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HomeMy WebLinkAbout20081121IPC to Staff 23-51.pdfDONOVAN E. WALKER Corporate Counsel eslDA~POR~ An IDACORP Company November 21,2008 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 Second Production Request of the Commission Staff. The response to Request No. 49 calls for substantial analysis and calculation and, therefore, wil be provided as soon. as possible. 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 DONOVANE. 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 dwalkercaidahopower.com bklinecaidahopower.com RECE1Vt:t" 20DBNOV 21 . c. Li PH 3: OS UTtdß1sO PUBLíc COMMISSJO,11 iy 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 MATTER 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 SECOND METERING INFRASTRUCTURE ("AMI") ) PRODUCTION REQUEST OF THE TECHNOLOGY THROUGHOUT ITS ) COMMISSION STAFF TO IDAHOSERVICE TERRITORY ) POWER COMPANY ) COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the Commission Staffs Second Production Request to Idaho Power Company dated October 31,2008, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO. 23: What intervals wil Idaho Power use for reading meters with the AMI system? RESPONSE TO REQUEST NO. 23: The AMI system wil be set up to read each meter daily beginning at midnight followed by three additional readings at eight hour intervals. The Company is also planning to collect 15 minute energy consumption on a smaller subset of customers for electrical system and energy consumption modeling. 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 SECOND PRODUCTION. REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST NO. 24: Does Idaho Power plan to use the AMI technology for remote connects and disconnects in the future? Please explain. RESPONSE TO REQUEST NO. 24: At this time, the Company has not identified any sites for installation of remote connect/disconnect devices, and has no plans to deploy these devices as part of the initial AMI deployment. However, upon an individual case evaluation, the Company may consider connect/disconnect devices for a customer in a remote location where the account has a high connect/disconnect activity. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO. 25: What are the read success rates and percentage of estimated readings with Idaho Power's existing metering system? What are the anticipated read success rates and percentage of estimated readings with the proposed AMI system? RESPONSE TO REQUEST NO. 25: Method of Monthly kWh Daily kWh Read Hourly Reading Billng Read Success Rate Consumption Success Rate Data Read Success Rate Manual 98.77%NA NA AMI 99.9%99.9%98% The above information is based on the most recent 12 months of data. It is important to understand that the actual percent of estimated reads for manually read meters is as high as 4.15% in the winter months, driving the average to 1.33% for the year. Also, the Phase I AMI area was historically our highest winter estimated read area; however, with AMI there are no longer seasonal increases in estimated reads as a result of snow. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 REQUEST NO. 26: What is the expected failure rate for AMI system meters compared with conventional meters? RESPONSE TO REQUEST NO. 26: Please see Idaho Power's response to Request No. 22 of Staffs First Production Request. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 REQUEST NO. 27: What is the risk of long-term failure and what would be the cost of temporary resources to manually read meters in the event of failure? RESPONSE TO REQUEST NO. 27: The AMI system chosen is the only two- way fixed network system capable of retrieving hourly data from all end points. This system has been fully deployed at a large number of utilities for more than 10 years. Through the investigation process, the Company did not uncover any incidents of catastrophic meter or communications failure that resulted in significant reading estimations. The chosen system represents the least risk alternative for AMI installation. Based on the experience of other utilities with this system, and the Company's Phase i experience, short of a major natural disaster or similar event that would have also prevented reading of the current meters, there is no foreseeable impact on the ability to read the AMI meters. Additionally, there are several documented incidences in Pennsylvania and Florida where this system's performance during natural disasters far exceeded the performance of manual processes. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 REQUEST NO. 28: How often do meter readers notice and report problems with the Idaho Power infrastructure as a result of their rounds? RESPONSE TO REQUEST NO. 28: The Company does not keep records on how frequently infrastructure problems are reported by personnel assigned to meter reading as meter reading personnel are not trained to provide detailed inspection of the distribution system. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 REQUEST NO. 29: Wil there be more visual surveilance required of the system by other Idaho Power personnel after the meter readers are no longer making rounds? RESPONSE TO REQUEST NO. 29: The Company does not plan additional visual surveilance of the system after AMI deployment. The frequent communications planned for the AMI system and built in system monitoring capabilities wil be more effective for timely discovery of most system problems. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST NO. 30: A PLC system can generally reach all end points serviced by the utility. Under what circumstances might the PLC system be unable to read a meter? RESPONSE TO REQUEST NO. 30: The planned PLC system cannot communicate with meters when there is no power to the meter. There is a short period after outage restoration or major switching events when the system might not be able to catch-up on the read schedule and obtain all readings from the system. In this type of event, the Company would prioritize meter reading to obtain critical billng data, and plan to use the system's memory capabilities to obtain any critical billng reads that were not obtained by the rescheduling of priorities. Also, the PLC system can have diffculty communicating with meters when there is noise on the power line, loose connections, or overloaded equipment. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 REQUEST NO. 31: Can the new AMI meters be read in the same manner as the existing meters if it is necessary to do so? If not, please explain. RESPONSE TO REQUEST NO. 31: All AMI meters wil display the current kWh and kW on an LCD display. Site readings can be obtained for kWh and kW if necessary. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10 REQUEST NO. 32: With AMI wil the Company be able to schedule a future meter read to automatically read the meter on a customer's requested closing or opening date? RESPONSE TO REQUEST NO. 32: The AMI meter wil be scheduled for reading four times a day, the Company wil use the scheduled midnight read the day of the request to complete all closing and opening meter read requests. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11 REQUEST NO. 33: How many regular cycle bils were sent to customers in 2007? RESPONSE TO REQUEST NO. 33: Idaho Power sent 5,206,214 regular cycle bils to its customers in Idaho in 2007. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -12 REQUEST NO. 34: How many regular cycle bils sent to customers in 2007 were estimated (not based on an actual meter reading)? RESPONSE TO REQUEST NO. 34: Idaho Power sent 25,411 regular cycle bils that were based on estimated usage to customers in Idaho in 2007. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -13 REQUEST NO. 35: How many out of cycle (opening or closing) bils were sent to customers in 2007? RESPONSE TO REQUEST NO. 35: Idaho Power does not send out-of-cycle opening bils. In 2007, 85,640 out-of-cycle closing bils were sent to customers in Idaho. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14 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? RESPONSE TO REQUEST NO. 36: Idaho Power does not leave meters connected between customers. If a new customer does' not request service at a premise for which the current customer has requested service be discontinued, the service is disconnected. As a result, Idaho Power does not incur unbiledkWh between customers. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15 REQUEST NO. 37: With the abilty to obtain out of cycle meter readings through the proposed AMI system, how wil Idaho Power handle physical disconnects when a customer closes his/her account? Wil there be an increase in unbiled kWh going forward? RESPONSE TO REQUEST NO. 37: For customer movement activities where a customer moves out and another moves in, or a "landlord" agreement is in place, the Company wil complete these requests with a reading from the AMI system. In the situation where the customer wants the power turned off and another customer is not taking over the service, or there is no "landlord" agreement in place, the Company wil continue to perform a physical disconnect. There wil be no increase in unbiled revenue as a result of implementing AMI to collect readings to support customer movement activity. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16 REQUEST NO. 38: Regarding opening bils prepared outside of regular biling cycles in 2007, please provide how many of the readings on which the bils were based were determined by: (a) an actual meter reading taken 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. RESPONSE TO REQUEST NO. 38: Idaho Power does not prepare opening bils outside of regular billing cycles. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17 REQUEST NO. 39: Please provide the year-to-year percentage decrease or increase in the total number of estimated meter readings for 2004-2007. RESPONSE TO REQUEST NO. 39: As can be observed in the table below, in years with heavy snow fall and wet springs such as 2005 - 2006, the estimated meter reading percentage wil increase. The total Company estimated meter reading percent change is: Year Percentage Difference 2004 -'2005 -23.80% 2005-2006 28.25% 2006 - 2007 -15.70% 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18 REQUEST NO. 40: Please provide the year-to-year percentage decrease or increase in the total number of misread or incorrect meter readings for 2004-2007. RESPONSE TO REQUEST NO. 40: The total Company misread or incorrect meter readings percent change is: Year Percentage Difference 2004 -2005 1.70% 2005 - 2006 -0.05% 2006 -2007 -4.30% 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19 REQUEST NO. 41: Please provide the reasons for and number of instances in 2007 where the Company had to rebil customers because a previous bil was based on incorrect biling determinants, e.g., incorrect identification of multiplier or meter size. RESPONSE TO REQUEST NO. 41: In 2007, Idaho Power prepared 15,658 corrected billngs. The specific reason for a corrected biling is not captured within the Company's Customer Information System ("CIS"). Therefore, a tally of the specific reasons for corrected billngs is not available. However, in 2007, the Company identified 10,339 instances in which a meter reading problem, such as an incorrect reading, was recorded. In addition, the Company identified 1,366 instances in which a meter equipment problem, such as a failed meter, was recorded. In almost all cases, a meter reading problem and a meter equipment problem resulted in a corrected billng. In 2007, there were 5,440 instances in which a request was made either by a customer or customer service representative for a meter re-read. Not all requests for meter re- reads result in corrected bilings, and a specific count of rebillngs resulting from these meter re-reads is not available. The total number of meter reads performed by the Company in 2007 was 5,738,903. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20 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? RESPONSE TO REQUEST NO. 42: The percentage and number of installed meters or metering equipment that failed for the years 2004-2007 are: Year Total Percentage 2004 2,566 .57% 2005 2,982 .65% 2006 2,734 .57% 2007 2,402 .50% The failure rate for AMI meters is anticipated to be similar to the historic failure rates on regular kWh meters. However, meter failures wil typically be discovered faster by AMI meters due to frequently scheduled meter reads. By reducing the detection and repair time, the biling impact of meter failures wil be minimized. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21 REQUEST NO. 43: Please explain how meter reading data is entered into the billng system currently. How wil this change with AMI? RESPONSE TO REQUEST NO. 43: In the Company's manual monthly meter reading process, billng reads are collected in a handheld electronic device and loaded into the Multi-Vender Reading System ("MVRS"). The MVRS performs validation on the readings and then a batch file loads the readings into the billng system. The AMI system meter reads wil be collected by the TWACS net server system on a preset schedule 4 times a day. The reads wil then be transferred to the Meter Data Management System ("MDMS") daily. Once the MDMS performs data validation, the TOU billng component calculation wil upload to the biling system via a system interface. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22 REQUEST NO. 44: Please explain how low income and other vulnerable customers wil benefit from AMI implementation? RESPONSE TO REQUEST NO. 44: Low income and other vulnerable customers wil benefit from AMI implementation in the same manner as other residential customers. All customers wil see lower overall costs, outage management benefits, more energy consumption information, and, eventually, increased pricing options with the extension of existing programs and the introduction of new ones. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23 REQUEST NO. 45: Is Idaho Power planning on making its current AMI pilot programs, i.e. Time-of-Day Program and Energy Watch, available to all customers during or after the meter conversion? If not, why? RESPONSE TO REQUEST NO. 45: As AMI is rolled out across our service territory, the Company plans on implementing more dynamic pricing programs for all customers, including time of use and critical peak pricing programs like the Time-of-Day and Energy Watch programs currently in place. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24 REQUEST NO. 46: Is the Company planning on introducing any new pilot programs with the deployment of AMI? If so, please provide a detailed description of any new programs. RESPONSE TO REQUEST NO. 46: The Company has done substantial research into various dynamic pricing programs that may be offered to customers with the completion of the AMI deployment, including time of use, critical peak, variable peak, and real time pricing programs as well as demand response programs like interruptible rates. However, as Mr. Gale stated in his testimony, additional investments wil be required before wide scale applications of such pricing programs becomes a reality. Because of the need for these additional back offce systems, exactly what programs wil be offered has not yet been determined. The Company continually explores and monitors pricing program results from utilities across the nation. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25 REQUEST NO. 47: Currently, what is the time delay for displaying customer usage and biling information on the Company's website for current AMI customers? What is the Company's goal for providing customer usage and billng information after AMI meters are fully installed? RESPONSE TO REQUEST NO. 47: Current AMI customers can view their hourly data online once they are registered as an Account Manager. Once logged on, the most recent hourly data available to customers is 14 days prior to the current date. As AMI is fully deployed, the Company's goal is to provide this data to customers on time variant rates, if desired, by the third business day. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26 REQUEST NO. 48: What plans does the Company have for implementing Time of Use rates after AMI has been fully deployed? RESPONSE TO REQUEST NO. 48: Please see Idaho Power's response to Request No. 46 of Staffs Second Production Request. 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 27 REQUEST NO. 49: Insofar as it has not been already provided in a response to a prior request, please provide an annual revenue requirement impact of the AMI implementation for each year of the project life. Please include the impact assuming existing meters are depreciated over 3 years, 5 years, 10 years and without accelerated depreciation. RESPONSE TO REQUEST NO. 49: The response for this Request calls for substantial analysis and calculation. It requires additional time and review and wil be made available as soon as possible. This response to this Request was prepared by Donovan E. Walker, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28 REQUEST NO. 50: Insofar as it has not been already provided in a response to a prior request, please provide the annual savings in meter reading expenses over the project life. Please include the assumptions used to determine the growth in current meter reading expenses. RESPONSE TO REQUEST NO. 50: When analyzing the benefits AMI wil provide with regard to meter reading, the Company looked at all the functions of a meter reader's job. These include collections, connect/disconnects, random and periodic testing of meters, verifications, unplanned maintenance, new installations, and actual meter reading. Based on these duties, it was determined AMI would reduce O&M expenses associated with meter reading 100 percent and with disconnects and connects 90 percent. Therefore, the following breakout of annual savings is based on a reduction of meter readings, disconnects, and connects duties: 2009 $ 262,827 2010 $2,915,385 2011 $5,164,680 Please refer to the confidential financial analysis provided on disk by Idaho Power in response to Staffs First Production Request No. 4 for assumptions used to determine growth in current meter reading expenses under the tab titled "Growth." 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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 29 REQUEST NO. 51: Please list the benefis 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. RESPONSE TO REQUEST NO. 51: The McCall and Emmett area customers who currently have AMI in place benefit from more energy consumption information and the Emmett area customers have dynamic pricing program options. When AMI is fully deployed, all customers wil see lower overall costs, outage management benefits, more energy consumption information, and, eventually, increased pricing options with the extension of existing programs and the introduction of new ones. For a more detailed description of the benefits AMI will provide, see page 8 of the Advanced Metering Infrastructure (AMI) Status Report dated May 1, 2007, filed with the Commission. 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. DATED at Boise, Idaho, this 21st day of November 2008. ~f~ DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 21st day of November 2008, I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND 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 Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 -XHand Delivered U.S. Mail _ Overnight Mail FAX -X Email neil.pricecæpuc.idaho.gov Kroger Co. Michael L. Kurt Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email mkurtcæBKLlawfirm.com kboehmcæBKLlawfirm .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 -X Email khigginscæenergystrat.com cGfU£ Donovan E. Walker IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31