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Home My WebLink About20110127IPC to ICIP 27-30.pdfLISA D. NORDSTROMLead Counsel "-,IV Inordstrom((idahopower.com \J1\L\i *SIDA~POR~ An IDACORP Company January 27, 2011 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-10-27 IN THE MATTER OF AN INVESTIGA TlON OF APPROPRIATE COST RECOVERY MECHAMSMS FOR IDAHO POWERS ENERGY EFRaENCY PROGRAMS Dear Ms. Jewell: Enclosed for filng please find an original and three (3) copies of Idaho Power Company's Response to the Third Production Request of the Industrial Customers of Idaho Power in the above matter. Also enclosed are four (4) copies of the non-confidential disk containing documents produced in response to the Industrial Customets Third Production Request. Very truly yours, òf~l)7z~ Lisa D. Nordstrom LDN:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise. ID 83707 LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(ëidahopower.com dwalker(ëidahopower.com RECJE~j~\l 2m \ JM~ 21 Ptî 4: 38 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 AN INVESTIGATION ) OF APPROPRIATE COST RECOVERY ) MECHANISMS FOR IDAHO POWER'S ) ENERGY EFFICIENCY PROGRAMS. ) ) ) ) ) ) CASE NO. IPC-E-10-27 IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the Third Production Request of the Industrial Customers of Idaho Power dated January 13, 2010, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1 REQUEST NO. 27: Reference the Company's Response to ICIP's Request Nos. 15 and 22 (stating the estimated 2011 Peak for the 3 Demand Response programs (AIC Cool Credit, Flex Peak, Irrigation Peak Rewards) is 376 MW (285+43+48=376)); and Power Point Presentation titled: "Demand Side Management Demand Response," presented at the IRPAC Meeting November 18, 2010, available as slide 22 at: http://ww.idahopower.com/pdfs/AboutUs/PlanningForFuture/irp/2011/201 011181RPAC MeetingPresenationSlides Web.pdf (discussing an "operational" limit through 2020 of 351 MW (330 MW for 2011) for the Company's Demand Response programs. Please explain why the 376 MW for 2011 provided in this case exceeds the estimated operational limit provided in the IRPAC meeting. Wil the Company rely upon the projections in this docket in future analysis regarding load and peak growth projections used in its IRP process? RESPONSE TO REQUEST NO. 27: Case No. IPC-E-10-27 was filed on October 22, 2010, reflecting the demand response megawatt ("MW") reductions contained on the 2011 budgets prior to the completion of the demand response analysis for the 2011 Integrated Resource Plan. The MW reduction from demand response and the associated investments in this docket are forecasts. Ultimately, actual expenses wil be included in determining the Power Cost Adjustment ("PCA") annually. In addition, the Company relies on the integrated resource planning process regarding load and peak growth projections. The response to this Request was prepared by M. Mark Stokes, Manager, Power Supply Planning, and Pete Pengily, Customer Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2 REQUEST NO. 28: Reference the Company's Response to the Commission Staff's Request NO.4. (a) Please provide a fully electronic executable spreadsheet containing all data and calculations that were used in the calculations presented in the column labeled "Energy-Based Allocation % (PCA Approach)." (b) Please provide a fully electronic executable spreadsheet containing all data and calculations that were used in the calculations presented in the column labeled "Energy-Based Allocation % (Rider Approach)." (c) Please indicate the demand response programs that are included in "allocation effects of moving all demand response incentive payment costs from the Rider to the Power Cost Adjustment (PCA)," as presented in the Company's spreadsheet in the referenced response. If this does not include all programs currently in operation, please state the program(s) not included and estimated allocation effect. (d) Please provide the estimated dollar impact (indicating increase or decrease) for each customer class for the 2011/2012 and 2012/2013 PCA years from shifting the DSR incentive payments from the current Rider approach to the PCA approach. Please provide a dollar impact also to each customer class of placing 0$ in DSR costs in the PCA, and instead increasing the EE rider percentage of 4.75% by 1.9% to 6.65%. (1.9% was provided as the necessary percentage in the Company's Response to ICIP Request No. 18(b).) RESPONSE TO REQUEST NO. 28: (a) The Company believes it provided a fully executable spreadsheet in its Response to Staffs Production Request NO.4. As shown in the column labeled "Energy-Based Allocation % (PCA Approach)" of the attachment to the Company's IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3 Response to Staff's Production Request NO.4, the listed allocation percentages were calculated by dividing total test year biled kilowatt-hours ("kWh") for each rate class by total test year biled kWh for the entire Idaho jurisdiction. Test year biled kWh used in this calculation reflect the June 1, 2010, through May 31, 2011, test year provided in compliance filings made June 1, 2010, with the Idaho Public Utilties Commission pursuant to Order Nos. 31091,31093, and 31097. (b) In the same attachment referenced above in part (a), the allocation percentages listed in the column labeled "Revenue-Based Allocation % (Rider Approach)" were calculated by dividing total test year base revenue for each rate class by total test year base revenue for the entire Idaho jurisdiction. Test year base revenues in this calculation reflect the June 1, 2010, through May 31, 2011, test year provided in compliance filngs made June 1, 2010, with the Idaho Public Utilties Commission pursuant to Order Nos. 31091,31093, and 31097. (c) As described on page 4 of the direct testimony of Darlene Nemnich, the Company is proposing to move direct incentive payment costs from all three current demand response programs (AIC Cool Credit, Irrigation Peak Rewards, and FlexPeak Management) into the PCA mechanism. Consequently, the allocation of direct incentive payment costs for all three programs would be affected under the Company's proposal. As a point of clarification, the inclusion or exclusion of programs has no effect on the allocation percentages provided in the attachment to the Company's Response to Staff's Production Request NO.4. These percentages are based on test year biled kWh and test year base revenue, and do not change based on which programs are included or excluded in the subsequent allocation. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4 (d) Please see the Excel spreadsheet provided on the enclosed CD. Please note that the allocation percentages contained within this attachment are for estimation purposes only and reflect the June 1, 2010, through May 31, 2011, test year provided in the previously described compliance filngs made June 1, 2010. Actual allocations wil be derived based on biled kWh and base revenue forecasts corresponding to the appropriate PCA test year. This response also assumes that no general rate case occurs prior to the filng of the 2012/2013 PCA year that would include some portion of demand response incentive payments in base power costs. The response to this Request was prepared by Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5 REQUEST NO. 29: Reference Direct Testimony of Darlene Nemnich, pages 8 and 9 (stating the Company proposes to collect DSR incentive payments through the PCA). How does the Company propose to include the DSR incentive payments in its cost-of-service study in a rate case? Would these DSR incentive costs be directly assigned to the customer class that received the incentive payments or assigned as a system resource? Would they be considered energy related or demand related? Please explain, and estimate the impact on a cost of service study and resulting rate allocation. RESPONSE TO REQUEST NO. 29: Idaho Power does not have a current proposal regarding how to include demand-side resource incentive payments in a cost- of-service study in a future rate case. The response to this Request was prepared by Timothy E. Tatum, Manager of Cost of Service, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6 REQUEST NO. 30: Reference the Company's Response to ICIP Request No. 22(e) (stating the (sic) with regard to EnerNOC program, the "targets for demand reduction fot' 2009 through 2013 are 2 MW, 30 MW, 40 MW, 50 MW, and 50 MW, respectively, and that these targets were used in the table provided in the response), and the FlexPeak Management 2009 Preliminary Report attached to the response, at pp.11-12. (a) Please admit or deny that for 2009 Idaho Power projected 2 MW of peak reduction, and EnerNOC achieved 11.1 MW of reduction, and therefore the actual reduction was over 500% of the predicted reduction. (b) Please admit or deny that actual costs were lower than expected for 2009. (c) In light of (a) and (b), please explain what adjustments the Company has made to the projections for 2011 used in the Response to ICIP Request No. 22(e). Were the projections changed after completion of the FlexPeak Preliminary Report on February 24, 2010? Is it reasonable to assume that the reductions wil be larger and the costs lower in years 2011 through 2013, as they were in 2009? If so, what is the likely impact in the S/MW figures provided. RESPONSE TO REQUEST NO. 30: (a) Idaho Power projected 2 MW of peak load reduction for 2009, which was the amount EnerNOC was contractually obligated to provide. EnerNOC achieved 11.1 MW of reduction in 2009. (b) Total program actual costs were not lower than projected for 2009. The administrative expenses were lower than projected in 2009, as stated in the FlexPeak report. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7 (c) The Company has not adjusted the projections for 2011 used in the Company's Response to the Industrial Customers of Idaho Powets Production Request No. 22(e). The Company has no reason to believe that the reductions wil be larger than predicted or that costs wil be lower than predicted for years 2011 through 2013 because the projections of existing resource potential have not changed. The response to this Request was prepared by Pete Pengily, Customer Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 2th day of January 2011. ¿(~ g tú I.~LISA D. NORD TROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 2th day of January 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Weldon B. Stutzan Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Weldon.Stutzman(ëpuc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email peter(ërichardsonandolearv.com greg(ërichardsonandolearv.com Dr. Don Reading Ben Johnson Associates 6070 Hill Road Boise, Idaho 83703 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email dreading(ëmindspring.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email botto(ëidahoconservation.org NW Energy Coalition Nancy Hirsh NW Energy Coalition 811 1st Avenue, Suite 305 Seattle, Washington 98104 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email nancy(ënwenergy.org IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9 Snake River Allance Ken Miler Snake River Allance 350 North 9th Street #B610 P.O. Box1731 Boise, Idaho 83701 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED 201 East Center P.O. Box 1391 Pocatello, Idaho 83204-1391 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Community Action Partnership Association of Idaho Brad M. Purdy 2019 North 1th Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email kmiller(ësnakeriveralliance.org Hand Delivered -lU.S. Mail _ Overnight Mail FAX -- Email elo(ëracinelaw.net Hand Delivered -lU.S. Mail _ Overnight Mail FAX 1 Email tony(ëyankel.net Hand Delivered -lU.S. Mail _ Overnight Mail FAX -l Email bmpurdVChotmail.com ~,l)'!b~ Lisa D. Nordst IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 10