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HomeMy WebLinkAbout200401291st Request of Indus. Customers of Idaho Power to IPC.pdf, r- "'- ',~ ' - r '- . . . I ''-'...IL " f"l'--APeter J. Richardson RICHARDSON & O'LEARY PLLC 99 East State Street Eagle, Idaho 83616 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~ri chardsonando I eary. com iLEn 200!i 29 P11 I: 4(3 ) , L;:L1C ljTiU.:cS CGt"lHjSS!ON 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