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Home My WebLink About20080910Staff to IPC 42-63.pdfWELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0318 BARNO. 3283 REceiVED ZfJ8 SEP I 0 PH 3: 06 IDAHO PUBUC UTILITIES COMMisSION NEIL PRICE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 ISB NO. 6864 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 INCREASE ITS RATES AND CHARGES ) FOR ELECTRIC SERVICE TO ITS ) CUSTOMERS IN THE STATE OF IDAHO. ) ) ) ) CASE NO. IPC-E-08-10 FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilties 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 WEDNESDAY, OCTOBER 1,2008. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 SEPTEMBER 10, 2008 The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228. 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 wil augment the documents produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name, job title and telephone number of the person preparing the documents. Please identify the name, job title, location and telephone number ofthe record holder. Please provide all Excel and electronic fies on CD with formulas activated. REQUEST NO. 42: Please provide all bil frequency analyses completed or in progress for the commercial schedules. Please provide a description of what each analysis conveys, what biling determinant it was used for, and how it was utilized in determining the proposed rate designs. REQUEST NO. 43: With regards to the Company's witnesses Nemnich and Waites, please provide electronic copies of all analyses supporting the commercial and residential schedules rate design. Please provide a description of what each analysis conveys, what biling determinant it was used for, and how it was utilized in determining the proposed rate designs. REQUEST NO. 44: In testimony by Company witnesses Nemnich and Waites, several statements are made regarding the strength, weakess, or introductory level of price signals within rate design. In light of this, please provide electronic copies of all analyses regarding the evaluation of these signals and the impact on customer behavior (i.e. load shifting, load shedding). REQUEST NO. 45: With regards to Schedule 19, has IPC analyzed the pre time-of-use biling structure in order to evaluate how the current time-of-use rate structure has influenced FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 SEPTEMBER 10, 2008 customer consumption behaviors, specifically, how differentials and time-of-use price signaling has impacted behavior? If so, please provide this to Staff. If not, please explain why not. (Nemnich Testimony, page 19) REQUEST NO. 46: Please provide a list of all Schedule 9 customers who have moved to another Schedule (e.g. Schedule 19) since January 2005. Please provide the dates of the transfer, as well as the monthly usage for each customer. REQUEST NO. 47: When determining the demand charge differentials for Schedule 9 summer vs. non-summer customers, Company witness Nemnich says in testimony: "In order to move towards alignment with cost-of-service, my proposal is to move 25 percent closer to the cost-of-service results." When cost-of-service results show differentials between summer and non-summer demand to be 62 percent for Schedule 9 customers, how was 25 percent determined as appropriate? (Nemnich Testimony, page 22) REQUEST NO. 48: After Company witness Nemnich describes the time-of-use differentials associated with Schedule 9, she says "these are not very large but do provide an introductory level of time differentiated rates. Customers have the opportunity to become familar with time variant pricing gradually, see how their usage patterns impact their bils, and plan accordingly." What range of customer behavior responses represents "introductory level" differentials? (Nemnich Testimony, page 26) Please provide all analyses on this "introductory level" . REQUEST NO. 49: According to Company witness Nemnich "Idaho Power can avoid the costs of manual bil processing associated with shadow bils that occurred during the Schedule 19 time-of-use rate implementation." Please provide all the cost/benefit analyses showing how a shadow bil "phase-in" period for time-of-use rates wil add more toward administrative expenses than the benefit incrementally added? (Nemnich Testimony, page 29) REQUEST NO. 50: When asked if Company witness Nemnich thought the Schedule 9 and Schedule 19 rate components and differentials were reasonable, she replied "I reviewed FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 SEPTEMBER 10, 2008 time-of-use rate structures of the other utilties and found that a total overall differential of 46 percent is within a typical range." What other utilities' time-of-use rate structures were examined and how was reasonableness assessed? (Nemnich Testimony, page 34) REQUEST NO. 51: Please provide all the analyses done in determining how the "Energy Watch Event" rate has affected demand and how IPC arrives at the differential between the event rate and base rate? (Waites Testimony, page 13) REQUEST NO. 52: Why was 60 percent of the average 2007 residential customer energy usage used as the benchmark for designing the first block? (Waites Testimony, page 10) REQUEST NO. 53: Why was only 2007 used in estimating customer energy usage? Why wasn't a trend developed to forecast usage? If so, why wasn't an average used? (Waites Testimony, page 10) REQUEST NO. 54: Please provide monthly customer counts and loads used to determine that average residential baseline usage was 806 kWh and 838 kWh. Please provide more detail on how May and October 2007 was selected and describe how daily usage was normalized. Were different geographic regions considered (e.g. McCall vs. Boise)? (Waites Testimony, page 10) REQUEST NO. 55: In regards to the Schedule 19 biling structure, why has IPC decided to change the differentials between Off-Peak, Mid-Peak, and On-Peak during the summer and the differential between Off-Peak and Mid-Peak Energy Charges during non- summer season? How has IPC determined the differentials? (Nemnich Testimony, pages 30-31) REQUEST NO. 56: When calculating new Off-Peak Energy Charges for the Schedule 9 summer and non-summer seasons, why were the current rates "increased by approximately 7.5 percent"? Why does Nemnich go on to say "This is approximately half of the total overall increase of 15 percent for Schedule 19 customers"? Why doesn't Off-Peak represent a smaller FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 SEPTEMBER 10, 2008 portion of the relative total Schedule 19 increase to convey a price signal of conservation? Please provide all analysis on this. (Nemnich Testimony, page 34) REQUEST NO. 57: When calculating the new Schedule 19 Mid-Peak Energy Charges in an "iterative process" resulting in new differentials, what "iterative process" was used? (Nemnich Testimony, page 34) REQUEST NO. 58: When calculating the new Schedule 19 Mid-Peak Energy Charges in an "iterative process" resulting in new differentials, what "iterative process" was used? (Nemnich Testimony, page 34) REQUEST NO. 59: Did the Company consider other possible rate tiers for the residential customers beyond those proposed in this filing? If so, what alternatives were considered? Why was a two-tier system selected over, for example, a three-tier rate structure? REQUEST NO. 60: On page 2 of Company witness Waites' testimony, the proposed rate design for residential customers is "both cost-based and encourages increased energy effciency." Please explain how the two-tier rate structure, with summer and non-summer differentials, adheres to the 'cost-based' criteria. Specifically, what resources (costs) are associated with the first rate block (up to 600 kWh) and what resources are associated with the second block? REQUEST NO. 61: Please provide an analysis demonstrating that the cost to provide the first 600 kWh of energy to residential Schedule i customers is higher in the summer than non-summer months. Specifically address the embedded resources for each season. REQUEST NO. 62: What effect on residential energy consumption does the Company expect from implementation of its Tiered Rate Proposal? Please provide any analysis used to support that expectation. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 SEPTEMBER 10, 2008 REQUEST NO. 63: Please provide an analysis for the residential customer classes that show the percentage of fixed costs included in energy rates by proposed rate block for both summer and non-summer months. Does the Company believe that the proposed changes to rate design wil affect the recovery of fixed costs during the remainder of the FCA pilot program? Why or why not? DATED at Boise, Idaho, this totay of September 2008. I1Q~'Ncce Deputy Attorney General - Technical Staff: Matt Elam42 - 57 Bryan Lanspery 58 - 63 i:umisc:prodreq/ipce08.IOwsnpmebl prod req4 FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 6 SEPTEMBER 10, 2008 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF SEPTEMBER 2008, SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-1O, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: BARTON L KLINE LISA D NORDSTROM DONOV AN E WALKER IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: bkline(iidahopower.com lnordstrom(iidahopower. com dwalker(iidahopower.com PETER J RICHARDSON RICHARDSON & O'LEARY PO BOX 7218 BOISE ID 83702 E-MAIL: peter(ârichardsonandoleary.com RANDALL C BUDGE ERICLOLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: rcb(âracinelaw.net elo(iracinelaw.net MICHAEL L KURTZ ESQ KURT J BOEHM ESQ BOEHM KURTZ & LOWRY 36 E SEVENTH ST STE 1510 CINCINATI OH 45202 E-MAIL: mkurz(iBKLlawfirm.com kboehm(iBKLlawfirm.com BRAD M PURDY ATTORNEY AT LAW 2019N 17TH ST BOISE ID 83702 E-MAIL: bmpurdyCâ1hotmaiL.com JOHNRGALE VP - REGULATORY AFFAIRS IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: rgale(iidahopower.com DR DON READING 6070 HILL ROAD BOISE ID 83703 E-MAIL: dreading(âmindspring.com ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 E-MAIL: yankel~Ù¡attbi.com KEVIN HIGGINS ENERGY STRATEGIES LLC PARKS IDE TOWERS 215 S STATE ST STE 200 SALT LAKE CITY UT 84111 E-MAIL: khiggins(ienergystrat.com LOTH COOKE ARTHUR PERRY BRUDER UNITED STATE DEPT OF ENERGY 1000 INDEPENDENCE AVE SW WASHINGTON DC 20585 E-MAIL: lot.cooke(ihq.doe.gov arth ur. bruder(ihq .doe. gov CERTIFICA TE OF SERVICE DWIGHT ETHERIDGE EXETER ASSOCIATES INC 5565 STERRTT PLACE, SUITE 310 COLUMBIA MD 21044 E-MAIL: detheridge(iexeterassociates.com DENNIS E PESEAU, Ph.D. UTILITY RESOURCES INC 1500 LIBERTY STREET SE, SUITE 250 SALEM OR 97302 E-MAIL: dpeseau(iexcite.com CONLEY E WARD MICHAEL C CREAMER GIVENS PURSLEY LLP 601 W BANNOCK ST PO BOX 2720 BOISE ID 83701-2720 E-MAIL: cew(igivenspursley.com KEN MILLER CLEAN ENERGY PROGRAM DIRECTOR SNAKE RIVER ALLIANCE PO BOX 1731 BOISE ID 83701 E-MAIL: kmiller(msnakeriverallance.org ,b~SECREfA ~ CERTIFICA TE OF SERVICE