20080328Staff to IPC 1-15.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 i 8
BARNO. 3283
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO IMPLEMENT FIXED COST ADJUSTMENT )
(FCA) RATES FOR ELECTRIC SERVICE )
FROM JUNE 1, 2008 THROUGH MAY 31, 2009. )
)
)
)
CASE NO. IPC-E-08-4
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
MONDAY, APRIL 14,2008.
This Production Request is to be considered as continuing, and Idaho Power Company 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.
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 who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY i MARCH 28, 2008
REQUEST NO.1: What were the fixed costs per customer (FCC) for the residential and
small general service customers for 20077 What were the resulting fixed costs per energy (FCE)
for each customer class?
REQUEST NO.2: How did the Company determine the FCC and FCE for 2007 based
on the settlement of Case No. IPC-E-05-8, the general rate case? Please provide all workpapers
used to determine the FCC and FCE in 2007 in executable format, with formulas intact.
REQUEST NO.3: Insofar as not provided in response to Production Request No.2,
please provide executable versions of Youngblood Exhibits 2-6, with formulas intact. Should
there be links to other worksheets, provide the other worksheets as well.
REQUEST NO.4: Please provide all workpapers, in executable format, used to
determine monthly customer counts for the 2007 calendar year and the 2008 calendar year.
REQUEST NO.5: Please provide all workpapers, in executable format, for the weather
normalization methodology used to calculate actual fixed costs recovered for 2007. Does the
methodology differ from that used in determining weather normalized energy for the test year
used in Case No. IPC-E-05-8? If so, please explain the differences, and provide the weather
normalization study from the 2005 general rate case.
REQUEST NO.6: What is the assumed level of fixed costs recovered through fixed
charges for the 2008 calendar year for the two customer classes? Please provide any
workpapers, in executable format, used to determine the assumed level of fixed costs recovered
in fixed charges for CY 2008.
REQUEST NO.7: Please provide an analysis of the financial impact of implementing
the new FCC/FCE rates on March i, 2008, rather than the Company's proposed Januar i, 2008
retroactive date. Please provide any workpapers, in executable format, with the response.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 MARCH 28, 2008
REQUEST NO.8: Please explain colum B, rows 46-51, entitled 'Additional Fixed
Cost Recovery' in Youngblood Exhibit 2, also referenced in Mr. Youngblood's testimony on
pages 9-10.
REQUEST NO.9: Please provide all workpapers, in executable format, used to
determine the 2008 forecasted normalized sales of 5,065,086,947 kWh and 190,586,226 kWh for
the residential and small general service classes, respectively.
REQUEST NO. 10: Of the 83 VendingMisers installed (page 49 of 2007 DSM Report),
how many were installed for small commercial customers? What is the estimated energy savings
associated with the VendingMisers?
REQUEST NO. 11: Please provide any preliminar results from the Quantec-conducted
study on appliance effciency standards referenced on page 49 of the 2007 DSM Report.
REQUEST NO. 12: Beyond the education and marketing programs detailed on page 48
of the 2007 DSM Report, what energy efficiency and DSM programs were enacted either
directly as a result of the FCA or were not operational in 2006. Please specify the energy or peak
savings resulting from the programs, and to which customer class they are attributed.
REQUEST NO. 13: In the press release dated March 14,2008, the Company states that
"Last year the company's combined energy efficiency programs saved 91.2 milion kilowatt-
hours..." Please specify the amount of savings associated with each program offered by
customer classes.
REQUEST NO. 14: Regarding the small commercial class, please provide an analysis
of the reduction of the per customer energy consumption the Company attributes to its DSM
programs. To what does the Company attibute any additional reduction in per customer
consumption? Please provide all workpapers used to prepare the response in executable format.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 MARCH 28, 2008
REQUEST NO. 15: Regarding the residential class, please provide an analysis of the
increase in per customer energy consumption in 2007, including what the Company attributes the
increase in consumption to? Please provide all workpapers used to prepare the response in
executable format.
DATED at Boise, Idaho, this is""day of March 2008.
~I Weldon B. Stu zman
Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umisc:prodreqlipce08.4wsrps prod req 1
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 MARCH 28, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF MARCH 2008,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-04, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom~idahopower.com
bkline~idahopower.com
MICHAEL J YOUNGBLOOD
JOHN R GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: myoungblood~idahopower.com
rgale~idahopower.com
.Y(0c
SECRETARY
CERTIFICATE OF SERVICE