20101217Staff 1-6 to IPC.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
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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 AN INVESTIGATION OF )
APPROPRIATE COST RECOVERY )
MECHANISMS FOR IDAHO POWER'S )
ENERGY EFFICIENCY PROGRAMS )
)
)
)
)
CASE NO. IPC-E-I0-27
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,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
THURSDAY, DECEMBER 30, 2010.
This Production Request is to be considerecl 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 hearing.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 DECEMBER 17,2010
REQUEST NO.1: Referencing Tables 1 and 2 in Exhibit NO.1 of Darlene Nemnich's
testimony filed on October 22, 2Q 10, plaase p~~yiçle all data, assumptions and calculations used to
construct those tables. Please provide this inf(:)1'Jlation in a fully executable spreadsheet.
REQUEST NO.2: Table 2, referenced above, shows forecasted Idaho Rider Revenue of
$38,088,745 for both 2011 and 2012. On page 54 of , Idaho Power's 2009 Integrated Resource
Plan (IRP), Table 5.2 shows a 2% increase in median forecasted average monthly energy load
from 2011 to 2012.
a) Please explain why Ms. Nernnich's Tables 1 and 2 do not anticipate increases to either
Idaho total revenue or Energy Efficiency Rider revenue consistent with the IRP's
forecasted load increase from 2011 to 2012.
b) Do Tables 1 and 2 also not anticipate energy load growth from 2010 to 2011? If not,
please explain.
REQUEST NO.3: Please recoIlstructMs. Nemnich's Tables 1 and 2 with the inclusion
ofload growth increases from 2010 to 2011 anddiröm2011 to 2012 that are consistent with such
forecasted growth on page 54 of Idaho Powers 2009 IRP and with correction of the error noted by
Idaho Power in its response to Request No. 15(c) of the Industrial Customers ofIdaho Power.
REQUEST NO.4: Please provide a fully executable spreadsheet containing all data,
assumptions and calculations estimating the cost-of-service allocation effects of moving all
demand response incentive payment costs from the Rider to the Power Cost Adjustment (PCA).
REQUEST NO.5: Assuming Commission approval of the Company's request to
capitalize the incentive payment costs of its Custom Efficiency program beginning Januar 1,
2011, please provide a fully executable spreadsheet containing all data, assumptions and
calculations estimating Idaho Power's anual earings from 2011 through 2015 attributable to the
requested change.
REQUEST NO.6: The Application infers that the Custom Efficiency program was
selected by the Company for cost capitalization partly because it is one of the most cost-effective
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 DECEMBER 17,2010
programs. (p.9) The Company's April 16, 2010, Revised Edition of Supplement 1: Cost-
Effectiveness to the Demand-Side Management 2009 Anual Report (p. 43) shows that cost-
effectiveness was calculated with an assumption of 100% net-to-gross; i.e. that no paricipating
customers would have pursued any of the energy efficiency measures absent incentives paid by
Idaho Power.
a) What is the basisofIdaho Power's 100% net-to-gross assumption?
b) A footnote on p. 43 of the Supplement states that TRC cost-effectiveness is maintained
down to 30% net-to-gross (NTG). What is the utilty cost test benefit-cost ratio at 30%
NTG?
DATED at Boise, Idaho, this lj"dayofDecember 2010.
~...Weldón B. Stutzman
.Deputy Attorney General
Technical Staff: Lynn Anderson
i:umisc:prodreq/ipcelO.27wsla prod reql
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 DECEMBER 17,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF DECEMBER 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-I0-27,
BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
DONOV AN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom(fidahopower.com
dwalker(fidahopower.com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(frichardsonandoleary.com
greg(frichardsonandoleary.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(fracinelaw.net
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
POBOX 844
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
KEN MILLER
SNAKE RIVER ALLIANCE
350 N 9TH ST STE B610
BOISE ID83702
E-MAIL: kmiler(fsnakeriveralliance.org
JOHNRGALE
DARLENE NEMNICH
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale(fidahopower.com
dnemnich(fidahopower.com
DR DON READING
6070 HILL RD
BOISE ID 83703
E-MAIL: dreading(fmindspring.com
ANTHONY Y ANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E..MAIL: tony(fyanel.net
NANCY HIRSCH
NW ENERGY COALITION
E",MAIL ONLY:
nancy(fnwenergy.org
Jo ýÝny(
SECRETAR .
CERTIFICATE OF SERVICE