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Home My WebLink About20090615IPC to ICL 8, 15(sic).pdf1SIlW~POR~ An IDACORP Company LISA D. NORDSTROM Senior Counsel June 12, 2009 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-09-03 LANGLEY GULCH POWER PLANT Dear Ms. Jewell: Enclosed for filing are an original and three (3) copies of Idaho Power Company's Response to the First Production Request of the Idaho Conservation League (second batch) in the above matter. In addition, also enclosed are non-confidential and confidential disks (four (4) copies of each) containing information responsive to the Conservation League's requests. Please note the confidential information should be handled in accordance with the Protective Agreement in place between the parties. If you have any questions about the enclosed information, please let me know. Very truly yours, (~£:!I0~ LDN:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise. 10 83702 CERTIFICATE OF ATTORNEY RECEIVED ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURIN~§UN 12 PM ~:.., COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDING ARE PROTECTED FROM PUBLIC INSPECTION U.TIL',DT.AleHsOcPo. ie ISSION Case No. IPC-E-09-03 The undersigned attorney, in accordance with RP 233, hereby certifies as follows: 1. The Response to Production Request No. 8 propounded by the Idaho Conservation League during the course of the above-referenced case contains information that is a trade secret or privileged or confidential as described in Idaho Code § 9-340, et seq., and § 48-801, et seq., and as such is exempt from public inspection, examination, or copying. DATED this 1ih day of June 2009. ~CI~ LISA D. NORDSTROM Counsel for Idaho Power Company REQUEST FOR PRODUCTION NO.8: Please provide IPC load data by customer category on a monthly basis beginning with 2004 and through 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. RESPONSE TO REQUEST FOR PRODUCTION NO.8: The requested information is included on the enclosed CD. Because the most recent data is material non-public information under SEC Regulation FD and is considered confidential information, it has only been provided to those parties that have executed the Protective Agreement in place in this matter. The response to this Request was prepared by Barr Smith, Planning Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 2 BARTON L. KLINE, ISB #1526 LISA D. NORDSTROM, ISB #5733 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: 208-388-2682 Facsimile: 208-388-6936 bklineCâidahopower.com InordstromCâidahopower.com RECE.\VEO iOnq JUN \ 2 PM l¡: 48 \DAHsOcPJW~\(Šs \0 ('l u,.\L\TIE. ~ , 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 IDAHO POWER COMPANY'S APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE LANGLEY GULCH POWER PLANT. ) ) CASE NO. IPC-E-09-03 ) ) IDAHO POWER COMPANY'S ) RESPONSE TO THE FIRST ) PRODUCTION REQUEST OF THE ) IDAHO CONSERVATION LEAGUE COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the First Production Request of the Idaho Conservation League dated June 4, 2009, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE-1 REQUEST FOR PRODUCTION NO. 1S(sic): 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 run using a cutoff of $0.1 25 cents per kWh, which amount corresponds to the levelized cost estimated for a CCCT presented at the February 3, 2009 IRPAC meeting. A. How many aMW and Summer Peak MW would be cost effective if the analysis were to be run using a cutoff the Residential Tariff third tier price point? RESPONSE TO REQUEST FOR PRODUCTION NO. 1S(sic): An analysis of potential reduction in aMW and Sumer Peak MW using a cutoff of $0.125 has not been performed. Performing the analysis described in the request would produce unreasonable and misleading results. Utilizing only the levelized cost of a program ignores the fact that energy savings benefits vary by time of day and by season. Comparing the levelized cost of a demand-side resource to the levelized cost of a single supply-side resource does not provide any relevant information regarding the economic potential of the demand-side resource. Such a comparison incorrectly assumes there are no hourly variations in load reduction associated with the demand-side resource. As stated in the Company's Response to Staff's Request No. 53, as part of the process of identifying price alternatives, Idaho Power follows the cost-effectiveness methodology as described in the DSM Annual Report and the Company's IRP. The most current description of this methodology can be found in the 2008 DSM Annual IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 3 Report on page 11 and in the 2006 IRP Technical Appendix D on pages 62-73. Using the accepted methodology, the Company is able to calculate the value of the energy savings attributed to a DSM program by using end-use load shapes in conjunction with the five DSM alternative cost pricing periods described in the Technical Appendix of each IRP. The DSM alternative energy costs are published in the Technical Appendix of each IRP. For each pricing period, these costs are based on either projected fuel costs of a peaking unit or forward market prices as determined by Idaho Power's power supply model, AURORAxmpCI Electric Market ModeL. The avoided capital cost is assigned only to the "On-Peak" pricing period and is based on a gas-fired simple-cycle turbine. In the IRP planning process (or program development) Idaho Power first .determines if a program is cost-effective using estimated expenses, time variant savings, and variant avoided costs values. In the process of determining the cost- effectiveness, a levelized cost from both a total resource cost ("TRC") and a utility cost ("UC") is calculated. These costs are then compared to the value of the benefits. As stated on page 63 of Appendix D of the 2006 IRP, "Ultimately, all programs must be cost-effective in order to be considered as ordered by the IPUC." A. An analysis of potential reduction in aMW and Summer Peak MW using a cutoff at the Residential Tariff third tier price point has not been performed. Performing the analysis as requested would produce unreasonable and misleading results. In addition to the reasons cited above for not comparing the levelized cost of demand-side resources to single cost, comparison to the Residential Tariff third tier price point presents other inconsistencies. The Residential Tariff rates are based on embedded IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 4 costs and, as such, contain fixed costs as well as variable energy-related costs. The embedded fixed costs include customer service costs, distribution infrastructure investment, transmission infrastructure investment, generation infrastructure investment as well as the net power supply costs. Any reduction in energy use as a result of demand-side programs wil only reduce a portion of the costs recovered through the Residential Tariff third tier rate. The response to this Request was prepared by Peter Pengily, Customer Research and Analysis Leader, and Tim Tatum, Cost of Service Manager, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 1 ih day of June 2009. ~gt1~íšORDS~ OM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 12th day of June 2009 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power and Northwest and Intermountain Power Producers Coalition Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Dr. Don Reading Ben Johnson Associates 6070 Hill Road Boise, Idaho 83703 Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 201 East Center Pocatello, Idaho 83204-1391 -X Hand Delivered U.S. Mail _ Overnight Mail FAX -X Email Scott.WoodburyCâpuc.idaho.gov Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email peterCârichardsonandoleary.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email dreadingCâmindspring.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email kmillerCâsnakeriveralliance.org Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email eloCâracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE - 6 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Village, Ohio 44140 Hand Delivered -X u.s. Mail _ Overnight Mail FAX -X Email tonyCâyankel.net Idaho Conservation League Betsy Bridge Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered -X u.s. Mail _ Overnight Mail FAX -X Email bbridgeCâwildidaho.org Northwest and Intermountain Power Producers Coalition Susan K. Ackerman 9883 NW Nottage Drive Portland, Oregon 97229 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email Susan.k.ackermanCâcomcast.net Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ¡th Street Boise, Idaho 83702 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email bmpurdyCâhotmail.com IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE-7