20121025Staff 30-42 to IPC.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
REC!_1V
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UTIL1TIS r.SSO:
Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5918
Attorney for the Commission Staff
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
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities 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, NOVEMBER 15, 2012.
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 will 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.
Please provide answers to each question and any supporting workpapers that provide detail
or are the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF 1 OCTOBER 25, 2012
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 30: Please explain in greater detail how the current FCA mechanism
"captures and fairly allocates the risk of fluctuations in economic activity" between customers and
the Company, specifically in regard to the customer count metric.
REQUEST NO. 31: Does IPC assume the 0.72% historical decline in use per customer is
attributable wholly or mainly to the Company's DSM efforts? Please explain.
REQUEST NO. 32: Does the proposed 2% UPC cap hold statistical significance? Please
explain.
REQUEST NO. 33: Please provide the data used to derive the charts on page 4 of the
compliance report in executable format.
REQUEST NO. 34: Please provide a similar analysis as that on page 4 of the compliance
report for the small commercial segment. Please provide the data in executable format.
REQUEST NO. 35: What is the rationale for applying the UPC cap to increases in use per
customer relative to the Company's energy efficiency efforts?
REQUEST NO. 36: Please explain why the Company proposes one aggregate UPC cap as
opposed to a cap specific to each customer segment.
REQUEST NO. 37: How does the 0.72% historical decline in residential use per customer
change when aggregated with the small commercial class? Please provide any workpapers in
executable format used in preparing this response.
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF 2 OCTOBER 25, 2012
REQUEST NO. 38: How often would IPC propose to update historical average change in
use per customer? What timeframe would be used in this calculation?
REQUEST NO. 39: Does IPC anticipate the UPC band to remain at +1- 2%, or will it
update the band over time? If so, what would cause the UPC band to be updated?
REQUEST NO. 40: Please provide documentation to support Mr. Cavanagh's
(Supplemental, p.4) claim that customer count was viewed by workshop participants as a "proxy
for annual changes in the economy."
REQUEST NO. 41: On page 4 of Mr. Cavanagh's supplemental testimony, he cites a study
in which "the per-customer index led all competing indices of economic activity by a margin of 27-
7." Did the study state that the per-customer metric was chosen as an index for economic activity?
Please explain.
REQUEST NO. 42: Regarding the study referenced in production request No. 14, please
list the electric utilities that are represented in 34 utilities cited. Which of these electric utilities
employ revenue per-customer decoupling mechanisms?
Respectfully submitted this Z'..' day of October 2012.
1k1iL
! Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umise:prod req/ipeel 1. I9wsbI prod req 2.doc
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF 3 OCTOBER 25, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF OCTOBER 2012,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-1 1-19, BY E-
MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
JASON B. WILLIAMS MICHAEL J YOUNGBLOOD
LISA D NORDSTROM ZACHARY L HARRIS
IDAHO POWER COMPANY IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: iwi11iamsidahopower. corn
[e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710N6TFST
BOISE ID 83701
E-MAIL: botto2iidahoconservation.org
THOR VALD 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: [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
r We] io:•iei
BOISE IDAHO 83707
E-MAIL: myoungb1oodcidahopower.corn
[e-mail]
RICHARD E MALMGREN
SR ASST GEN COUNSEL
MICRON TECHNOLOGY INC
8005 FEDERAL WAY
BOISE ID 83716
E-MAIL: rema1rngren(Zirnicron.com
NANCY HIRSH POLICY DIR
NW ENERGY COALITION
8111 1STAVE STE 305
SEATTLE WA 98104
E-MAIL: nancy(nwenergy.org
SECRETARY
CERTIFICATE OF SERVICE