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Home My WebLink About20080919Staff to IPC 89-109.pdfWELDON B. STUTZMAN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-03 1 8 BARNO. 3283 RECEIVED 2808 SEP '9 PH 3: 02 IDAHO PUBLIC UTILITIES COMMISSION NEIL PRICE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-03 14 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 SIXTH 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 FRIDAY, OCTOBER 3, 2008. SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 SEPTEMBER 19,2008 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 supplementar responses, additional documents that it or any person acting on its behalf may later obtain that will 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 of the record holder. Please provide all Excel and electronic fies on CD with formulas activated. REQUEST NO. 89: For each Idaho-fuded demand-side management (DSM) program included in Appendix 4 of Idaho Power's Demand-Side Management 2007 Anual Report, please provide a breakdown of annual and 5-year total costs, including incentive payments to participants, direct program administrative costs, direct program evaluation costs, and allocated indirect administrative and evaluation costs with a description of how such allocations were made. REQUEST NO. 90: For each Idaho-fuded demand-side management (DSM) program included in Appendix 4 of Idaho Power's Demand-Side Management 2007 Anual Report, please provide the pre-implementation estimated evaluation budget, the amount spent on evaluations through 2007, and the amount spent for evaluations in 2008 to-date. REQUEST NO. 91: Please provide copies of any post-implementation evaluations of all Idaho-funded DSM programs completed by or for Idaho Power from 2003 through 2008. Include evaluations of program processes, direct energy and peak demand impacts, and educational and/or market transformation effects. SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 SEPTEMBER 19,2008 REQUEST NO. 92: Please describe how post-implementation evaluations have been used by Idaho Power to improve its DSM programs and/or to improve its overall resource planing. Include supporting discussion notes, letters and memorandums, all whether on paper or electronically distributed. REQUEST NO. 93: Please provide a reasonably detailed description and cost summar of each post-implementation evaluation ofDSM programs. Include in the descriptions the names and affiliations of the primar evaluators and the process(es) by which the evaluators were chosen. . REQUEST NO. 94: Please describe any post-implementation DSM program evaluations that are not yet completed, but are currently in progress. REQUEST NO. 95: Please describe any post-implementation DSM program evaluations that are currently in a planning stage. REQUEST NO. 96: Please provide post-implementation benefit/cost (B/C) ratio estimates for each Idaho-funded DSM program listed in Appendix 4 of Idaho Power's Demand- Side Management 2007 Annual Report. Include B/C ratios from all perspectives considered, e.g. societal, total resource, utilty, paricipant, and non-participant. Provide complete descriptions of, and bases for, all assumptions (e.g. net-to-gross savings ratios), values (e.g. demand, energy and non-energy savings) and calculations used in estimating the B/C ratios and the actual calculations on executable Excel spreadsheets. REQUEST NO. 97: Describe all sensitivity analyses conducted by or for Idaho Power of any non-firm variables and assumptions used in estimating DSM program B/C ratios. REQUEST NO. 98: To the extent that assumptions and variable values of post- implementation B/C ratios differ from those used in pre-implementation DSM "potential" studies, please describe and explain those differences. SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 SEPTEMBER 19,2008 REQUEST NO. 99: On page 7, line 1, of Theresa Drake's pre-fied testimony is a reference to Idaho Power's use of the Electric Power Research Institute End Use Technical Assessment Guide and the California Standard Practice Manual, both of which recognize the value that each of the five standard tests (i.e. societal, total resource, utilty, participant, and non- paricipant) can lend to optimizing and balancing DSM planing and program design. To the extent that Idaho Power does not consider B/C ratios from any of those five standard tests, please explain why not. REQUEST NO. 100: On page 7, lines 3 and 4, of Theresa Drake's pre-fied testimony is the statement that "...if the benefit/cost ratio is greater than" 1 , "the program is considered cost- effective. Is a B/C ratio greater than 1.0 Idaho Power's sole criterion for determining the success of a DSM program? Or does the Company also evaluate program success based on possible alternative demand-side costs? If so, please provide documented examples of the use of such. REQUEST NO. 101: On page 12 of Theresa Drake's pre-fied testimony is the statement that "NEEA estimated that 28,601 megawatt-hours were saved in the Company's service territory in 2007." Please provide the assumptions and calculations NEEA used to estimate that savings number and any Idaho Power analyses of the veracity of that megawatt-hour savings number and the value of such savings. REQUEST NO. 102: In response to Production Request No.1, the Company provided a spreadsheet that indicates that in July of 2007, Idaho Power's Customer Service Center attained a 67.94% service leveL. Please provide the reason or reasons for the service level to fall below the goal of answering 80% pf calls within 30 seconds. REQUEST NO. 103: Please explain why Schedule 25, the Irrigation Time-Of-Use Pilot Program, was discontinued. Include any pertinent fiings to and by the Commission. REQUEST NO. 104: Please explain how the proposed declining block rates during the summer for Schedule 24 adhere to the principles of cost-based pricing and promotion of energy efficiency. Provide any supporting documentation the Company may have. SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 SEPTEMBER 19, 2008 REQUEST NO. 105: Please explain why proposed off-season energy rates for Schedule 24 are 32-36% higher than on-season rates. What are the drivers for the off-season rate and the differential? REQUEST NO. 106: Why has the Company decided not to propose tiered rates for Schedule 24 in off-season months while proposing such for virtually all other customer classes? REQUEST NO. 107: Why did the Company decide to leave the first block of energy at 0-300 kWh for Schedule 7 customers instead of raising it to 0-600 kWh as it did for the residential classes? Please provide any supporting documentation. REQUEST NO. 108: How did the Company determine the rate differentials for on-/off- /mid-peak prices for Schedule 5? Does the Company believe these rates accurately reflect the cost to serve during the time periods? Does the Company truly believe the 'relationships between the on-, Mid-, and Off -Peak periods' (Waites, p. 17) have not changed since the advent of the program (since the differentials did not change in the last general rate case)? Why or why not? REQUEST NO. 109: Many of the Excel work fies for rate design have links to a worksheet entitled "Charges by Component", with a link address of'I:\Mary M\2008 General Rate Case\Worksheets base to new base\(Charges by Component.xls)'. Please provide this workbook, in executable format, and any other workbooks that are linked to it. DATED at Boise, Idaho, this \~ day of September 2008. ~ Deputy Attorney General Technical Staff: Lynn Anderson/89 - 101 Marilyn Parker/1 02 Bryan Lanspery/103 - 109 i:umisc:prodreq/ipce08. i Owsnplampbl prod req6 SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 SEPTEMBER 19, 2008 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS DATE 19TH OF SEPTEMBER 2008, SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-10, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: BARTON L KLINE LISA D NORDSTROM DONOVAN E WALKER IDAHO POWER COMPANY POBOX 70 BOISE ID 83707-0070 E-MAIL: bklineCfidahopower.com lnordstromCfidahopower. com dwalkerCfidahopower .com PETER J RICHARDSON RICHARDSON & O'LEARY PO BOX 7218 BOISE ID 83702 E-MAIL: peterCfrichardsonandoleary.com RANDALL C BUDGE ERIC L OLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: rcbCfracinelaw.net eloCfracinelaw.net MICHAEL L KURTZ ESQ KURT J BOEHM ESQ BOEHM KURTZ & LOWRY 36 E SEVENTH ST STE 1510 CINCINATI OH 45202 E-MAIL: mkurzCfBKLlawfirm.com kboehmCfBKLlawfirm.com BRAD M PURDY ATTORNEY AT LAW 2019N 17THST BOISE ID 83702 E-MAIL: bmpurdyCfhotmail.com JOHN R GALE VP-REGULATORY AFFAIRS IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: rgaleCfidahopower.com DR DON READING 6070 HILL ROAD BOISE ID 83703 E-MAIL: dreadingCfmindspring.com ANTHONY Y ANKEL 29814 LAK ROAD BAY VILLAGE OH 44140 E-MAIL: yankelCfattbi.com KEVIN HIGGINS ENERGY STRATEGIES LLC PARKS IDE TOWERS 215 S STATE ST STE 200 SALT LAKE CITY UT 841 1 1 E-MAIL: khigginsCfenergystrat.com LOT H COOKE ARTHUR PERRY BRUDER UNITED STATE DEPT OF ENERGY 1000 INDEPENDENCE AVE SW WASHINGTON DC 20585 E-MAIL: lot.cookeCfhq.doe.gov arhur. bruderCfhq.doe.gov CERTIFICATE OF SERVICE DWIGHT ETHERIDGE EXETER ASSOCIATES INC 5565 STERRTT PLACE, SUITE 310 COLUMBIA MD 21044 E-MAIL: detheridgeCfexeterassociates.com DENNIS E PESEAU, Ph.D. UTILITY RESOURCES INC 1500 LIBERTY STREET SE, SUITE 250 SALEM OR 97302 E-MAIL: dpeseauCfexcite.com CONLEY E WARD MICHAEL C CREAMER GIVENS PURSLEY LLP 601 WBANNOCKST PO BOX 2720 BOISE ID 83701-2720 E-MAIL: cewCfgivenspursley.com KEN MILLER CLEAN ENERGY PROGRAM DIRECTOR SNAKE RIVER ALLIANCE PO BOX 1731 BOISE ID 83701 E-MAIL: kmilerCfsnakeri veralliance.org CERTIFICATE OF SERVICE