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HomeMy WebLinkAbout20081119IPC to Staff 1-22.pdfDONOVAN E. WALKER Corporate Counsel $SIDA~POR~ An IDACORP Company t:)\JHUGS\"'''1 · ' S U~'l November 18, 2008 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-08-16 Advanced Metering Infrastructure (''AMI') Technology Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Response to the First Production Request ofthe Commission Staff. In addition, enclosed are four (4) copies of a disk in which electronic files are being produced by Idaho Power in response to Staffs production requests. Also, enclosed in a separate envelope are four (4) copies each of a disk and agreements in which Idaho Power has produced confidential information in response to Staffs production requests. Please note this information should be handled in accordance with the Protective Agreement between the parties. I would appreciate it if you would return a stamped copy of this letter for Idaho Power's file in the enclosed stamped, self-addressed envelope. Donovan E. Walker DEW:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 DONOVAN E. WALKER, ISB No. 5921 BARTON L. KLINE, ISB No. 1526 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: 208-388-5317 Facsimile: 208-338-6936 dwalker(ãidahopower.com bkline(ãidahopower.com RECË1\1ED 2808NOV 18 PH 5: Q4 IDAHO PUP! 1,., UTILITIES COf)t~l;ŠS10N Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION )IN THE MAnER OF THE APPLICATION ) CASE NO. IPC-E-08-16 OF IDAHO POWER COMPANY FOR A ) CERTIFICATE OF PUBLIC CONVENIENCE ) IDAHO POWER COMPANY'S AND NECESSITY TO INSTALL ADVANCED ) RESPONSE TO THE FIRST METERING INFRASTRUCTURE ("AMI") ) PRODUCTION REQUEST OF THE TECHNOLOGY THROUGHOUT ITS ) COMMISSION STAFF TO IDAHO SERVICE TERRITORY ) POWER COMPANY ) COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the Commission Staffs First Production Request to Idaho Power Company dated October 28,2008, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO.1: The Company has determined that a "3-year AMI implementation plan is reasonable" based on the following factors: a. Impact on Revenue Requirement b. Impact on existing employees c. Operational savings d. Impact on annual 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. RESPONSE TO REQUEST NO.1: a. Impact on Revenue Requirement. In the long run, AMI produces a total revenue requirement savings for Idaho Power customers; however, in the short run, it is more costly to customers due to the up-front capital investments required. Different scenarios were considered to determine that three years was the best implementation time frame. A longer implementation would delay the benefits from AMI both in customer's rates and in operations, while a shorter implementation would maximize O&M savings by reducing manual processes and increasing operation effciencies sooner. A shortened implementation creates a larger revenue requirement increase initially, but speeds up the realization of savings and benefits. The Company felt that a three year implementation was a good balance that emphasizes the sooner realization IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 of benefits and incorporates the practical logistics of procuring and installng the equipment system wide. b. Impact on Existing Employees. Much of the operational savings comes from the elimination of manual meter reading positions. The Company is currently, and has been for some time, moving the meter reading positions to work on a term specific basis in anticipation of their eventual elimination. The planned deployment allows sufficient time to re-train some employees for other positions within the Company and for others time to seek different employment. Additionally, the way in which the planned deployment progresses geographically, lowers the impact on existing employees by starting in areas that have the greatest opportunity for them to either re-train or find other work. Those employees who are in geographically lower opportunity areas wil have more time to re-train and/or seek other opportunities, as their positions wil be eliminated later in the three year deployment schedule. c. Operational Savings. Operational savings begin to occur when the area covered by a manual meter reader is converted to the AMI system. The greatest savings occurs when the entire area covered by the manual meter reader is converted such that the meter reading position can be eliminated. Consequently, the deployment is planned to generally follow meter reading routes, and proceed route by route and substation by substation until an entire geographic operational area is completely converted before moving on to the next area. This wil allow the Company and customers to realize the greatest operational savings by maximizing the reduction in operational cost once an area is completely automated. The three year deployment is designed to complete operational areas, districts, and regions in an organized and IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 focused succession across the territory, such that the greatest operational savings can be achieved. d. Impact on Annual Capital Requirements. Deployment of AMI throughout the entire service territory requires a substantial capital investment and impacts Idaho Power's ability to raise suffcient cash to fund this deployment while continuing to fund other infrastructure needs of the system. In order to raise the capital, the Company must issue both debt and equity in order to maintain its current capital structure and credit ratings. Many scenarios were considered to determine the best implementation time frame. Extending the project for more than three years would postpone the operational benefits that are derived from the AMI project. Idaho Power emphasized a shorter implementation process in order to maximize O&M savings by reducing the manual processes and increasing operational effciencies. That desire was balanced with the capital constraints on the Company. In 2008, Idaho Power is estimating to spend between $235M and $250M on capital projects not including AMI. Idaho Power expects to spend similar amounts in 2009 in order to meet its obligation to serve its customers. With operating cash inflows of approximately $150M, Idaho Power is required to externally finance a significant portion of its total capital expenditures. AMI requires additional external financing on top of current capital plans. To partially offset the impact of the increased capital requirements, Idaho Power proposed an amortization of the existing meters over the same period as the deployment and included that cost in the revenue requirement. This revenue requirement would generate cash flows that partially offset the external financing requirements. Even with IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 the increased cash flows from the proposed amortization, Idaho Power's total capital spend for the next three years is aggressive. e. Other Major Capital Requirements Needed to Reliably Serve Existing Customers. The Company's current projections for capital expenditures, for the next 5 years, points to increases in capital spend for large infrastructure such as generation and transmission projects needed to serve its current and projected loads. The Company is currently evaluating the impacts of the current economic conditions of its service territory as well as the financial markets to determine if any projects can be deferred due to lower growth projections. The analysis thus far indicates that even with no load growth there are many aspects of the system that need investments in order to adequately serve customers. The bottom line is that the current capital requirements outweigh the cash that Idaho Power produces, thus continuing to force the Company to debt and equity markets. The availability of those markets is questionable at the present levels that have been forecast, and wil likely not be available at dollar amounts higher than those forecasted. f. Areas with High Growth (New Meters). The deployment generally starts and completes areas with higher customer growth earlier in the project. This minimizes issues associated with deploying AMI meters for new service connections prior to the infrastructure for communications being in place and the operational issues that would create. Deploying the high growth areas first also minimizes the number of non-AMI meters required to support customer growth prior to AMI deployment and the associated costs. Additionally, as conventional meters are removed from service during the deploying of AMI in the high growth areas, these meters wil then be available for IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 installation in suffcient numbers to support the customer growth meter needs in the areas where AMI deployment has not begun. g. Ease of Implementation Logistics. The three year plan not only follows area, district, and regional boundaries but also follows electrical system boundaries. The areas, districts, and regions are set up geographically and electrically. The plan takes advantage of the boundaries to provide the best case for practical installation, process implementation, and operating cost. The personnel and "teams" can easily set up for each area, complete that area, and move on to the next in an organized and focused succession across the territory, such that the greatest operational savings can be achieved, while also providing for the logistics of completing each region. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, and Natalie Angell, Financial Analyst ", Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 REQUEST NO.2: Please categorize and explain all the required components needed to implement AMI. RESPONSE TO REQUEST NO.2: Generally, there are three main categories of components that are required to implement AMI: (A) the AMI meters/modules, (B) the substation/distribution system equipment, and (C) the operating softare. (A) The existing meters must be exchanged for the new meters containing the AMI communications modules, capable of retrieving and transmitting energy use data for at least hourly intervals. (B) For Power Line Carrier ("PLC") technology, the electrical distribution system must be equipped with the communications equipment to send and receive the data to and from the individual AMI equipped meters. This consists of equipment at the distribution substation level including: (1) Equipping each substation with a Control Receiver Unit ("CRU"). This is a microprocessor that controls the communications and processes for the substation; (2) Equipping each substation bus section with an Outbound Modulation Unit ("OMU") and a Modulation Transformer Unit ("MTU"). The OMU controls the outbound communications process and the MTU actually sends the outbound messages; (3) Equipping each substation feeder with Inbound Pickup Units ("IPUs") on each of its three phases and on the feeder neutral (4 per feeder). The IPUs receive the data from the meters and pass the information on to the station CRU; and IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY-7 (4) Implementing a backhaul communications system from the substation to the Company's internal computer network where the softare for the system is installed. It has been determined that the best option is a "frame relay" phone circuit to support the retrieval of hourly data from all metered endpoints. For the backhaul system the Company wil employ the existing systems where they are adequate and add frame relay circuits from the local phone service supplier where needed. (C) The system requires operational softare. There are three distinct systems: (1) the TWACS Net Server which controls the PLC system and retrieves data from the system; (2) the Meter Data Management System to manage the data and perform various validation and calculation functions for billng and for time variant rates (The company has implemented the Itron EE system to manage the data and perform these functions); and (3) the PROASYS System from Aclara to provide the interface between the TNS system and the Outage Management System ("OMS"). This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST NO.3: Please explain and provide detail regarding how AMI implementation throughout the remainder of the Company's service area wil differ from automated meter installation in the McCall/Emmett areas in terms of equipment, installation process and overall costs. RESPONSE TO REQUEST NO.3: The system is basically the same but there are a number of technical improvements including: (1) The AMI modules that go into the meters have been standardized which allowed the Company to take advantage of competition among meter providers. This allowed the Company to obtain the meters and the AMI modules at a lower cost for the system wide implementation than the costs for the pilot program; (2) The AMI modules have additional memory which provides greater assurance of data retrieval; and (3) There have been a number of hardware and softare improvements that provide expanded data collection bandwidth, increasing the data retrieval success rates. The installation process is essentially the same but, obviously on a much larger scale. The pilot, or Phase i, installation involved two relatively small and isolated operational areas, Emmett and McCalL. The process for installng AMI system wide wil have to accommodate much larger operating areas that are much more intertined electrically and operationally. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 REQUEST NO.4: Please provide all details of the financial analysis summarized in the August 31, 2007, Advanced Metering Infrastructure (AMI) Implementation Plan report attached 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. RESPONSE TO REQUEST NO.4: The response to this Request contains confidential information which is included with this response subject to the Protective Agreement. Enclosed is a confidential disc containing the financial analysis summarized in the August 31, 2007, Advanced Metering Infrastructure ("AMI") Implementation Plan report as well as in the attached workpaper. These documents have been provided on colored paper and marked as confidentiaL. This financial analysis was developed to provide a "snapshot" analysis of the cost-effectiveness of AMI if deployed throughout Idaho Powets entire system. As stated in the materials filed in this case, "The results of the financial analysis indicate that the long-term benefits derived from reduced operating expenses are suffcient to support a decision to move forward with AMI implementation." August 31, 2007, AMI Implementation Plan, p. 2. Recognizing that the enclosed model may be diffcult to view and understand, the Company offers to arrange for a representative of Idaho Power to work the Staff to demonstrate the model and how it works. This model was the basis of the decision in 2007 that an AMI deployment was financially viable. Although no other updates to this model have been conducted by the Company since the report was filed with the Commission, the Company used its Strategic Sourcing Process to ensure the products IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10 and services selected for the project were of the most value and at the lowest cost to the Company. As a whole, the contracts negotiated with the four vendors came in below costs estimated in the financial analysis performed in 2007. A description of the Company's Strategic Sourcing Process can be found in Response to Staffs First Production Request NO.9. If the analysis was to be replicated at this time, certain assumptions and inputs would necessarily change and results would not be exactly the same. However, the Company believes that the conclusions of the analysis would not change. The long-term benefits derived from reduced operating expenses are suffcient to support a decision to move forward with AMI implementation. This response to this Request was prepared by Courtney Waites, Pricing Analyst, Idaho Power Company, in consultation with Donovan Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11 REQUEST NO.5: Please provide an analysis showing the effect on annual 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. RESPONSE TO REQUEST NO.5: Please see the attached analysis showing the effect on annual 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. The analysis assumes year one is in today's dollars and adds the net present value of years two through thirt. The summary tab compares the net present value of the cost of depreciating the removed meters over three years to that of depreciating over five and ten years. This response to this Request was prepared by Courtney Waites, Pricing Analyst, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12 REQUEST NO.6: Please explain the features of AMI which wil be immediately utilized by the Company without the need of additional investments. RESPONSE TO REQUEST NO.6: Shortly after deployment, the Company wil shift the monthly meter reading to an automated process. Once all of the meters associated with a particular distribution substation are automated for monthly meter reading, a transition can be made to daily meter reading and automated customer movement reading/tracking can begin. Once the deployment is complete for an entire region, the Company wil implement the interface with the Outage Management System and outage management processes. It is also at this time, when deployment is complete for an entire region, that the Company can collect hourly data from all endpoints and wil be ready to support small scale time variant rate offerings. The AMI system wil have the functionality to collect hourly data from all endpoints once the deployment is complete for a region. However, the Company is stil evaluating the benefits and costs of collecting and storing this very large quantity of data for all customers. Depending on the timing of implementation and the type of time- variant pricing offered to customers, it may not be economic to collect and store hourly data for all customers, and some additional investment may be required for any given pricing program that is developed. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -13 REQUEST NO.7: The AMI system also provides a platform for future "smart grid" operations and other features. a. Please list the anticipated functionalities the Company may utilize in the future and explain its benefits. b. Please provide the projected incremental cost for each anticipated future benefit. RESPONSE TO REQUEST NO.7: In addition to the immediate benefits of automated meter reading and billng, the Company currently anticipates using the AMI system for the following: 1. Direct Customer Load Control. The AMI system wil replace the current pager based system utilized for the AC Cycling program. The system would not need to be modified to support this functionality. There is an incremental cost for the hardware that is installed in the field which is very similar to the cost of the pager units currently being deployed in the AC Cycling program. The AMI system would expand the program beyond the current range available with the pager based system. 2. Providing Additional Data to Customers on Their Energy Use. The system is capable of collecting hourly data for all metered endpoints without additional investment. The cost of providing the data to customers wil depend greatly on the media and the frequency of data delivery. 3. Time Variant Rates. The Company intends to provide hourly energy use data to support the implementation of time variant rates. As stated in Response to Request NO.6 above, the system wil fully capable of providing the data required for all metered endpoints with no additional investment. However, the IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14 Company is stil evaluating the benefits and costs of collecting and storing this very large quantity of data for all customers. Depending on the timing of implementation and the type of time-variant pricing offered to customers, it may not be economic to collect and store hourly data for all customers, and some additional investment may be required for any given pricing program that is developed. Additionally, there is the potential that the AMI system may be used for other functions, some more advanced, into the future, such as: (1) remote service connects/disconnects; (2) the in-home display of energy use or pricing data; (3) enhanced electrical system data collection such as voltage and power quality metrics; as well as (4) the automation of other distribution system functions based upon the two- way communications technology. The benefits of these potential system uses are not quantifiable and the cost would depend on the scale to which the features are implemented. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -15 REQUEST NO.8: Company stated that "achieving the full benefit from hourly data collection wil 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 offce systems" are needed to realize TOU pricing rates. RESPONSE TO REQUEST NO.8: The AMI system proposed is fully capable of providing hourly energy use data. However, the Company's current Customer Information System ("CIS") was not designed to accommodate meters with the ability to provide readings for standard rates, time variant rates, and dynamic time variant rates. Rather, it was designed to accommodate meters with fixed functionality to provide readings for standard rates. As a result, the process to establish customers ona time- variant rate such as Time of Use ("TOU") or critical peak pricing is cumbersome. It requires manual intervention within the CiS and the completion of complex manual processes to attach the required measuring components to the meter so that readings can be properly fed into the CiS and applied to the appropriate rates. Each time a customer is set up on a time-variant rate, including both new customers and customers switching to the rate, the manual process takes about 20 minutes. Given this constraint, the number of customers that can be accommodated on time-variant rates is limited until the CiS can be modified to eliminate this time-intensive manual process. This response to this Request was prepared by Maggie Brilz, Customer Service Manager, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -16 REQUEST NO.9: Please provide the written version of the Strategic Sourcing Process the Company used to select vendors and contracts to secure hardware, softare 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. RESPONSE TO REQUEST NO.9: In selecting the best vendors for the procurement of AMI Technology, IPC followed a 5 Phase Strategic Sourcing Process that develops utilizes procedures and strategies to reduce the total supply chain costs, or the company's total cost of ownership. Those five steps are: 1. Form a cross functional team and identify Stakeholders; 2. Perform internal and external market assessments through a Request for Information ("RFI") process; 3. Develop the sourcing strategy for the Request for Proposals ("RFP"); 4. Supplier screening through the RFP, selection, and negotiation process; 5. Final agreement and contract implementation. The RFI was sent to 17 suppliers of which 12 responded, the RFI specifically asked for a Company's demonstrated ability to meet the stated requirements. The cross functional team evaluated proposals on a "meets" or "does not meet" IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17 requirements basis. Two suppliers were deemed to meet these requirements: Elster and Aclara Powerline Systems. The RFP was sent to these two suppliers to further determine their capacity and capabilities and to put them in a competitive price environment. After initial evaluations by the cross-functional team, both suppliers were asked to provide Best and Final Price Proposals. Aclara lowered their price substantially from their original proposaL. After final evaluations the cross-functional team selected Aclara to move into the final negotiation stage after determining they could provide the best overall solution for the entire service territory. A core team negotiated face to face with Aclara gaining acceptance on all negotiation points including an extended warranty, 5 year fixed pricing, as well as liquidated damages to ensure delivery of the product on a timely basis to meet the implementation timeline. Final negotiations lead to terms and conditions being solidified and a final contract to be executed. The same process was used for selecting the meter manufactures with the exception of issuing an RFI. The meter companies were well established and had been previously identified. The information related to the RFI and RFP process that the Company used to evaluate and assess possible AMI solutions is quite voluminous, and much of it exists and is archived in electronic form. The Strategic Sourcing information including the RFI and RFP documentation developed for the procurement of the AMI technology and the meters can be viewed at the offces of Idaho Power Company. Please contact Doug Jones at 388-2615 or Camila Victoria at 388-5821 to make arrangements to view. Most IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -18 of these documents contain information that the bidders, selected AMI vendors, and the Company deems to be confidential, commercially sensitive, and/or trade secrets. To assure full bidder participation in future Idaho Power RFPs, as well as to protect critical, confidential commercial information of the AMI vendors the information wil be provided pursuant to the executed Confidentiality Agreement signed by the parties. This response to this Request was prepared by Kelly Hewlett, Buyer II, Corporate Services, Procurement, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19 REQUEST NO. 10: Please provide the breakdown and details of the total capital cost ("Commitment Estimate") of the AMI project. a. Please also provide total unit cost per meter by rate schedule (including labor). RESPONSE TO REQUEST NO. 10: The response to this Request contains confidential information and is being produced subject to the Protective Agreement. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20 REQUEST NO. 11: Please provide the details of the negotiated pricing and terms between the Company and its AMI vendors. RESPONSE TO REQUEST NO. 11: The response to this Request contains confidential information which is included with this response subject to the Protective Agreement. Attached please find copies of the four contracts that have been executed with the vendors to acquire the Advanced Metering Infrastructure ("AMI") modules, softare, substation equipment, and meters as well as to remove the existing meters and install the AMI equipped meters. These contracts provide the details of the negotiated pricing and terms between Idaho Power and our four AMI vendors. These documents contain information that the vendors and the Company deem to be confidential, commercially sensitive, and/or trade secrets. This information is provided pursuant to the executed Confidentiality Agreement signed by the parties. This response to this Request was prepared by Courtney Waites, Pricing Analyst, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21 REQUEST NO. 12: Please provide details of the cost of the lead-in equipment the Company ordered and purchased as of today. RESPONSE TO REQUEST NO. 12: As of November 4, 2008, the Company has purchased approximately $6,588,000 of AMI related equipment and materials. That total number breaks down further as follows:(1) the Company has received approximately $700,000 worth of AMI stations communication and backhaul infrastructure equipment; (2) the Company has on order for delivery to meet the proposed implementation start date of January 1, 2009, approximately $4,710,400 worth of AMI equipped meters (meters and AMI modules); and (3)approximately $1,177,600 worth of station and backhaul equipment. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22 REQUEST NO. 13: Please explain why the Company chose power line carrier technology over radio frequency technology or some combination of both. RESPONSE TO REQUEST NO. 13: The Company chose Power Line Carrier ("PLC") technology as the best fit for Idaho Power's system for several reasons including: (1) PLC provides better coverage for the geographic size and customer distribution of Idaho Power's system; (2) there are more complete systems utilizing PLC technology the demonstrate its full functionality; (3) PLC has a demonstrated applicability and compatibility with Idaho Power's outage management systems; and (4) a complete PLC system has a lower overall cost of ownership. Additionally, the Company found some deficiencies in the two-way fixed radio frequency network including: (1) there are currently no demonstrated, fully deployed and implemented two-way fixed radio frequency network AMI systems in operation (only in beta); (2) there are no demonstrated, in service integrations with a two-way fixed radio frequency network and Idaho Power's outage management systems; and (3) a two-way fixed radio frequency network has a higher total cost of ownership for a full deployment based upon Idaho Power's geographic service area and customer density. The Company did not choose a combination of PLC and radio technology because the total cost of ownership was higher than a complete PLC system for Idaho Power's service area and customer density. Additionally, a combined, or "hybrid" system presents a number of operational issues including: (1) managing multiple stocks of material; (2) managing AMI technology system boundaries between PLC and radio frequency areas; (3) managing multiple softare systems; (4) managing multiple installation and maintenance processes; and (5) providing training and support for IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23 multiple systems. This hybrid choice is popular with utilities that supply gas or water service along with electrical service primarily because PLC, while the best choice for electrical utilities, is not compatible with typical gas and water metering systems. Thus, many utilities that provide electricity as well as gas and/or water service have a hybrid system where PLC is utilized for electric customers, and radio frequency is utilized for their gas and/or water customers. This response to this Request was prepared by Mark Heintzelman, Delivery Service" Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24 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 wil 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. RESPONSE TO REQUEST NO. 14: When purchasing and implementing new technology that is stil evolving like AMI systems, the risk of obsolescence is always a consideration. The Company feels the TWACS PLC system offers several advantages over the other available systems. This TWACS PLC system is already deployed at a larger number of utility service territories than the other viable options and those utilities that have utilized the technology selected by Idaho Power have proven the system's ability to continue to advance the its capabilities, while remaining backwards compatible with existing equipment. The TWACS PLC system has two-way communications and demonstrated ability to make firmware changes. The Company believes that the PLC system offers the best protection against technology obsolescence because of the use of the power line as the major communications path where most other systems rely heavily upon the use of unlicensed radio signals. The TWACS PLC system chosen for this installation has the largest installed system base of any two-way fixed network AMI system. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25 This response to this Request was prepared by Mark Heintzelman, Delivery Service" Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26 REQUEST NO. 15: AMI has the ability to provide energy consumption information to the customers. Wil this information be available to customers following the deployment of AMI? Please explain. RESPONSE TO REQUEST NO. 15: Energy consumption information wil be available to the customers following the deployment of AMI. This response to this Request was prepared by Courtney Waites, Pricing Analyst, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 27 REQUEST NO. 16: Please provide a listing of the number of meters to be deployed by customer class. RESPONSE TO REQUEST NO. 16: The following table summarizes the number of meters to be deployed by customer class which includes the meters included in the response to question No. 17: Residential 389,212 Commercial 68,122 Irrigation 15,698 Total 473,032 This response to this Request was prepared by Courtney Waites, Pricing Analyst, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28 REQUEST NO. 17: What is the Company's estimate of additional meters needed due to customer growth during the deployment period? RESPONSE TO REQUEST NO. 17: The following table summarizes the Company's estimate of additional meters needed due to customer growth during the deployment period: 2009 2010 2011 Residential 6,809 5,369 8,553 Commercial 0 926 1,341 Irrigation 0 0 0 Total 6,809 6,295 9,894 This response to this Request was prepared by Courtney Waites, Pricing Analyst, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 29 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? RESPONSE TO REQUEST NO. 18: The current manual meter reading accuracy is about 99.75%. The AMI meter reading accuracy has been about 99.99%. While the percentage change is small, when it is applied to total system, it would equate to over 1,000 misreads per month that would be eliminated when AMI is fully installed.. This wil result in increased customer satisfaction, and potential cost savings. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30 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? RESPONSE TO REQUEST NO. 19: As previously stated in Response to Request Nos. 6 and 7, shortly after deployment the Company wil shift the monthly meter reading to an automated process. Once all of the meters associated with a particular distribution substation are automated for monthly meter reading, a transition can be made to daily meter reading and automated customer movement reading/tracking can begin. Once the deployment is complete for an entire region the Company wil implement the interface with the Outage Management System and outage management processes. It is also at this time, when deployment is complete for an entire region, that the Company can collect hourly data from all endpoints and wil be ready to support small scale time variant rate offerings. The "additional functionality" occurs once the deployment is complete for an entire region. This is when the Company wil be able to tie the AMI system to the outage management system and use the AMI system to support direct customer load control programs. Additionally, at that point the AMI system wil also be able to provide data for implementing time-variant rates and to give customers more information on their energy usage. However, as previously stated, some additional investment and softare development wil be needed before either of these two additional functionalities can be fully implemented. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31 REQUEST NO. 20: How compatible is the outage management system of the Company to the AMI system? a. Does the Company anticipate any problems during the outage management integration into the AMI system? Please explain. b. Did the Company test to ensure that outage management functionality is working properly with the proposed AMI system once it is implemented? Please explain. RESPONSE TO REQUEST NO. 20: a. The Company does not anticipate any problems integrating the systems. b. During the evaluation of the technology through the RFI and RFP process, as well as the Company's experience, several utilities were identified that have full TWACS PLC deployments that have integrated the same Outage Management Systems that Idaho Power currently has in service. Those utilties are using the Outage Management Systems to manage outage scoping and restoration confirmation and gave favorable reports on system integration and performance. Idaho Power did not feel that it was necessary to pilot outage management integration with the small deployment since it was fully implemented and demonstrated at other utilities. This response to this Request was prepared by Mark Heintzelman, Delivery Service II Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 32 REQUEST NO. 21: Please explain in further detail how the installation of the AMI system wil not interrupt service to the customers. a. During the exchange of the meters, wil this cause meter reading inaccuracies (Le. meter reading gap)? Please explain. RESPONSE TO REQUEST NO. 21: During the exchange of meters, customers served by self-contained meters wil see a short power interruption (several seconds). Residential customers wil receive notice before changing their meter; also, an attempt wil be made to contact them on site prior to changing any meters. Commercial customers, with metering installations requiring a short power interruption to exchange their meter, wil be contacted to scheduie an appointment prior to exchanging their meter. This is the same process that was used to exchange the 25,000 meters in 2004 for the Phase i deployment. The feedback from the Phase i deployment was very positive. The Company did not experience reading inaccuracies or reading gaps in previous meter exchange programs or in the initial AMI deployment, and does not anticipate any issues with the deployment moving forward. This response to this Request was prepared by Mark Heintzelman, Delivery Service" Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 33 REQUEST NO. 22: What is the expected useful life and failure rate for AMI meters compared to the existing conventional meters? RESPONSE TO REQUEST NO. 22: The current useful life for non AMI meters is 20 years, and for AMI meters it is 15 years. The failure rate for non AMI mechanical meters has historically been around 1 % per year, the failure rate for solid-state meters with AMI modules has been between 0.5% and 1 % per year in the Phase i area. One significant difference is in full replacement warranty. The warranty on meters prior to AMI was a one year full replacement, but because of the volume and competition for AMI meters, a 3-year full replacement warranty was secured on both the meters and the AMI modules. This response to this Request was prepared by Mark Heintzelman, Delivery Service" Leader, Idaho Power Company, in consultation with Donovan E. Walker, Corporate Counsel, Idaho Power Company. DATED at Boise, Idaho, this 18th day of November 2008. - OVAN E. WALKER Attorney for Idaho Power Company LISA D. NORDSTROM Attorney for Idaho Power Company BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 34 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 18th day of November 2008, I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Neil Price, Esq. Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 -lHand Delivered U.S. Mail _ Overnight Mail FAX -X Email neil.price(ãpuc.idaho.gov Kroger Co. Michael L. Kurt Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Hand Delivered -LU.S.Mail _ Overnight Mail FAX -l Email mkurt(ãSKLlawfrm.com kboehm(ãBKLlawfirm .com Kevin Higgins Energy Strategies, LLC Parkside Towers 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Hand Delivered -LU.S.Mail _ Overnight Mail FAX -lEmail strat.com Donovan E. Walker IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 35