20081028Staff to IPC 1-22.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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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 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
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staf of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, 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
TUESDAY, NOVEMBER 18, 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 wil augment the documents produced.
FIRST PRODUCTION REQUEST TO
IDAHO POWER 1 OCTOBER 28, 2008
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.1: The Company has determined that a "3-year AMI implementation plan
is reasonable" based on the following factors:
a. Impact oft Revenue Requirement
b. Impact on existing employees
c. Operational savings
d. Impact on anual capital requirements
e. Other major capital requirements needed to reliably serve existing customers
f. Areas with high growth (new meters)
g. Ease of implementation logistics
Please explain in detail how each factor affected the implementation plan and why the
Company has chosen a 3-year deployment plan of AMI technology.
REQUEST NO.2: Please categorize and explain all the required components needed to
implement AMI.
REQUEST NO.3: Please explain and provide detail regarding how AMI implementation
throughout the remainder of the Company's service area will differ from automated meter
installation in the MeCalVEmmett areas in terms of equipment, installation process and overall
costs.
REQUEST NO.4: Please provide all details of the financial analysis summarized in the
August 31, 2007, Advanced Metering Infrastructure (AMI) Implementation Plan report attched as
Company Exhibit NO.1. Please provide any and all updates to the financial analysis conducted by
the Company since the report was filed with the Commission.
FIRST PRODUCTION REQUEST TO
IDAHO POWER 2 OCTOBER 28, 2008
REQUEST NO.5: Please provide an analysis showing the effect on anual revenue
requirement and the net present value of savings over the 30-year period of depreciating removed
meters over a 3, 5 and 10-year period.
REQUEST NO.6: Please explain the features of AMI which wil be immediately utilzed
by the Company without the need of additional investments.
REQUEST NO.7: The AMI system also provides a platform for future "smar grid"
operations and other features.
a. Please list the anticipated fuctionalities the Company may utilze in the future
and explain its benefits.
b. Please provide the projected incremental cost for each anticipated future benefit.
REQUEST NO.8: Company stated that "achieving the full benefit from hourly data
collection will likely require more time as additional back office systems and rate structures wil
need to be in place before significant benefits could be realized through TOU pricing rates."
a. Please explain what "additional back office systems" are needed to realize TOU
pricing rates.
REQUEST NO.9: Please provide the written version of the Strategic Sourcing Process
the Company used to select vendors and contracts to secure hardware, software and labor for AMI
deployment.
a. Please provide all information related to the RFI and RFP process the Company
used to evaluate and assess possible AMI solutions.
b. Please show how the Company used this process to determine whether a vendor or
a contractor is the right fit for the Company's AMI objective.
REQUEST NO. 10: Please provide the breakdown and details of the total capital cost
("Commitment Estimate") of the AMI project.
FIRST PRODUCTION REQUEST TO
IDAHOPUWER 3 OCTOBER 28, 2008
a. Please also provide total unit cost per meter by rate schedule (including labor).
REQUEST NO. 11: Please provide the details of the negotiated pricing and terms
between the Company and its AMI vendors.
REQUEST NO. 12: Please provide details of the cost of the lead-in equipment the
Company ordered and purchased as of today.
REQUEST NO. 13: Please explain why the Company chose power line carrier technology
over radio frequency technology or some combination of both.
REQUEST NO. 14: The metering technology has evolved over time from Automated
Meter Reading to Advance Metering Infrastructure. It shows how technology can become
obsolete over time.
a. Please explain how the Company will keep its system up to date with continuous
improvement of metering technology.
b. Is the AMI system selected by the Company flexible enough to avoid technological
obsolescence? Please explain.
REQUEST NO. 15: AMI has the abilty to provide energy consumption information to
the customers. Wil this information be available to customers following the deployment of AMI?
Please explain.
REQUEST NO. 16: Please provide a listing of the number of meters to be deployed by
customer class.
REQUEST NO. 17: What is the Company's estimate of additional meters needed due to
customer growth during the deployment period?
REQUEST NO. 18: What is the increase in accuracy of meter readings using AMI
compared to conventional meter reading? Wil this increased accuracy reduce costs to customers?
FIRST PRODUCTION REQUEST TO
IDAHO POWER 4 OCTOBER 28, 2008
REQUEST NO. 19: On page 8, line 18-19 of Mr. Heintzelman's testimony, what is the
"additional functionality" that wil be implemented in the succeeding year?
REQUEST NO. 20: How compatible is the outage management system of the Company
to the AMI system?
a. Does the Company anticipate any problems durng the outage management
integration into the AMI system? Please explain.
b. Did the Company test to ensure that outage management fuctionality is working
properly with the proposed AMI system once it is implemented? Please explain.
REQUEST NO. 21: Please explain in fuher detail how the installation of the AMI
system wil not interrpt service to the customers.
a. During the exchange of the meters, wil this cause meter reading inaccuracies (i.e.
meter reading gap)? Please explain.
REQUEST NO. 22: What is the expected useful life and failure rate for AMI meters
compared to the existing conventional meters?
DATED at Boise, Idaho, thi~~ of October 2008.
,;v~
~eil Price
Deputy Attorney General
Technical Staff: T.J. Golo
i:umisc:prod reqlipce08. i 6 prod req l.doc
FIRST PRODUCTION REQUEST TO
IDAHO POWER 5 OCTOBER 28, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF OCTOBER 2008,
SERVED THE FOREGOING FIRST 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(iidahopower.com
bkline(iidahopower .com
COURTNEY WAITES
JOHNRGALE
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: cwaites(iidahopower.com
rgale(iidahopower .com
MICHAEL L KURTZ
KURT JBOEHM
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurz(iBKLlawfrm.com
kboehm(iBKLlawfrm.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
CERTIFICATE OF SERVICE