20110623IPC to Staff 16-17.pdf

DONOVAN E. WALKER
Lead Counsel
dwalkertmidahopower.com
ø¡IDA.iPOR~
An 10ACORP Company
June 22, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-11-05
IN THE MA TTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
FOR A PRUDENCY DETERMINA TlON OF 2010 ENERGY EFFICIENCY
RIDER EXPENDITURES
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the Second Production Request of the Commission Staff to Idaho
Power Company in the above matter. Also enclosed are four (4) copies of a non-
confidential disk containing information being produced in response to Staff's Second
Production Request.
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, 10 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom(áidahopower.com
dwalker(áidahopower.com
RECEIVED
2011 JUN 22 PH ~:ld
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
PRUDENCY DETERMINATION OF 2010
ENERGY EFFICIENCY RIDER
EXPENDITURES.
)
) CASE NO. IPC-E-11-05
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE SECOND
) PRODUCTION REQUEST OF THE
) COMMISSION STAFF TO IDAHO
) POWER COMPANY
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Second Production Request of the Commission Staff to Idaho Power
Company dated June 1, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 16: For each month during 2010, please provide the DSM rider
collection amount, total DSM expenditures, and the interest charged to the rider
balance. Please show the interest calculation.
RESPONSE TO REQUEST NO. 16: Please see the Excel file provided on the
enclosed CD. The first tab of the Excel file, Response No. 16, contains the Detailed
Trial Balance - Beginning Balance, Total Revenue Collected, Total Interest Charges,
Total Program Expenses, and Detailed Trial Balance - Ending Balance by month for
January 2010 through December 2010. The second tab of the Excel file, Interest
Charge Schedule, shows the interest calculations by month for 2010.
In accordance with Idaho Public Utilties Commission ("Commission") Order No.
29065 establishing the interest rate for the demand-side management Energy Efficiency
Rider, "The Commission finds the customer deposit rate (Le., the interest rate paid on
customer deposits effective at the beginning of each year) to be the appropriate interest
rate under these circumstances." Per Commission Order No. 30965, "It is further
ordered that the rate on deferred accounts using the customer deposit rate during
calendar year 2010 shall be 1.0%."
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.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 17: Please explain why the budget for the Flex Peak
Management program increased without a corresponding increase in energy savings
between 2009 to 2010.
RESPONSE TO REQUEST NO. 17:In personal communication with
Commission Staff ("Staff) on Thursday, June 2, the Staff indicated the above question
was in reference to the data contained on page 84 of Idaho Power's Demand-Side
Management 2010 Annual Report. The data on page 84 shows a 19.3 megawatt
("MW") load reduction with a total program cost of $528,681 for 2009 and a 47.5 MW
load reduction at a total cost of $1,807,527 for 2010. Staff questioned the different
ratios of cost per MW for the two years.
The cost per MW is higher in 2010 for two reasons. First, the MW reduction
reported in the Demand-Side Management 2010 Annual Report is the maximum hourly
reduction achieved in the season. Program funding costs are based on the monthly
average MW reduction. Because 2009 was a ramp-up year, the monthly average was
considerably different in the first month than in the last month. Therefore, early in the
season, Idaho Power paid for less load reduction than the reported maximum reduction.
In 2010, the average monthly commitment did not vary as greatly from the start of the
season to the end; therefore, Idaho Power paid closer to the reported maximum
reduction throughout the season.
Second, the difference in cost per MW occurs because Idaho Powets payments
for achieved load reductions are capped at 10 percent above the MW reduction
EnerNOC commits to provide each week. Each week EnerNOC commits to providing a
certain level of load reduction for the following week if an event is called. In 2009,
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
EnerNOC provided reductions greater than 110 percent of the weekly commitment
every time an event was called. Therefore, while Idaho Power received the benefit of
the full reductions, the Company was biled for only the committed amount plus 10
percent above that commitment for those weeks. In 2010, EnerNOC's commitments
were closer to the reductions actually achieved. Consequently, the payments were
more in line with the demand that was actually reduced.
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 22nd day of June 2011.
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LISA D. NORDSTROM
Attorney for Idaho Power Compan
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of June 2011 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
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 Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Weldon.Stutzman(ápuc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 2th Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email peter(qrichardsonandoleary.com
greg(qrichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email dreading(qmindspring.com
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5