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Home My WebLink About20081031Staff to IPC 23-51.pdfNEIL PRICE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 3/34-0314 ISB NO. 6864 RECEIVED 200S OCT 31 PH 2: 03 IDAHO PUBLiC UTILITIES COMMISSION Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commìssion Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR A ) CERTIFICATE OF PUBLIC CONVENIENCE ) AND NECESSITY TO INSTALL ADVANCED ) METERING INFRASTRUCTURE ("AMI") ) TECHNOLOGY THROUGHOUT ITS SERVICE )TERRTORY. ) CASE NO. IPC-E-08-16 SECOND 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, Scott Woodbur, Deputy Attorney General, requests that Idaho Power Company (Company; Idaho Power) provide the following documents and information as soon as possible, but no later than FRIDAY, NOVEMBER 21, 2008. The Company ìs 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 hearìng ifneed be. Reference IDAPA 31.01.01.228. This Production Request is to be considered as continuìng, and Idaho Power is requested to provide, by way of supplementar responses, addìtional documents that it or any person acting on its behalf may later obtain that wil augment the documents produced. SECOND PRODUCTION REQUEST TO IDAHO POWER 1 OCTOBER 31,2008 Please provide answers to each question, supporting workpapers that provide detail or are the source of information used ìn calculations, and the name, job tìtle and telephone number of the person preparing the documents. Please identìfy 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. 23: What intervals wil Idaho Power use for readìng meters with the AMI system? REQUEST NO. 24: Does Idaho Power plan to use the AMI technology for remote connects and disconnects in the future? Please explaìn. REQUEST NO. 25: What are the read success rates and percentage of estimated readings with Idaho Power's exìsting metering system? What are the anticipated read success rates and percentage of estimated readings with the proposed AMI system? REQUEST NO. 26: What is the expected failure rate for AMI system meters compared with conventional meters? REQUEST NO. 27: What ìs the risk oflong-term failure and what would be the cost of temporary resources to manually read meters in the event of failure? REQUEST NO. 28: How often do meter readers notice and report problems with the Idaho Power infrastrcture as a result of their rounds? REQUEST NO. 29: Wil there be more visual surveilance requìred of the system by other Idaho Power personnel after the meter readers are no longer makìng rounds? REQUEST NO. 30: A PLC system can generally reach all end points serviced by the utilty. Under what circumstaces might the PLC system be unable to read a meter? SECOND PRODUCTION REQUEST TO IDAHO POWER 2 OCTOBER 31, 2008 REQUEST NO. 31: Can the new AMI meters be read in the same maner as the existìng meters ìf it ìs necessary to do so? If not, please explain. REQUEST NO. 32: With AMI will the Company be able to schedule a future meter read to automatically read the meter on a customer's requested closing or opening date? REQUEST NO. 33: How many regular cycle bils were sent to customers in 20077 REQUEST NO. 34: How many regular cycle bils sent to customers in 2007 were estìmated (not based on an actual meter reading)? REQUEST NO. 35: How many out of cycle (opening or closing) bils were sent to customers in' 20077 REQUEST NO. 36: How many kWh went unbiled in 2007 as a result of the Company's leaving meters connected between customers? What is the total dollar value or those unbiled kWh? REQUEST NO. 37: With the abilty to obtain out of cycle meter readings through the proposed AMI system, how will Idaho Power handle physical disconnects when a customer closes his/her account? Wil there be an increase in unbiled kWh going forward? REQUEST NO. 38: Regarding opening bils prepared outside of regular billng cycles in 2007, please provide how many of the readìngs on whìch the bils were based were determined by: (a) an actual meter reading taen by a Company employee or via remote meter reading; (b) a computer estimate; (c) a manual estimate made by a Company employee; (d) a customer-provided reading; or (e) other methods. REQUEST NO. 39: Please provìde the year-to-year percentage decrease or ìncrease in the total number of estimated meter readìngs for 2004-2007. SECOND PRODUCTION REQUEST TO IDAHO POWER 3 OCTOBER 31, 2008 REQUEST NO. 40: Please provide the year-to-year percentage decrease or increase in the total number of misread or ìncorrect meter readings for 2004-2007. \ REQUEST NO. 41: Please provide the reasons for and number of instaces in 2007 where the Company had to rebil customers because a previous bil was based on incorrect biling determinants, e.g., ìncorrect identification of multiplier or meter size. REQUEST NO. 42: By year, please provide the number and percentage of installed meters or metering equipment that failed for the years 2004-2007. Is the failure rate for AMI meters significantly different than that of older technology meters? REQUEST NO. 43: Please explain how meter reading data is entered into the biling system currently. How wil tils change with AMI? REQUEST NO. 44: Please explain how low income and other vulnerable customers wil benefit from AMI implementation? REQUEST NO. 45: Is Idaho Power planìng on making its curent AMI pilot programs, i.e. Time-of-Day Program and Energy Watch, available to all customers durìng or after the meter conversion? If not, why? REQUEST NO. 46: Is the Company planing on introducing any new pilot programs with the deployment of AMI? If so, please provide a detailed description of any new programs. REQUEST NO. 47: Curently, what is the time delay for displaying customer usage and biling information on the Company's website for curent AMI customers? What is the Company's goal for providing customer usage and biling informatìon after AMI meters are fully installed? REQUEST NO. 48: What plans does the Company have for implementìng Time of Use rates after AMI has been fully deployed? SECOND PRODUCTION REQUEST TO IDAHO POWER 4 OCTOBER 31,2008 REQUEST NO. 49: Insofar as it has not been already provided in a response to a prìor request, please provide an anual revenue requirement impact of the AMI implementation for each year of the project life. Please include the impact assumìng existing meters are depreciated over 3 years, 5 years, 10 years and without accelerated depreciatìon. REQUEST NO. 50: Insofar as it has not been already provided in a response to a prior request, please provìde the anual savings in meter reading expenses over the project life. Please include the assumptions used to determine the growth in curent meter readìng expenses. REQUEST NO. 51: Please list the benefits the McCall and Emmett customers are currently receiving from AMI. a) Wil this be the same benefits other customers wil receive in the Company's service territory after full deployment of AMI? Please explain. DATED at Boìse, Idaho, thig \ ~ay of DATE 2008. ,-,~.. ~~ Neil Price Deputy Attorney General Technical Staff: Daniel Klein/1-48 Donn English/49 & 50 T.J. Golo/51 i:umisc:prod reqlipce08, 16 prod req 2,doc SECOND PRODUCTION REQUEST TO IDAHO POWER 5 OCTOBER 31,2008 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 31ST DAY OF OCTOBER 2008, SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-16, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: DONOV AN E WALKER BARTON L KLINE IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: dwalker(fidahopower.com bkline(fidahopower .com COURTNEY WAITES JOHN R GALE IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: cwaìtes(fidahopower.com rgale(fidahopower.com MICHAEL L KURTZ KURT JBOEHM BOEHM KURTZ & LOWRY 36 E SEVENTH ST STE 1510 CINCINATI OH 45202 E-MAIL: mkurz(fBKLlawfrm.com kboehm(fBKLlawfrm.com KEVIN HIGGINS ENERGY STRATEGIES LLC PARKS IDE TOWERS 215 S STATE ST STE 200 SALT LAKE CITY UT 84111 E-MAIL: khiggins(fenergystrat.com ~"et SECRETARY CERTIFICATE OF SERVICE