20060905IPC to NWEC 1-10.pdf

IDAHO POWER COMPANY
O. BOX 70
BOISE, IDAHO 83707
BARTON L KLINE
Senior Attorney
An IDACORP Company
September 5, 2006
HAND DELIVERED
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
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Re:Case No. IPC-06-
Petition For Modification of Load Growth Adjustment
Rate Within the Power Cost Adjustment Methodology
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power Company
Response to the First production Request of NW Energy Coalition to Idaho Power
Company regarding the above-referenced matter.
I would appreciate it if you would return a stamped copy of this transmittal letter
to me in the enclosed self-addressed stamped envelope.
ilL
Barton L. Kline
BLK:sh
Enclosures
Telephone [phone] Fax [phone], E-mail BKline(ff)idahopower.com
BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Phone: [phone]
FAX: [phone]
bkline (fY idahopower.com
mmoen (fY idahopower.com
RECEIVED
2006 SEP -5 PH 4: ~ 7
IDAHO PU8UC
UTILITIES COMMISSION
Attorneys for Idaho Power Company
Express Mail Address
1221 West Idaho Street
Boise , Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR
MODIFICATION OF THE LOAD
GROWTH ADJUSTMENT RATE
WITHIN THE POWER COST
ADJUSTMENT METHODOLOGY
CASE NO. IPC-06-
IDAHO POWER COMPANY'
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF NW
ENERGY COALITION TO IDAHO
POWER COMPANY
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company") and , in
response to the First Production Requests of NW Energy Coalition to Idaho Power
Company dated August 8, 2006 , herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page
REQUEST FOR PRODUCTION NO.
Please state Idaho Power company s normalized system loads for each year
starting with year 1995 through 2005.
RESPONSE TO REQUEST FOR PRODUCTION NO.
Idaho Power company s normalized system loads for 1995 through 2005 in MWh'
are as follows:
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
14656029
15141574
15180588
14758836
15240817
15837958
15759779
14276689
14193837
14536634
14819152
The response to this request was prepared by Gregory W. Said, Manager of
Revenue Requirement, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 2
REQUEST FOR PRODUCTION NO.
Please explain the basis for Witness Greg Said's use of normalized system load to
calculate the current embedded PCA-related cost of serving load (which he states to be
$6.81/MWh), as opposed to using normalized firm system sales to calculate the same
figure..
RESPONSE TO REQUEST FOR PRODUCTION NO.
The Load Change Adjustment, as calculated in the Company s PCA Deferral
Report is based upon the change from Normalized System Load to Actual System
Load. It would be inappropriate to use an adjustment rate based upon sales unless the
growth measured was also based upon sales , i.e. a sales change adjustment rather
than a load change adjustment. Please also see the Company response to Staff
Request for Production No.
The response to this request was prepared by Gregory W. Said, Manager of
Revenue Requirement, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 3
REQUEST FOR PRODUCTION NO.
Please state Idaho Power Company s current average unit cost of serving load
growth.
RESPONSE TO REQUEST FOR PRODUCTION NO.
From the Company s perspective average unit cost is synonymous with embedded
cost. As stated in Mr. Said's testimony, the current embedded PCA related cost of
serving load is $6.81 per MWh.
The response to this request was prepared by Gregory W. Said , Manager of
Revenue Requirement, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 4
REQUEST FOR PRODUCTION NO.
Please state Idaho Power Company s total amount of spending on demand-side
management ("DSM") programs or initiatives (including payments to the Northwest
Energy Efficiency Alliance ("NEEA") for each year starting with year 1995 through 2005.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The following table details Idaho Power Company s total amount of spending on
demand-side management ("DSM") programs or initiatives (including payments to the
Northwest Energy Efficiency Alliance ("the Alliance )) for each year starting with year 1995
through 2005 as provided in the Company s respective DSM Annual Reports (previously
termed Conservation Plan) filed with the Commission.
Total System
(nominal $)
1995 $6 186 558
1996 $4 350 128
1997 $3 189 173
1998 $2 681 668
1999 $2 127 840
2000 $1 609 217
2001 $1 694 314
2002 $2 143 103
2003 $2,482 972
2004 $3 707 280
2005 $6 700 973
Notes:
Expenses are reported on a cash basis.
The response to this request was prepared by Tim Tatum , Senior Analyst, Idaho
Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 5
REQUEST FOR PRODUCTION NO.
Please state an estimate of Idaho Power Company s expected total amount of
spending on DSM programs or initiatives (including payments to NEEA) in 2006.
RESPONSE TO REQUEST FOR PRODUCTION NO.
Idaho Power Company s expected total amount of spending on DSM programs or
initiatives (including payments to the Alliance) in 2006 is $12 670 000.
The response to this request was prepared by Tim Tatum, Senior Analyst, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 6
REQUEST FOR PRODUCTION NO.
Please state the total amount collected by Idaho Power Company under Schedule
91 ("Energy Efficiency Rider") for each year starting with year 2002 through 2005.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The total amount collected by Idaho Power Company under Schedule 91 ("Energy
Efficiency Rider") on a system basis for each year starting with year 2002 through 2005 is
provided in the following table.
Idaho Power Company
DSM Rider Funds - GL Account 254201 & 254202
Idaho & Oregon Yearly Data from 2002-2005
2002 2003 2004 2005 2002-2005 Total
Idaho Rider
Funding 577 984.587 753.647,832.761 727.575 298.44
Interest 063.044.507.105 269.200 885.
Idaho Total 592 048.629,798.687 339.866 997.12,776 183.
Oregon Rider
Funding 101,742.10 1,7 42.42
Interest 3,475.3,475.
Oregon Total 105 217.105,217.
**Oregon Rider approved in August 2005. In August 2005 , $141 089.64 was transferred into the rider account from a
deferrral account. Year end available funding balance was $246,307.14.
The response to this request was prepared by Tim Tatum , Senior Analyst, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 7
REQUEST FOR PRODUCTION NO.
Please state an estimate of Idaho Power Company s expected total collections
under the Energy Efficiency Rider in 2006.
RESPONSE TO REQUEST FOR PRODUCTION NO.
Idaho Power Company s expected total collections under the Energy Efficiency
Riders in Idaho and Oregon in 2006 is approximately $8 740 979 based upon forecasted
normalized sales. Idaho customers are expected to provide approximately $8 334,415
and $406,564 is expected from Oregon customers.
The response to this request was prepared by Tim Tatum , Senior Analyst, Idaho
Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 8
REQUEST FOR PRODUCTION NO.
Please state the total amount of estimated energy savings (expressed as average
megawatts) Idaho Power Company and its customers have achieved as a result of DSM
programs (including any savingsj achieved as a result of NEEA programs) for each year
starting with year 1995 through 2005.
RESPONSE TO REQUEST FOR PRODUCTION NO.
The following table details the total amount of estimated energy savings
(expressed as average megawatts) Idaho Power Company and its customers have
achieved as a result of DSM programs (including any savings achieved as a result of
Alliance programs) for each year starting with year 1995 through 2005 as provided in the
company s respective DSM Annual Reports (previously termed Conservation Plan) filed
with the Commission.
Year
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
005
Annual Energy
Savings
excluding
Alliance
(Mwa)
2.42
Alliance
Reported
Energy
Savings *
(Mwa
29**
Total
Annual
Energy
Savings
(Mwa)
Notes:
Alliance Savings not available prior to 2004. The Alliance savings based on regional load allocation
percentage of 6.5%.
Preliminary estimate from the Alliance , February 24, 2006
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 9
The response to this request was prepared by Tim Tatum , Senior Analyst, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 10
REQUEST FOR PRODUCTION NO.
Please state the total amount of estimated energy savings (expressed as average
megawatts) Idaho Power Company and its customers are expected to achieve as a result
of DSM programs (including any savings achieved as a result of NEEA programs) in
2006.
RESPONSE TO REQUEST FOR PRODUCTION NO.
Idaho Power Company and its customers are expected to achieve energy savings
of approximately 3.6 average megawatts in 2006 as a result of DSM programs. This
estimate does not include savings achieved as a result of Alliance programs as such
estimate is not available to Idaho Power at this time.
The response to this request was prepared by Tim Tatum , Senior Analyst, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page
REQUEST FOR PRODUCTION NO.1 0:
Please provide any studies, reports, memoranda, or similar analyses which
estimate the potential energy or peak demand savings which may be achievable through
DSM programs in Idaho Power s service territory.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
Idaho Power objects to this request on the grounds that it does not specify any
timeframe for producing studies, reports, etc.This objection notwithstanding, the
enclosed CD contains copies of the studies , reports , etc. addressing the Company
most recent estimates of DSM potential.
The response to this request was prepared by Tim Tatum , Senior Analyst, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
DATED this 5th day of September, 2006, at Boise, Idaho.
1Et~
BARTOJ L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 5th day of September, 2006 , I served a true and
correct copy of the within and foregoing document upon the following named parties by
the method indicated below, and addressed to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
) U.S. Mail, Postage Prepaid
(X) Hand Delivered
) Facsimile
(X) Email Scottwoodbury(g)puc.idaho.qov
Peter J. Richardson
Richardson & O'Leary PLLC
515 N. 27'h Street
Boise, Idaho 83702
(X) U.S. Mail , Postage Prepaid
) Facsimile [phone]
(X) Email peter(gj richardsonandoleary.com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83702
(X) U.S. Mail , Postage Prepaid
) Facsimile
(X) Email dreadinq(g)mindsprinq.com
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701
(X) U.S. Mail, Postage Prepaid
) Facsimile
(X) Email billeddie(g)rmci.net
Nancy Hirsh
NW Energy Coalition
219 First Ave South , Suite 100
Seattle, Washington 98104
(X) U.S. Mail , Postage Prepaid
) Facsimile
(X) Email
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington, DC 20585
(X) U.S. Mail , Postage Prepaid
) Facsimile
(X) Email Lawrence.qollomp(g)hq.doe.qov
Dale Swan
Exeter Associates, Inc.
5565 Sterret Place, Suite 310
Columbia, MD 21044
(X) U.S. Mail, Postage Prepaid
) Facsimile
(X) Email dswan (g) exeterassociates.com
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Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF NW ENERGY COALITION TO IDAHO POWER COMPANY - Page 13