts 364, 365
366, 367 and 368 including data and analyses used in developing classification factors for these
accounts.
REQUEST FOR PRODUCTION NO. 26:
Please provide copies of all customer satisfaction surveys from 1993 to 2003.
REQUEST FOR PRODUCTION NO. 27:
Please provide copies of any and all documents detailing efforts to improve customer
relations with Schedule 19 customers.
5 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 28:
Please provide by year from 1993 to 2003 copies of all conservation, demand side
management and renewable energy programs executed by Idaho Power.
REQUEST FOR PRODUCTION NO. 29:
Please provide all data and analyses documenting costs and results of all conservation
demand side management and renewable energy programs executed by Idaho Power from 1993
to 2003.
REQUEST FOR PRODUCTION NO. 30:
Please provide monthly load profile reports for all rate schedules for 2003.
REQUEST FOR PRODUCTION NO. 31:
Please provide lists of any and all costs referred to as "fixed and unrelated to usage
patterns" referred to in Ms. Brilz' testimony.
REQUEST FOR PRODUCTION NO. 32:
Please provide a list of all Schedule 19 customers by District Office and or Region.
REQUEST FOR PRODUCTION NO. 33:
Please provide data and analysis supporting any and all changes proposed for Rule H.
REQUEST FOR PRODUCTION NO. 34:
Please explain the rationale for closing the option of Schedule 25 to new participants
while at the same time proposing a mandatory TOU for Schedule 19 customers.
REQUEST FOR PRODUCTION NO. 35:
Please explain Idaho Power s rationale for proposing a new Schedule 19 rate that can
have as many as 3 demand charges on one monthly bill.
6 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 36:
Please provide records of any and all meetings and/or discussions Idaho Power has had
with Schedule 19 customers as a group regarding the proposed changes in Schedule 19.
REQUEST FOR PRODUCTION NO. 37:
Please provide copies of any and all data and analyses documenting the potential
economic impact on Idaho s economy of the proposed Schedule 19 changes.
REQUEST FOR PRODUCTION NO. 38:
Please explain the contractual process required of Schedule 9 and Schedule 19 customers
as their capacity requirement increases above 1000KW or drops below 1000KW respectively.
REQUEST FOR PRODUCTION NO. 39:
Please provide copies of any and all data and analyses that support keeping the
relationship between Schedule 9 and Schedule 19 Basic and Demand charges the same for
different service levels.
REQUEST FOR PRODUCTION NO. 40:
Please provide copies of any and all data and analyses that support the overall increase of
24% for Primary and Transmission service level customers for Schedule 9 customers.
REQUEST FOR PRODUCTION NO. 41:
Please provide copies of any and all data that support Schedule 9 and Schedule 19 having
the same Basic charge for primary and Transmission service.
REQUEST FOR PRODUCTION NO. 42:
Please provide copies of any and all data that support Schedule 9 and Schedule 19 having
the same Non-Summer Demand charge for primary and Transmission service.
7 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 43:
Please provide any and all data and analyses that support the proposal for no seasonality
in the Basic and Service Charge for Schedule 9 and 19.
REQUEST FOR PRODUCTION NO. 44:
Please provide any and all data and analyses supporting Idaho Powers selection of the
proposed time blocks for Schedule 19.
REQUEST FOR PRODUCTION NO. 45:
Please provide any and all data and analyses supporting Idaho Powers selection of June
July and August as Summer Months and the remaining months of the year as Non-Summer
Months.
REQUEST FOR PRODUCTION NO. 46:
Please provide any and all data and analyses used to calculate the energy charges for
Schedule 19 for Summer and Non-Summer Months.
REQUEST FOR PRODUCTION NO. 47:
Please provide copies of any and all data and analyses Idaho Power proposes to use to
anticipate a customer s need that immediately exceeds 1O00KW as referenced in Ms. Brilz
testimony.
REQUEST FOR PRODUCTION NO. 48:
Please provide copies of all of Idaho Power s Distribution Reliability Indices records
from 1993 to 2003.
8 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 49
Has Idaho Power ever developed a method for weather normalization of peak loads?
, please provide copies of all such studies.
REQUEST FOR PRODUCTION NO. 50:
Was weather normalization of peak loads used in the preparation of this rate case? If not
please fully explain why not.
REQUEST FOR PRODUCTION NO. 51:
Does the Company anticipate any future use of weather normalization of peak loads?
not please explain fully why not.
REQUEST FOR PRODUCTION NO. 52.
Please explain how peak load data was used in this rate case filing that would impact the:
Estimates of Revenue Requirement; and
Estimates of Class Cost of Service Assignments.
REQUEST FOR PRODUCTION NO. 53:
Please provide monthly operating hours and MWh production from the Danskin Station
from its on line date to the present. (Response to Staff 3rd set has a total of 104 721 for the
period from being on-line and Oct. 2003, please provide the monthly Mwh output from the
online date to Oct 2003, and please provide the monthly Mwh output from the online date and
the latest month available.
REQUEST FOR PRODUCTION NO: 54:
Please indicate for the date provided in response to No. 53 above, for each month, how
much was used to serve native load and how much was generated for off system sales. For the
generation used for off system sales please provide the price received for that power.
9 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 55:
Reference to Exhibit 33 , page 1 , line 14: Please fully explain the charge identified as
Fixed Capacity Charge - Gas Transportation ($ x 1000)"
REQUEST FOR PRODUCTION NO. 56:
Line 13 on page one of Exhibit 33 is labeled "Cost ($x 1 000). Is this the cost of gas
needed to generate the output listed on line 12 on the same page? Ifnot please fully explain the
import of the quoted language.
REQUEST FOR PRODUCTION NO. 57:
Please fully document the planning process for construction of the Danskin Station.
Include copies of all company memoranda, planning studies, minutes from meetings (at Board of
Directors level and below) at Idaho Power, IdaCorp and IdaCorp Energy Services.
REQUEST FOR PRODUCTIN NO. 58:
Please provide copies of all communications between Idaho Power and IdaCorp Energy
Services regarding the Danskin Station.
REQUEST FOR PRODUCTION NO. 59:
What consumer groups were contacted during the planning phase for the Danskin Station.
Please provide copies of all communications with said consumer groups.
REQUEST FOR PRODUCTION NO. 60:
Please describe and document the public involvement engaged in by Idaho Power during
the planning phase for the Danskin Station.
REQUEST FOR PRODUCTION NO. 61:
Who made the final decision to construct the Danskin Station?
10 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
REQUEST FOR PRODUCTION NO. 62:
Does Idaho Power expect to add any capacity to the Danskin Station? If so, how much
additional capacity and when would the additional capacity be brought on line?
DATED this 29th day of January 2004.
RICHARDSON & O'LEARY PLLC
By.
.;;L
Peter J. Richardson, ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
11 - FIRST PRODUCTION OF THE ICIP TO IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the~~day of January, 2004, a true and correct copy of
the within and foregoing INDUSTRIAL CUSTOMERS OF IDAHO POWER'S FIRST
PRODUCTION REQUEST TO IDAHO PO~R, Case No. IPC-03-, was hand-delivered
to each of the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707
IDAHO POWER COMPANY
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83702
COMMISSION STAFF
and mailed. postage prepaid to the following
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge
Bailey, Chartered
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington, DC 20585
THE UNITED STATES
DEPARTMENT OF ENERGY
Certificate of Service - IPC- E-03-l3 and 13A
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
Dean 1. Miller
McDevitt & Miller LLP
PO Box 2564
Boise, ID 83701
Jeremiah J. Healy
United Water Idaho, Inc.
PO Box 190420
Boise, ID 83719-0420
William M. Eddie
Advocates for the West
PO Box 1612
Boise, ID 83701
Nancy Hirsh
NW Energy Coalition
219 First Ave. South, Suite 100
Seattle, W A 98104
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
PO Box 2720
Boise, ID 83701-2720
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste 250
Salem, OR 97302
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
CERTIFICATE OF SERVICE
UNITED WATER IDAHO, INC
NW ENERGY COALITION
MICRON TECHNOLOGY, INC
AARP
Thomas M. Power
Economics Department
Liberal Arts Bldg. 407
University of Montana
32 Campus Drive
Missoula, MT 59812
Brad M. Purdy
Attorney at Law
2019N.Street
Boise, ID 83702
Michael Karp
147 Appaloosa Lane
Bellingham, W A 98229
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
Boehm, Kurtz & Lowry
36 E. Seventh Street, Suite 2110
Cincinnati, OH 45202
CERTIFICATE OF SERVICE
COMMUNITY ACTION P ARTNER-
SHIP ASSOCIATION OF IDAHO
KROGER COMPANY
~K1. Cvf\~
Nina M. Curtis
Legal Assistant