20101217ICIP 16-26 to IPC.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Lear, PLLC
515 N. 27m Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandolear.com
gregt8richardsonandolear .com
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Attomeysfor the Industral Customers of Idaho Power
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S REQUEST TO MODIFY
RECOVERYOF INCENTIVES PAID TO
SECURE DEMAD-SIDE
RESOURCES
)
) CASE NO. IPC-E-10-27
)
) SECOND PRODUCTION REQUEST
) OF THE INDUSTRIAL CUSTOMERS
) OF IDAHO POWER
Pttsuatto Rule 225 of the Rules of Procedure of the Idao Public Utilities Commssion
(the "Commssion"), the Industral Customers of Idao Power ("ICIP") hereby requests that
Idaho Power Company ("Idaho Power") provide responses to the following with supportng
i
documents, where applicable, no later than January 6, 20i~. Please follow the instrctions set
fort in ICIP's First Production Request in ths docket.
Page 1 ~ SECOND PRODUCTION REQUEST OF THE INUSTRIL
CUSTOMERS OF IDAHO POWER - IPC-E-l 0-27
REQUEST FOR PRODUCTION NO. 16
Reference Idaho Power's Response to ICIP Request NO.6. Please identify and explain the
"other program expenses." Please estimate and list separately (by "other expense" each year) the
amount spent on the other expenses identified in each year.
2003 2004 2005 2006 2007 2008 2009
Other Expense A
Other Expense B
Other Expense C
Etc...
REQUEST FOR PRODUCTION NO. 17
Reference Idaho Power's Response to ICIP Request No. 7(a) and the attchment thereto.
(a) Why does the Company evaluate the cost-effectiveness of the AfC Cool Credits program
based on projected data for the 20-year life cycle of the program when it possesses actu data
from which it has provided cost-effectiveness of the program for the years 2008 and 2009, and
will soon have similar data for 201 O?
(b) Based on the table provided, the program has achieved well below a 1.0 TRC value for
each year for which the Company has actu figures, includg TRC values of 0.09 in 2004, 0.24
in 2005,0.34 in 2006,0.33 in 2007,0.56 in 2008,0.73 in 2009, but the Company projects it will
achieve 1.0 TRC value in futue years. Based on the Company's projection, in what year will the
program's cumulative TRC be 1.0? Please explai why this program should not need to prove
cost-effective sooner or be discontiued.
(c) Please provide the updated calculation for 201 o once the books have been closed and
financial records reportd.
(d) Please reconcile the statement in the response that "expenses for Idaho Power demand
response programs are front loaded," with the data in the char provided in response to ICIP
Request No.6, which shows the cost for ths program have escalated each year since 2008.
(e) Does Idaho Power posses data demonstrating that the AfC Cool credits program costs are
front loaded? If so, please provide such data and explain. If not, please explain the basis to use a
20-year levelized cost benefit analysis.
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CUSTOMERS OF IDAHO POWER - IPC-E-l 0-27
(f) Wht is the amortzation period for the AfC Cool Credits program? Given the cost-
effectiveness oftheAfC Cool Credit program is determed based on the 20-year life of the
program, please explai why a 20-year amortization period would not be appropriate.
REQUEST FOR PRODUCTION NO. 18
Reference Idao Power's Response to ICIP Request No. 9(d).
(a) Please explain how Idaho Power's response of "Zero percent," is an accurate "estimate of
the percentage of base rates Idaho Power will collect for total energy efficiency and DSR
activities in 2011 if the Commission were to grant Idaho Power's requested relief in ths case."
For example, Idaho Power curently collects 4.75% of base rates as the EE rider; please explai
how ths filing (if granted) would result in collection of 0% of base rates for use for EE and DSR.
If 0% is correct,. how will Idaho Power finance its EE and DSR programs?
(b) Please provide an estimate of the percentage of base rates Idao Power will collect for
total energy effciency and DSR activities in 2011 and 2012 (listed separately) if the Commission
were to grant Idaho Power's requested relief in this case.
(c) Please admit or deny that Idaho Power's application in ths docket requests an increase in
overall payment from customers for energy efficiency and/or DSR in 2011 and 2012 (listed
separately).
(d) If Idaho Power denies the admission in (c) for either year, please explain how the
application does not request an increase in payment by customers.
REQUEST FOR PRODUCTION NO. 19
Reference Idaho Power's Response to ICIP Request No.lO. Other than the requested relief in
this docket, please identify and explain what other Commission action would "restore the
symetr of the mechasm."
REQUEST FOR PRODUCTION NO. 20
Reference Idao Power's Response to ICIP Request No.12(c).
(a) Why does Idaho Power propose to accumulate incentive payments paid under the custom
effciency program as a regulatory asset rather than request for rate recovery at ths time?
(b) Assuming the requested relief in this case is granted, will Idao Power subsequently file a
request that the amortzation amount and retu amount accumulated in 2011, be allowed for
recovery in base rates effective Janua 1, 20l2?
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CUSTOMERS OF IDAHO POWER~ IPC-E-IO-27
(c) Does Idaho Power adit that its fiing in ths docket regards expenses the Company will
incur in 2011 but which the Company was not authorized to recover at the time of the stipulation
in Case No. IPC-E-09-30?
(d) Does Idaho Power understand ~5.2 of the stipulation in Case No. IPC-E-09-30to allow it
create new types of expenses for which it may recover though the PCA, or to otherwse alter the
PCA? If yes, please explain how the Company's position is consistent with the stipulation's
language in ~5.2, which only exempts from the rate moratorium PCA "filings with the
Commission to adjust its revenue requirement and change rates." If not, please explain how the
Company's request to alter the PCA in ths case is in accord with the stipulation.
(e) Please identify the date the Company first planed to file the requested relief in ths case.
Please provide supporting evidence.
(f) Did Idaho Power make the paries to the stipulation aware of its plans at the time of the
stipulation? Ifnot, please explain why.
REQUEST FOR PRODUCTION NO. 21
Reference Idao Power's Response to ICIP Request No. l5(a). Does the Company expect file to
reduce the EE rider percentage to less than 4.75% of base rates prior to June 20l2?
REQUEST FOR PRODUCTION NO. 22
Reference Idaho Power's Response to ICIP Request No. 15( c).
(a) Does Idaho Power admit that the identified error means that its filing actually requests
recovery the $14.9 milion (not $13.7 milion) in DSR program expenses though the PCA?
(b) Does Idaho Power admit that this is analogous to an increase in the EE rider by $14.9
milion in 2011 ?
(c) Please provide the $/MW figures including all "dollars per MW need to offer the demand
response program" for each of the three programs.
(d) If the data requested in (c) is unavailable, please explai why, and please explain how
Idaho Power can accurately test cost-effectiveness of the programs without cost data that
incorporates all dollars needed to offer the programs.
(e) Does Idaho Power expect that the increased fuding of the Flex peak program of
$2,421,603 will result in a greater MW reduction than provided in the response? If so, please
provide an updated $/MW figue. Please explai how the MW reduction is derived,.and provide
supporting work papers or documents.
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CUSTOMERS OF IDAHO POWER- IPC-E-IO-27
(f) Please explain how the MW reduction was derived for the AfC Cool Credits and the
Irrgation Peak Rewards progras, and provide supporting work papers or documents.
REQUEST FOR PRODUCTION NO. 23
Reference Direct Testimony of John R. Gale, page 6, line 10. Please provide a copy of the 1994
study titled "The Pursuit of Demand-Side Management."
REQUEST FOR PRODUCTION NO. 24
Reference Direct Testimony of John R. Gale, page 6, line 10 (discussing Case No. IPC-E-97-
12).
(a) Please admit or deny that the Commission set the amortization period at 12 years and the
Company proposed a 5 year amortization period.
(b) On page 4 in the order in Case No. IPC-E-97-12 (Order No. 27660) in IPUC Case lPC-E.
97-12 the Commission stated "We also find significant the changes that are sweeping though the
electrc industr and the unpredictabilty that has resulted" Does the Company see a similar
conditions in the electrc industr today? Please explain.
REQUEST FOR PRODUCTION NO. 25
Reference Direct Testimony of John R. Gale, page 7, lines 5-8 (stating ". . . . that DSR ought to
be treated in the same maner as a supply-side resource, including the maner in which
expenditues were recovered in rates.").
(a) Please explain why caring charges are a problem in financing DSR and not a problem
for supply side resources.
(b) Please explain why amortzation the period for DSR resources should not be tied to the
actual expected life of the equipment as with supply side resources.
(c) Please provide examples of supply-side resources with which the Commission has
authorized the Company to based the length of the amortization period on "balancing the need
for timely recovery of out-of-pocket. . . investments with the desire to establish a reguàtory
asset capable of earing a retu," as described in the Response to ICIP Request No.3.
REQUEST FOR PRODUCTION NO. 26
Reference Idao Power's Response to ICIP Request No.8.
(a) Please explai what the Company means when it says DSR and supply-side resources
would provide a "similar business rationale."
Page 5 - SECOND PRODUCTION REQUEST OF THE INUSTRIL
CUSTOMERS OF IDAHO POWER ~ IPC-E-l 0-27
(b) How could they share a similar business rationale when they are not on equal footing
with profit incentive?
(c) Wil the Company make supply side resource decisions based on profit incentive or
"business rationale"?
Than you for your prompt attention to ths Second Request for Production.
ereiy~
. Adams
SON & O'LEARY, PLLC
Page 6 ~ SECOND PRODUCTION REQUEST OF TH INDUSTRI
CUSTOMERS OF IDAHO POWER- IPC-E~10-27
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ths 16th day of November, 2010, I caused a tre
and correct copy of the foregoing SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER to be served by the method indicated
below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commssion
472 West Washington Street (83702)
Post Offce Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(x) Hand Delivered
( ) Overnght Mail
( ) Facsimile
( ) Electronic Mail
Lisa Nordstrom
Donovan Walker
Idaho Power Company
POBox 70
Boise, Idaho 83707
dwalker(ßidahopower.com
lnordstromt8idahopower .com
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
JohnR. Gale
Darlene Nemnich
Idaho Power Company
POBox 70
Boise, ID 83707
jgalet8idahopower .com
dnemncht8idahopower.com
(x) U.S. Mail, Postage Prepaid
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(X) Electronic Mail
Brad M. Purdy
Attorney at Law
2019 N. 17th Sl.
Boise, ID. 83702
(x) U.S. Mail, Postae Prepaid
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Nancy Hirsh
NW Energy Coalition
811 1st Ave, Suite 305
Seattle, W A 98104
nancyt8nwenergy.org
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()) Electronic Mail
Page 7 - SECOND PRODUCTION REQUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER~IPC-E-IO-27
Ken Miler
Snake River Allance
350 N 9th St # B6l0
Boise, ID 83702-5473
kmillert8snakeriveralliance.org
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(x) Electronic Mail
Benjamin 1. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
bottoß!idaoconservion.org
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Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho
elot8racinelaw.net
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Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
tony(fyaneLnet
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Signed OWL i' MtlS
Nina M. Curis
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