20111216Staff 1-28 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
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO CONVERT SCHEDULE 54 - FIXED COST )
ADJUSTMENT - FROM A PILOT SCHEDULE )
TO AN ONGOING PERMANENT SCHEDULE. )
)
)
)
CASE NO. IPC-E-11-19
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
FRIDAY, DECEMBER 30, 2011.
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.
F or 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 16, 2011
REQUEST NO.1: Please quantify the amount oflost sales related to the Company's
residential and small commercial DSM efforts for each year of the FCA pilot program. Provide all
workpapers used in the calculation, with formulas intact.
REQUEST NO.2: Please identify all other sources beyond DSM contributing to lost sales
for residential and small commercial for each year of the FCA pilot program. Provide all
workpapers used in the calculation, with formulas intact.
REQUEST NO.3: Would the Company support a modification of the FCA methodology
to isolate only lost sales attibuted to the Company's DSM efforts in the residential and small
commercial classes only? Please explain.
REQUEST NO.4: Please provide all available information to verify that the Company
has fulfilled its obligations specified in Commission Order No. 30267 to:
a) "promote the adoption of energy codes to achieve improved levels of efficiency in new
commercial and residential construction and appliance standards in Idaho"
b) "promote and support appropriate energy code training programs and advocate the
enforcement of energy codes"
c) "identify ways to support energy code implementation and enforcement in all
jurisdictions in Idaho Power's service territory"
Evidence may include, but need not be limited to, workpapers, e-mails, internal and
external meeting minutes, and presentation materials.
REQUEST NO.5: To the extent not covered in its response to the previous question,
please identify any changes since the inception of the FCA to:
a) energy codes in new commercial and residential construction and appliance standards
in Idaho
b) enforcement of energy codes in Idaho
c) energy code implementation and enforcement in all jurisdictions in Idaho Power's
service territory
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 DECEMBER 16, 2011
REQUEST NO.6: Please provide a table showing the following information for each
DSM program by year of the FCA pilot:
a) DSM program
b) Applicable paricipant rate schedules
c) Estimated expenditures
d) Estimated savings
REQUEST NO.7: What percentage of homes in Idaho Power's service territory use
electricity as the primar source for space heating? Please provide this data for the past five years.
REQUEST NO.8: In the past five years, what percentage of new home construction
within Idaho Power's service territory use electricity as the primar source for space heating?
REQUEST NO.9: Does Idaho Power believe that new home construction wil rely more
on electric space heating or natural gas space heating going forward? Please explain.
REQUEST NO. 10: If the Commission decided to terminate the FCA, how would the
Company change its approach to acquiring all available cost-effective DSM?
REQUEST NO. 11: Please explain how reimbursing the Company for lost sales (or
refunding ratepayers for excess sales) unelated to DSM activities is in the ratepayers' interests.
REQUEST NO. 12: Please explain how the Company identifies the number of meters
installed for new construction.
REQUEST NO. 13: Please provide FCA results for each year of the FCA pilot program
assuming each rate class (excluding lighting schedules) were subject to the FCA. In this analysis,
include the FCC and FCE for each year, the FCA adjustment rate per class and percentage of class
revenues, assuming no blended rate. Please provide all workpapers with the response, with
formulas intact.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 DECEMBER 16,2011
REQUEST NO. 14: Please provide the cost of service results used to calculate fixed costs
for this filing. Identify the line items that constitute fixed costs.
REQUEST NO. 15: In reference to Request No. 14, please indicate which items included
in the fixed cost calculation are incurred by the Company when it adds a new customer in an
existing residence or building. Please provide a brief explanation of the items and why those items
are necessar to serve these types of new customers.
REQUEST NO. 16: In reference to Request No. 14, please indicate which items included
in the fixed cost calculation are incurred by the Company when it adds customers in newly
constructed residences or buildings. Please provide a brief explanation of the items and why those
items are necessary to serve these types of new customers.
REQUEST NO. 17: Given the success the Company believes the FCA has achieved, does
the Company support expanding the FCA to all customer classes? Please explain why or why not.
REQUEST NO. 18: Please provide all financial analyses referenced on page 10 of Mr.
Youngblood's testimony regarding equity analysts' views on decoupling for Idaho Power.
REQUEST NO. 19: For each year of the pilot FCA program, please provide the. inputs for
calculating the FCC and FCE (total fixed costs, customer counts, energy sales). Identify the
program years in which the FCC and FCE rates changed due to Commission Orders, and in which
month the change went into effect. Please provide all workpapers in executable format with this
response.
REQUEST NO. 20: For each year of the pilot FCA program, please provide the inputs for
calculating the FCA deferral balance (such as monthly customer counts and energy sales). Identify
and explain any end of the year adjustments. Please provide all workpapers in executable format
with this response.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 DECEMBER 16, 2011
REQUEST NO. 21: For each year of the pilot FCA program, please provide the baseline
and +/- adjustment cap levels. Please provide all workpapers in executable format with this
response.
For Mr. Cavanagh
REQUEST NO. 22: Given his support of the mechanism, does Mr. Cavanagh believe
Idaho Power should expand the FCA to include all customer classes? Why or why not?
REQUEST NO. 23: To the extent not answered in the previous response, what benefits,
both to the customer and the Company, does Mr. Cavanagh see in limiting the FCA to Idaho
Power's residential and small commercial classes, should it be made peranent?
REQUEST NO. 24: Please list all other jurisdictions that Mr. Cavanagh has served as an
expert witness regarding decoupling mechanisms. Please note the date of the proceeding and the
party that Mr. Cavanagh represented.
REQUEST NO. 25: Of the jurisdictions listed in the response to Request No. 24, what
jurisdictions have instituted a pilot or permanent decoupling mechanism?
REQUEST NO. 26: Please provide all similarities and differences to Idaho Power's
curent FCA program and the decoupling mechanisms listed in response to Request No. 25.
REQUEST NO. 27: Ifnot answered in the previous response, is Mr. Cavanagh aware of
any jurisdiction listed in response to Request No. 25 that explicitly adjusted a utilty's rate of
retu due to instituting a decoupling mechanism?
REQUEST NO. 28: Of the jurisdictions listed in response to Request No. 24, what
jurisdictions decided against implementing a decoupling mechanism? To the extent possible,
please explain why a decoupling mechanism was not approved.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 DECEMBER 16,2011
DATED at Boise, Idaho, this ((Gl"ay of January 2011.
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Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Stacey Donohue/1 - 10
Bryan Lanspery/11 - 21
Nikki Karpavich!22 - 28
i:umisc:prodreq/ipcel 1.9wsblsdnk prod reql
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 6 DECEMBER 16, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF DECEMBER 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-11-19, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
JASON B. WILLIAMS
LISA D NORDSTROM
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: jwillamsriidahopower.com
lnordstromriidahopower .com
MICHAEL J YOUNGBLOOD
ZACHARY L HARRS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: myoungbloodriidahopower.com
zharsriidahopower .com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83701
E-MAIL: bottoriidahoconservation.org
RICHARD E MALMGREN
SR ASST GEN COUNSEL
MICRON TECHNOLOGY INC
800 S FEDERAL WA Y
BOISE ID 83716
E-MAIL: remalmgrenrimicron.com
THORV ALD A NELSON
FREDERICK J SCHMIDT
BRIAN T HANSEN
MARY V YORK
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIR
STE 500
GREENWOOD VILLAGE CO 80111
E-MAIL: tnelsonrihollandhar.com
fschmidtrihollandhart.com
bhansenrihollandhart.com
myorkrihollandhart.com
lnbuchanarihollandhar.com
NANCY HIRSH POLICY DIR
NW ENERGY COALITION
8111 1 ST AVE STE 305
SEATTLE WA 98104
E-MAIL: nancyrinwenergy.org
SECRETARY
,KGt
CERTIFICATE OF SERVICE