HomeMy WebLinkAbout20100226IPC to Staff 1-3.pdfBARTON L. KLINE
Lead Counsel
esIDA~POR~
An IDACORP Company
February 26, 2010
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-09-28
FCA - FROM A PILOT SCHEDULE TO AN ONGOING, PERMANENT
SCHEDULE
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 Commission Staff in the above matter.
Very truly yours,
OMI~
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise. ID 83702
BARTON L. KLINE (ISB No. 1526)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: 208-388-5317
Facsimile: 208-388-6936
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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 )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-09-28
AUTHORITY TO CONVERT SCHEDULE )
54 - FIXED COST ADJUSTMENT - FROM ) IDAHO POWER COMPANY'S
A PILOT SCHEDULE TO AN ONGOING, ) RESPONSE TO THE FIRST
PERMANENT SCHEDULE. ) PRODUCTION REQUEST OF THE
) COMMISSION STAFF TO IDAHO
) POWER COMPANY
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to the First Production of Request of the Commission Staff to Idaho Power
Company dated February 5, 2010, 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: Please provide monthly actual (non-annualized) kWh savings
attributed to the Company's DSM efforts for the residential and small commercial
classes from 2005 to the end of 2009.
RESPONSE TO REQUEST NO.1: There are several issues that make it
difficult, if not impossible, for Idaho Power to provide monthly actual (non-annualized)
kWh savings as requested by Staff. Currently, Idaho Power tracks incentive payments
to customers for energy efficiency projects/purchases by month and by year along with
the energy savings associated with these payments. The Company reconciles this
information annually for reporting purposes, resulting in changes being made to the
monthly savings. Also, the date of the payments of incentive is not necessarily
coincident with when the savings may actually occur. As Staff clarified in direct
testimony, Case No. IPC-E-08-10, L. Anderson pages 4 and 5:
For clarification, it is worth noting that the 91,145 MWh were the
annual savings reported as occurring due to program efforts in
2007, presumably less than 50% of which would actually be saved
in 2007. The reported energy savings occurring in 2007 due to the
Company's DSM efforts from 2003 through 2007 are probably close
to, but less than, the sum of each prior yeats annual savings plus
about one-half of 2007's annual savings. Those annual savings
numbers are shown on page 70 of the same 2007 DSM Report.
The sum of 2003-2006's savings plus half of 2008's total to about
190,000 MWh saved in 2007, reportedly as a result of Idaho
Power's DSM efforts from 2003 through 2007.
The same logic that Staff used in their testimony applies to energy savings
reported monthly. An example would be if a customer installs new energy efficient
lighting that qualifies for an incentive. It may take the customer weeks or more to finish
the project, receive an invoice, complete paperwork, and apply for an incentive,
resulting in the savings starting before the incentive payment is made. Although it is
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
common practice in the industry to account for energy savings when it is expensed, the
granularity of the actual savings data is not extremely precise. As stated earlier, Idaho
Power reconciles its energy savings on an annual basis and is currently completing this
process for 2009.
Another issue involved with providing data for Idaho Powets small commercial
customers is that the Company's energy efficiency programs that are available to small
commercial customers are also available to large commercial customers. Easy
Upgrades and Building Effciency are available to customers taking service under Idaho
rate Schedules 7, 9, and 19 and Custom Efficiency is available to customers taking
service under Idaho rate Schedules 9 and 19. The Company tracks energy savings and
expenses by program not by rate schedule. Idaho Power is currently designing and
building a new system that wil be implemented in 2010 which wil include tracking
participant data by rate schedule.
Historic annual savings by program and sector can be found in Appendix 4 of the
Demand-Side Management 2008 Annual Report, which was filed with the Commission
on March 13, 2009, in Case Nos. IPC-E-02-03 and IPC-E-03-19. The table below
shows the annual savings by sector for 2005 through 2008 and the preliminary annual
savings for 2009. !he final energy savings for 2009 wil be included in the Demand-
Side Management 2009 Annual Report, which wil be filed with the Commission on or
before March 15,2010.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
Year 2005 2006 2007 2008 2009
Idaho Power Energy Savings Annual Annual Annual Annual Annual kWh
kWh kWh kWh kWh (Preliminary)
Residential Sector Total 7,519,84 11,283,798 12,440,682 21,777,729 25,979,920
Building Effciency 494,239 704,541 2,817,248 6,598,123 6,146,139
Easy Upgrades 5,183,640 26,187,483 32,980,278
Oregon School Effciency 223,368
Buildine Operator Training 434,167
Commercial Sector Total 928,406 927,909 8,000,888 32,785,606 39,126,417
Custom Effciency 12,016,678 19,211,605 29,789,304 41,058,639 51,835,612
Industrial Sector Total 12,016,678 19,211,605 29,789,304 41,058,639 51,835,612
Irreation Effciency Rewards 1,012,883 16,986,008 12,304,073 11,746,395 13,157,619
Irrigation Sector Total 1,012,883 16,986,008 12,304,073 11,746,395 13,157,619
Northwest Energy Effciency Allance (NEEA)16,297,235 22,337,477 28,601,410 32,671,465 32,671,465
Local Energy Effciency Funds (LEEF)78,000 19,027 9,000 115,931 10,340
NEEA and LEEF Total 16,375,235 22,356,504 28,610,410 32,787,396 32,681,805
Annual Total 37,853,046 70,765,825 91,145,357 140,155,765 162,781,373
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, 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 COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO.2: Please provide the monthly customer counts and normalized
energy sales for both the residential and small commercial classes for 2009.
RESPONSE TO REQUEST NO.2: Please see the attached document.
The response to this Request was prepared by Scott Sparks, Senior Pricing
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 COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO.3: Please explain how the FCA components would have
changed relative to the current (base 2008) components had the Company filed and
Commission approved a general rate increase in 2009. What would be the impact for
2010 through 2012? If any workpapers were used in determining this response, please
provide.
RESPONSE TO REQUEST NO.3: The Company has not prepared the analysis
necessary to calculate the requested information. The requested analysis is typically
provided as a part of the Company's general rate case filings and because the
Company has not filed a general rate case since Case No. IPC-08-10, the requested
data for the years 2009 through 2012 is not available.
The response to this Request was prepared by Scott Sparks, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
DATED at Boise, Idaho, this 26th day of February 2010.
~
BARTON E. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of February 2010 I served a true and
correct copy of the foregoing 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
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-1 Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-1 Email Weldon.stutzmancæpuc.idaho.gov
Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
Hand Delivered
-1 U.S. Mail
_ Overnight Mail
FAX
-1 Email kmilercæsnakeriverallance.org
Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 17th Street
Boise, Idaho 83702
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email bmpurdycæhotmail.com
Idaho Conservation League
Betsy Bridge
Idaho Conservation League
P.O. Box 844
710 North Sixth Street
Boise, Idaho 83701
Hand Delivered
-1 U.S. Mail
_ Overnight Mail
FAX
-1 Email bbridgecæidahoconservation.org
Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-09-28
IDAHO POWER COMPANY
RESPONSE TO STAFF'S PRODUCTION
REQUEST NO.2
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