20121227Staff 1-8 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RE CE I
2812 DEC 23 fj 4: 00
IDAHO FU;Z UTILITIES COMiSSO;
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY) CASE NO. IPC-E-12-27
TO MODIFY ITS NET METERING SERVICE )
AND TO INCREASE THE GENERATION ) FIRST PRODUCTION
CAPACITY LIMIT. ) REQUEST OF THE
) COMMISSION STAFF TO
) IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that Idaho Power Company (Company; IPC)
provide the following documents and information as soon as possible, by THURSDAY,
JANUARY 17, 2013.
This Production Request is to be considered as continuing, and the 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER 27, 2012
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: On pages 18-19 of Matt Larkin' s testimony, he says "utilizing the
results of the Company's most current class cost-of-service study that was reviewed in Case No.
IPC-E- 11-08, Schedule 6 and Schedule 8 reflect three primary modifications to the collection of
revenue requirement from Residential and Small General Service net metering customers."
Please provide the cost-of-service study used to develop the proposed modifications. As part of
your response, please explain how the results of this study were specifically used to design rates.
REQUEST NO. 2: On page 20 of Matt Larkin's testimony, he says the "proposed
schedules simply modify the charges through which the Company collects its currently
authorized revenue requirement without modifying the level of revenue collection." Please
provide the rate design workpapers used to confirm the currently authorized revenue requirement
will be collected if the proposed rates are approved.
REQUEST NO. 3: On page 17 of Matt Larkin's testimony, he says the "majority of the
Company's revenue requirement associated with Residential Service and Small General Service
is collected through volumetric energy rates." For both Residential Service and Small General
Service, please provide the percentage of revenue requirement collected through the volumetric
energy rates.
REQUEST NO. 4: On page 25 of Matt Larkin's testimony, when discussing Schedules
9, 19, and 24, he says the "majority of fixed cost recovery is excluded from the energy rates."
For these schedules, please provide the percentage of revenue requirement collected through the
volumetric energy rates.
REQUEST NO. 5: The Company proposes that the credits from Excess Energy expire
annually at the conclusion of a customer's December billing period. For the last two years,
please provide 12 separate scenarios showing the amount of excess energy customers would
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 DECEMBER 27, 2012
have forfeited if the annual credits expired at the conclusion of each month's billing period. For
all scenarios, please categorize the results by month, class and generation type.
REQUEST NO. 6: On page 22 of Matt Larkin's testimony, he says by "leaving the
collection of demand-related generation and transmission costs in the volumetric energy rate, the
Company's proposal recognizes that these systems potentially provide benefits at the generation
and transmission level by reducing loads on these components of the Company's system at
certain times." Please provide a schedule explaining in more detail all net metering transmission
related benefits and the associated cost savings.
REQUEST NO. 7: On page 23 of Matt Larkin's testimony, when discussing the
Company's consideration of offering a two-meter option for Schedule 6 and Schedule 8, he says
the "Company determined that this option is not feasible for net metering customers, as the need
for a second meter can be problematic in application and would increase the cost associated with
net metering service." Please explain how a second meter can be problematic in application, and
provide an estimate of the increased cost associated with adding a second meter.
REQUEST NO. 8: Please provide the following for each Idaho customer currently
taking Net Metering Service:
• Rate Class
• Effective Date
• City
• Generation Type
• Total Watts
DATED at Boise, Idaho, this 27 ''day of December 2012.
Karl T. Klein
Deputy Attorney General
Technical Staff: Matt Elam/1 -8
i:umisc:prodreq/ipce12.27kkme prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 DECEMBER 27, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF DECEMBER 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF, IN CASE NO. IPC-E-12-27, BY E-MAILING AND MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: Inordstrom2iidahopower.com
dockets(idahopower.com
BENJAMIN J. OTTO
IDAHO CONSERVATION LEAGUE
710 N. 6TH ST.
BOISE ID 83702
EMAIL: [e-mail]
MATT LARKIN
GREG SAID
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: [e-mail]
gsaid(idahopower.com
S TARY
CERTIFICATE OF SERVICE