20090604ICL 1-21 to IPC.pdf

Betsy Bridge, ISB #8111
Idaho Conservation League
POBox 844
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
bbridge(Ðwildidaho.org
RECEIVED
tOng JUN -4 PH 3: 40
IDAHO PUBl.iÇ
UTILITIES COMMltiSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE IDAHO POWER
COMPAN'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE LANGLEY
GULCH POWER PLANT
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CASE NO. IPC-E-09-03
FIRST PRODUCTION
REQUEST OF THE IDAHO
CONSERVATION LEAGUE
Pursuant to Idaho Public Utilties Commission (the "Commission") Rule of Procedure
225, the Idaho Conservation League ("ICL") by and through their attorney of record, Betsy
Bridge, hereby requests that Idaho Power Company ("Company") provide the following
documents.
This production request is to be considered as continuing, and the Company 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.
Please provide one physical copy and one electronic copy, if available, of your answer to
Ms. Bridge at the address noted above. For each item, please indicate the name of the person(s)
preparing the answers, along with the job title of such person(s) and the witness at hearng who
can sponsor the answer.
FIRST PRODUCTION REQUEST OF
THE IDAHO CONSERVATION LEAGUE
IPC-E-09-03
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REQUEST FOR PRODUCTION NO.1:
According to Response to Staff Request # 6, since the selection of the Langley Gulch project
there have been no changes to the Company's load projections that have either accelerated or
deferred the on-line dates need for this resource. Please provide an updated 10-year load
forecast, which incorporates the impacts of the economic downtu.
REQUEST FOR PRODUCTION NO.2:
Provide the updated load forecast data in equivalent form as shown IPC's 2008 IRP Update,
Section 3. Planning Period Forecasts:
A. Table 2. Range of System Load Growt Forecasts (aMW) 2008 IR Update, page 11.
B. Table 3. Change in System Load Growt (aMW) 2008 IR Update vs. 2006 IRP, page
12. Please modify the table to compare the requested updated load forecast with the
2008, not 2006 IR.
C. Figue 2. Forecasted Firm Load - 70t Percentile, page 12.
D. Table 4, Rage of System Peak Growt Forecasts (MW) 2008 IRP Update, page 13.
E. Table 5, Change in System Peak Growt (MW) 2008 IR Update, page 13.
F. Figue 3. Forecasted Fir Sumer Peak - 95th Percentile, page 13.
REQUEST FOR PRODUCTION NO.3:
Please provide a sumar worksheet that indicates for the 2008 IPR Update and the requested
load forecast update by the years 2008,2012, and 2016, the data for the key varables that
underlie the load forecast including but not limited to the following data listed as follows in (A),
(B), and (C).
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A. Residential, Commercial, Industral, Agrcultual, and Additional Firm Load, and
Contract Off System Load (i.e. the input data in Appendix A - Sales and Load Forecast,
IPC 2006 Load Forecast).
B. Employment by Nonagrcultual, Mining, Constrction, Manufactung, Transportation /
Communications / Utilties, Wholesale and Retail Trade, Finance / Insurance / Real
Estate, Services, and Governent (i.e. the input data in Appendix C - Economic
Forecast, IPC 2006 Load Forecast).
C. Total Personal Income, Per Capita Personal Income, Population (i.e. the input data in
Appendix C - Economic Forecast, IPC 2006 Load Forecast).
REQUEST FOR PRODUCTION NO.4:
Please provide the source data for each of the items (a), (b), and (c) listed in Request for
Production No.3 above.
REQUEST FOR PRODUCTION NO.5:
IPC's 2006 IRP Appendix A - Sales and Load Forecasts at pages 7 - 9 the section entitled "Load
Forecasts Based on Economic Uncertainty", provides the results of two additional load forecasts
for the Idaho Power service area that provide a range of possible load growts for the 2005-2025
planning period due to variable economic and demographic conditions. As stated in the 2006
IRP Appendix A page 7: "The average growt rates for the high and low growt scenaros were
derived from the historical distrbution of one-year growth rates over the period 1979 - 2005."
The result is Firm Load Growt Rate per year 2005 - 2025 of 1.9% for the Expected Scenaro,
and 2.4% and 1.5% for the High and Low Scenaros, respectively.
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A. If there is a similar load forecast sensitivity analysis for IPC's 2008 IR Update, please
provide the results of that analysis in a format similar to the 2006 IR.
B. If there was not a load forecast sensitivity analysis conducted for IPC's 2008 IR Update,
please explain why.
C. If there is a similar load forecast sensitivity analysis for IPC's Febru 2009 IRP
Addendum using IPC's Augut 2008 load forecast, please provide the results of that
analysis in a format similar to the 2006 IR.
D. If there is not a load forecast sensitivity analysis conducted for IPC's Februar 2009 IRP
Addendum using IPC's August 2008 load forecast, please explain why.
REQUEST FOR PRODUCTION NO.6:
IPC's 2008 IR Update, Section 3. Planing Period Forecasts, page 10, states that "The recent
cyclical slowdown in customer growt, as indicated in the total number of customers for year
end 2007 is approximately thee tenths of a percent lower than forecast (0.3%). The effect of the
cyclical downtu on the longer term trend will be evaluated for the 2009 IRP." Please provide
the results of all analyses in preliminar, intermediate, or fial form conducted by or for IPC
concerning the effect of the cyclical downtu on the IPC's most recent published forecast.
A. Ifno such analyses in preliminar, intermediate, or final form have been conducted,
please explain why.
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REQUEST FOR PRODUCTION NO.7:
Concerning IPC's August 2009 load forecast, please provide all preliminar, intermediate, or
final results.
A. If no preliminar or intermediate results are available, please indicate when such results
wil be available.
B. Please provide all preliminary or intermediate results when available.
REQUEST FOR PRODUCTION NO.8:
Please provide IPC load data by customer category on a monthly basis beginning with 2004 and
though the latest available month of 2009. Please provide the requested information by:
A. Sales.
B. Number of customers.
C. Heating and cooling degree-day data.
D. Normal heating and cooling degree-day data.
REQUEST FOR PRODUCTION NO.7:
Please provide the following information regarding IPC's residential customers on a monthly
basis beginning with 2008 and though the latest available month of 2009:
A. The number of idle residential meters (meters that exist with no customers tang
service).
B. The number of residential meters with usage ofless than 50 kWh per month.
C. The number of residential customers in arears by more than 30 days, 60 days, and 90
days.
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D. The number of disconnection notices served in each month,
E. The number of actual disconnections for non-payment in each month.
F. The number of reconnections in each month.
REQUEST FOR PRODUCTION NO.8:
Please provide an equivalent "Average Energy Load and Resource Balance" spreadsheet per
IPC's 2008 Updated IR Appendix C, page 96, "70th Percentile Water and 70th Percentile
Average Load" on a monthly basis January 2012 though December 2012" based on the
requested load forecast update in Request for Production No. 1 above.
REQUEST FOR PRODUCTION NO.9:
Please provide additional "Average Energy Load and Resource Balance" spreadsheets per IPC's
2008 Updated IRP Appendix C, page 96, "70th Percentile Water and 70t Percentile Average
Load" for 2013 and beyond until the need for the proposed 330 MW Langely Gulch Power Plant
is demonstrted based on the requested load forecast update in Request for Production No. 1
above.
REQUEST FOR PRODUCTION NO. 10:
In regard to the Request for Production No.8 and 9, for the peak summer month of July 2012
and the peak summer month of2013 - 2016, for the data entr of "Monthly SurluslDeficit"
under the category "Existing Resources" please provide the following information:
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A. Hourly load distrbution cure of the projected monthly deficit: i.e., disaggregating the
monthly figue into 744 hours.
B. Geographic location (or distribution) of the projected monthly deficit, disaggregated by
hour if available.
REQUEST FOR PRODUCTION NO. 11:
In regard to IPC's Februar 2009 Addendum for the Boardman to Hemingway Transmission
Project, Appendix B - Load and Resource Balance, in the year 2012 though 2020, IPC assumes
Total Power Puchase Agreements of 47 MW in the month of July. Given the downward
pressure on electrcity demand in the Western region from the recession, please provide the
results of all analysis conducted by or for IPC of increasing Power Puchases in 2012 though
2020 above the 47 MW included in IPC's February 2009 Addendum.
A. Ifno such analysis has been conducted, please provide IPC's opinion as to the increased
availabilty of purchased power given the downward pressure on electrcity demand in
the Western region from the recession.
REQUEST FOR PRODUCTION NO. 12:
Idaho Public Utilities Commission Order No. 30171 approved significant changes to IPC's
Irrgation Peak Rewards Program. The changes authorized a new dispatchable curilment
program that is expected to increase avoided peak demand from the 35 MW realized durng the
summer of2008 to an estimated 144 MW in 2009, 186 MW in 2010, and 232 MW in 2011.
Please provide the results of all analysis on the change in the forecasted "Monthly Surlus /
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Deficit" for the peak summer month of July 2012 and the peak sumer month of 20 13 - 2016
for the:
A. IPC 2008 IRP Update.
B. IPC Febru 2009 IR Addendum.
REQUEST FOR PRODUCTION NO. 13:
On March 13, 2009, Idao Power fied Case No. IPC-E-09-05 with the IPUC to increase the
Idao Rider from 2.5 percent of base rate revenues to 4.75 percent. Please provide the results of
all analysis including preliminar and intermediate estimates of projected increase in IPC
incremental energy effciency and demand response anual energy and peak demand savings by
year beginning with 2010 through 2016. Please provide the results of all analysis on the change
in the forecasted "Monthly Surplus / Deficit" for the peak summer month of July 2012 and the
peak summer month of 20 13 - 2016 for the:
A. IPC 2008 IR Update.
B. IPC Februar 2009 IR Addendum.
REQUEST FOR PRODUCTION NO. 14:
As mentioned in the Response to Staff Request #53, in 2008 IPC contracted with Nexant
Consulting to produce a DSM Potential Study. Preliminar results and computer models
provided by Nexant are being used to identify new DSM potential for the 2009 IRP. Please
provide the preliminar results from the Nexant DSM Potential Study.
FIRST PRODUCTION REQUEST OF
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REQUEST FOR PRODUCTION NO. 15:
As mentioned in the Response to Staff Request #53, Idaho Power Company's DSM cost
effectiveness methodology is described on pages 62-73 of 2006 IRP Technical Appendix D. On
page 73 of that report the DSM plans deemed to be cost effective have total resource cost (TRC)
levelized costs of between $0.035 and 0.044 cents per kWh. How many aMW and Summer Peak
MW would be cost effective if the analysis were to be ru using a cutoff of $0. 125 cents per
kWh, which amount corresponds to the levelized cost estimated for a CCCT presented at the
Febru 3, 2009 IRPAC meeting.
A. How many aMW and Summer Peak MW would be cost effective if the analysis were to
be ru using a cutoff the Residential Tarff third tier price point?
REQUEST FOR PRODUCTION NO. 16:
As mentioned in Response to Staff Request #55, in 2009 IPC plans to expand its effort in energy
efficiency in a number of areas, including via IPUC Case No. IPC-E-09-02, a demand response
program to its commercial and industral customers though a third-par demand response
aggregator. Please provide the results of all preliminar analysis indicating the projected
increase in IPC incremental energy effciency and demand response anual energy and peak
demand savings by year begining with 2010 through 2016.
REQUEST FOR PRODUCTION NO. 17:
As mentioned in Response to Staff Request #55, in 2009 IPC has been trsitioning from
traditional flat rate designs towards more time differentiated pricing for a number of year, and
that the Company envisions widespread use of dynamic pricing across the system. Please provide
FIRST PRODUCTION REQUEST OF
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IPC-E-09-03
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the results of all preliminar analysis indicating the projected decreases in customer peak
demand requirements from differentiated pricing and dynamic pricing by year begining with
2010 though 2016.
REQUEST FOR PRODUCTION NO. 18:
As mentioned in Response to Staff Request #55, since 2005, IPC has operated a successful
Critical Peak Pricing progr in the Emmett Valley with customers who piloted its Advanced
Metering Infrstrctue (AM) system. Please provide the results of the projected decreases in
customer peak demand requirements from the Emmett Valley AM program from 2005 though
2008.
A. Please provide the projected decreases in customer peak demand requirements from the
Emmett Valley AM program for 2009 though 2016.
B. Please indicate all plans to expand the successful Emmett Valley Critical Peak Pricing
program to other pars ofIPC's service terrtory.
REQUEST FOR PRODUCTION NO. 19:
When estimating futue customer loads, how does Idaho Power Company account for reductions
in customer demand due to increases in electrcity prices?
A. How does the Company estimate this price elasticity?
B. Provide any studies conducted by or for IPC or relied upon by IPC to estimate price
elasticity.
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REQUEST FOR PRODUCTION NO. 20:
Please describe what preparations Idaho Power is making in anticipation of federal renewable
electricity standard ("RES"), specifically:
A. Please describe how the acquisition of renewable energy to meet a federal RPS affects the
need for the Langley Gulch project.
B. IfIdaho Power must meet an RES that requires 20 percent of electrcity generated for
retail customers to come from renewable sources by 2020 how many megawatts of
renewable energy must be brought online with Langley Gulch and without Langley
Gulch?
C. If an analysis has not been conducted please explain in detail how the company believes
it is prudent to go forward with this project without the analysis. Please provide any and
all memos and documentation of discussion regarding an anticipated RES.
REQUEST FOR PRODUCTION NO. 21:
Please describe what preparations Idaho Power is making in anticipation of federal cap and trde
system, specifically:
A. Please provide information on Idao Power's carbon dioxide emissions, specifically total
tons emitted and the amount of carbon emissions expected from the Langley Gulch plant.
B. Please provide an analysis of how the additional carbon emissions from Langley Gulch
wil affect Idaho Power and its ratepayers under the proposed cap and trade system in the
American Clean Energy and Securty Act of 2009 or other proposed cap and trade
systems.
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C. If an analysis has not been conducted please explain in detail and how the company
believes it is prudent to go forward with this project without the analysis. Please provide
any and all memos and documentation of discussion regarding an anticipated cap and
trade system.
Dated: June 4, 2009 Respectfully submitted,
FIRST PRODUCTION REQUEST OF 12
THE IDAHO CONSERVATION LEAGUE
IPC-E-09-03
CERTIFICATE OF SERVICE
I hereby certify that on this 4th day of June, 2009, tre and correct copies of the foregoing
FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE were
delivered to the following persons via the method of service noted:
Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
427 W. Washington St.
Boise, ID 83702-5983
j jewell(iuc. state. id. us
~ Hand Delivery
U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile
Lisa Nordstrom
Baron L. Kline
Idaho Power Company
POBox 70
Boise, ID 83707-0070
Inordstrom(lidahopower.com
bkline(lidahopower.com
_ Hand Delivery
~ U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile
Scott Woodbur
Deputy Attorney General
Idaho Public Utilties Commission
427 W. Washington St.
Boise, ID 83702-5983
Scott. woodbur(iuc.idaho.gov
~Hand Delivery
_ U.S. Mail, postage pre-paid
x Electronic Mail
Facsimile
Pete Richardson, Esq.
Richardson & O'Lear
515 N. 27th Street
PO Box 7218
Boise, ID 83702
peter(lrichardsonandolear.com
Hand Delivery
~ U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile
Don Reading
6070 Hil Road
Boise, ID 83703
dreading(lmindspring.com
Hand Delivery
~ U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile
FIRST PRODUCTION REQUEST OF
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IPC-E-09-03
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Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
elo(lracinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage OH 44140
tony(lyane1.net
Ken Miler
Clean Energy Program Dirctor
Snake River Allance
PO Box 1731
Boise, ID 83701
kmiler(lsnakeriverallance.org
Brad Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID 83702
bmpurdy(lhotmail.com
Susan Ackerman
9883 NW Nottge Dr.
Portland, OR
susan.k.ackerman(lcomcast.net
Robert Ka
rkah(lnippc.org
FIRST PRODUCTION REQUEST OF
THE IDAHO CONSERVATION LEAGUE
IPC- E-09-03
_ Hand Delivery
~ U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile
_ Hand Delivery
~ U.S. Mail, postage pre-paid
2- Electronic Mail
Facsimile
~ Hand Delivery
_ U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile
_ Hand Delivery
~U.S. Mail, postage pre-paid
2- Electronic Mail
Facsimile
_ Hand Delivery
2. U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile
_ Hand Delivery
_ U.S. Mail, postage pre-paid
~ Electronic Mail
Facsimile ,/--
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