20100414Staff 1-6 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF 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-I0-06
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, APRIL 28,2010.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil augment the documents produced.
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 who can sponsor the answer at hearng.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 APRIL 14,2010
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 hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas intact.
REQUEST NO.1: Please provide all workpapers supporting the testimony,
attachments, and exhibits in this case including all Excel files with formulas intact.
REQUEST NO.2: Please provide a copy of the most recent AMI implementation plan
showing installation areas and equipment.
a. The Commission is aware of the delayed OMS integration in the Capital
region. Please provide a status update on this matter and other deviations from
the original implementation plan, if any.
b. Please provide detailed information on any changes, problems, or issues the
Company encountered so far during the implementation of AMI, if any.
REQUEST NO.3: Company witness Courtney Waites states that, "The Company
continues to ru slightly ahead of scheduled installations and equipment orders." Waites'
testimony, p. 7.
a. Please quantify the amount (number and dollars) of station equipment the
Company has received and is going to receive during the test year.
b. Please provide a comparison of this quantity to the required number of station
equipment for the full deployment of AMI. What percentage of the entire project
does this equipment represent?
REQUEST NO.4: Please provide the actual numbers to date for the AMI meters
installed and to be installed during the test year, actual dollar amount of capital investment and
the actual O&M costs. Please provide supporting documents.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 APRIL 14,2010
REQUEST NO.5: The Company is proposing to spread the revenue requirement for
AMI across the service charge and demand charge in addition to the energy charge for Schedule
9 secondary and 24 secondary service.
a. Please provide a justification for the Company's proposaL.
b. Please provide workpapers supporting the calculation of the proposal.
REQUEST NO.6: Please provide information as to when the Company exchanged the
master meter for Schedule 3 and meters for Schedule 41 - Mercury Vapor customers to AMI
meters and how many are installed and how many are left to be exchanged for these customer
classes.
DATED at Boise, Idaho, this 11day of April 2010.
,---
Scott oodbury
Deputy Attorney General
Technical Staff: TJ. Golo
e-mail: dwalkerßYidahopower.com
lnordstromêidahopower .com
gsaidêidahopower.com
cwaitesßYidahopower .com
cbearryêidahopower.com
i:umisc:prodreq/ipce i O.06swtj ipc prod req I
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 APRIL 14,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF APRIL 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-1O-06, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E WALKER
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalkerifidahopower.com
Inordstromifidahopower .com
COURTNEY WAITES
GREG SAID
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: cwaites(iidahopower.com
gsaid(iidahopower .com
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SECRETARY
CERTIFICATE OF SERVICE