20090423Staff 1-10 to IPC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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Z009 APR 23 PM 2: 38
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES DUE TO THE )
INCLUSION OF ADVANCED METERING )
INFRASTRUCTURE ("AMI") INVESTMENT IN )
RATE BASE. )
)
)
)
CASE NO. IPC-E-09-7
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Idaho Power Company (Company; Idaho
Power) provide the following documents and information as soon as possible, but no later than
FRIDAY, MAY 8, 2009.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearng if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST TO
IDAHO POWER 1 APRIL 23, 2009
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job tite, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.1: As technology evolves over time, the potential benefits of the AMI
system may also change. As of today, has the Company seen an incremental change in benefits
of the AMI system that have been captured in the revenue requirement analyses? Please explain
and list them.
a. Please list all of the immediate benefits AMI can provide after deployment.
'REQUEST NO.2: Please list and explain any changes, issues or problems the Company
encountered so far during the implementation of AMI.
a. Did the Company need to deviate from the original implementation plan because
of those problems or issues? Please explain.
REQUEST NO.3: Company witness Courney Waites states that "due to the downtur
in the economy, stations equipment orders are being filled more quickly."
a. Please quantify the amount (number and dollars) of stations equipment the
Company has received to date.
b. Please provide a comparison of this quantity to the required number of stations
equipment for the full deployment of AMI. What percentage of the entire project
does this equipment represent?
c. Please list AND provide details of the remaining equipment needed for full
deployment of AMI.
REQUEST NO.4: Please provide all workpapers supporting the testimony and exhibits
in this case.
FIRST PRODUCTION REQUEST TO
IDAHO POWER 2 APRIL 23, 2009
REQUEST NO.5: Please provide the actual numbers to date for the AMI meters
installed, actual dollar amount of capital investment and the actual O&M costs. Please provide
supporting documents.
REQUEST NO.6: Please provide detailed schedules showing the monthly O&M costs
and all benefits.
REQUEST NO.7: Please provide schedules showing when the Information
Technology, Meter Data Management System and Two-Way Automated Communication
System Net Server equipment was or wil be installed. Please show the capital costs, O&M costs
and benefits associated with each.
REQUEST NO.8: Please provide schedules and supporting workpapers to calculate
Exhibit NO.3 at December 31, 2009.
REQUEST NO.9: Please provide an update on the availabilty of stimulus fuds for
AMI investments. Please document Idaho Power's request for stimulus fuds and the process
being followed by providing copies of requests, letters, internal and external memorandums,
emails, etc.
REQUEST NO. 10: Please provide a copy of the most recent implementation plan
showing installation areas and equipment.
DATED at Boise, Idaho, ths ~y of April 2009.
A~
Neil Price
Deputy Attorney General
Technical Staff: TJ Golo
Terri Carlock
i:umisc:prodreq/ipce09.7nptjtc prod reql
FIRST PRODUCTION REQUEST TO
IDAHO POWER 3 APRIL 23, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF APRIL 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-09-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
DONOV AN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bklineCiidahopower.com
dwalkerCiidahopower .com
.COURTNEY WAITES
GREG SAID
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: cwaitesCiidahopower.com
gsaidCiidahopower.com
~~SECRETAR --
CERTIFICATE OF SERVICE