20130220IPC to ICL 1-33.pdf

IDAHO
- An IDACORP Company
2UIFEB20 PM 4: h7
LISA D. NORDSTROM
Lead Counsel
Inordstromcidahopower.com :- UMISS iO
February 20, 2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-12-27
Net Metering Service - Idaho Power Company's Response to the First
Production Request of the Idaho Conservation League
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's Response to the First Production Request of the Idaho Conservation
League ("ICL") to Idaho Power Company.
In addition, enclosed are four (4) copies of the non-confidential disk and four (4)
copies of a confidential disk containing data responsive to ICL's Request. Please handle
the confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
Lisa D. Nordstrom
LDN:evp
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
JULIA A. HILTON (ISB No. 7740)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
InordstromidahoDower.com
jhiItonidahopower.com
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Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-12-27
AUTHORITY TO MODIFY ITS NET )
METERING SERVICE AND TO ) IDAHO POWER COMPANY'S
INCREASE THE GENERATION ) RESPONSE TO THE FIRST
CAPACITY LIMIT. ) PRODUCTION REQUEST OF THE
) IDAHO CONSERVATION LEAGUE
) TO IDAHO POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Idaho Conservation League ("ICL") to
Idaho Power Company dated January 30, 2013, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -1
REQUEST NO. 1: Please provide the most recently used alternate costs for
analyzing demand side resources. Please provide these costs for each hour of the year
and for the future 20 years. Please provide these costs in excel spreadsheet or other
digital format.
RESPONSE TO REQUEST NO. 1: The most recent costs for analyzing
demand-side resources were produced in the 2011 Integrated Resource Planning
("IRP") process. In addition, Attachment I (attached hereto) contains hourly avoided
costs from January 1, 2011, to December 31, 2029. Attachment 2 (attached hereto)
contains copies of the 2011 IRP Appendix C, pages 66 to 71. This section of Appendix
C explains the derivation of the Demand-Side Management ("DSM") alternative costs.
These costs are averaged in time-of-use type pricing categories for analysis of DSM
resources. Please note, the Summer On-Peak prices are calculated using Idaho
Power's 30-year levelized capacity, variable energy, and operating costs of a 170
megawatt ("MW") Simple Cycle Combustion Turbine.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -2
REQUEST NO. 2: For the alternate cost data requested above, please identify
and quantify the following components. If Idaho Power has not identified or quantified
any of the following, please explain why.
a.Energy
b.Capacity
C. Transmission
d.Distribution
e.Operationsand maintenance
f.Avoided line losses identified and quantified separately for the
transmission and distribution systems.
g.Any other components Idaho Power includes in alternate costs not
specifically referred to in a-f.
RESPONSE TO REQUEST NO. 2:
a.As explained on page 67 of the 2011 IRP Appendix C, the prices of
avoided energy throughout the 20-year planning period are simulated using
AURORAxmp by applying Idaho Power's Preferred Portfolio. Idaho Power uses
AURORAxmp to model variable operating costs. For the Idaho Power system,
AURORAxmp reports the total portfolio cost and hourly marginal costs.
b.In Idaho Power's IRP process, the Company conducts its thirty-year
levelized cost analysis outside of the AURORAxmp model. As reported in Idaho
Power's Response to ICL's Production Request No. 1, Summer On-Peak prices are
calculated using Idaho Power's thirty-year levelized capacity, variable energy, and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -3
operating costs of a 170 MW Simple Cycle Combustion Turbine. All of the inputs for
this calculation are included in Appendix C of the 2011 IRP.
c-e. The cost granularity requested is not reported in the output tables from
AURORAxmp. There is no cost reporting of transmission although the model does
account for wheeling charges as necessary. Distribution costs are not modeled. There
is no capacity component in these prices. The fuel costs and variable operating costs of
each unit in each plant are input into the model. Scheduled maintenance for the
Company's generation plants is accounted for and operating capacity factors at plant
and unit level are reported on a monthly and annual basis. The hourly marginal energy
values output from AURORAxmp model for the 2011 IRP planning period are included
in the Company's response to ICL's Production Request No. 1.
f.As reported on page 69 of the of the 2011 IRP Appendix C, the line losses
used in analyzing DSM resources are 10.9 percent for non-summer on-peak periods
and 13 percent for summer on-peak periods.
g.None.
The response to this Request was prepared by Pete Pengilly, Customer
Research and Analysis Leader, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -4
REQUEST NO. 3: Page 23 of Mr. Larkin's testimony discusses the complexity in
using time-differentiated rates for net metering service. Please provide the following:
a.When does Idaho Power plan to complete "implementing a new customer
information and billing system"?
b.Will this new system have the capability to apply time-differentiated rates
for net metering service?
C. When does Idaho Power plan to determine whether applying time-
differentiated rates is feasible for net metering usage and generation?
d. Describe in further detail the complexity of the calculations to implement
time-differentiated rates for net metering customers.
RESPONSE TO REQUEST NO. 3:
a. Idaho Power's new customer information and billing system is scheduled
to go into production on July 1, 2013.
I b. The new system will have the capability to apply time-differentiated rates
to net metering service only if the customer's consumption in the time-differentiated time
blocks is greater than the customer's generation during those same time blocks. If the
customer generates more energy during the billing period than is consumed during any
of the time-differentiated time blocks, a system error will occur, preventing the billing
from taking place. If a system error occurs the bill must be manually calculated.
C. Once the new system is implemented in July, Idaho Power will begin
learning more about the system as it is used in day-to-day operations. As more
experience with the system is gained, Idaho Power will have a better understanding of
its functionality and flexibility. As stated in the Company's response ICL's Production
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -5
Request No. 3.b above, the ability to bill negative net consumption over a given time
period is not available through the Company's billing software on an automated basis.
Although the Company will continue to explore options to allow for automated billing of
negative net consumption, it cannot say with certainty when this functionality will be
available.
d. Idaho Power's new billing system is not designed to process negative
meter readings, such as would occur if the customer's generation during the billing
period exceeds the customer's consumption. When a negative reading is encountered,
a billing error will occur, requiring manual intervention and calculation of the bill. Under
a negative reading scenario, the primary complexity of applying time-differentiated rates
to net metering service is the manual processing of bills and the inherent potential for
human error. As time blocks are added, it increases the potential for the occurrence of
negative reads and the complexity of the subsequent manual billing process. The
potential for the monthly billing process to become time-intensive and error-prone on a
customer-by-customer basis would increase as the number of customers taking time-
variant net metering service increased.
The response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, at the direction of Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -6
REQUEST NO. 4: Does Idaho Power admit or deny that the Fixed Cost
Adjustment mechanism addresses the recovery of fixed costs that are affected by any
change in customer energy consumption.
RESPONSE TO REQUEST NO. 4: Idaho Power cannot confirm the statement
as written. However, the Company agrees that the Fixed Cost Adjustment mechanism
addresses the recovery of fixed costs that are affected by changes in average kilowatt-
hour ("kWh") use per customer for the Residential and Small General rate classes.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -7
REQUEST NO. 5: Please explain how Idaho Power arrived at a capacity limit of
5.8 MW. Please include any documents, analysis, or data used in setting this limit.
RESPONSE TO REQUEST NO. 5: As stated on page 13 of the Direct
Testimony of Matthew T. Larkin, lines 15 through 19, "By increasing the current capacity
limit to 5.8 [megawatts], the Company is facilitating the expansion of its net metering
service while maintaining the opportunity to appropriately evaluate and request to
modify this service as necessary." The decision to double the cap was based on
discussions with various departments throughout the Company, including Customer
Relations & Energy Efficiency, Regulatory Affairs, and Finance. Through these
discussions it was ultimately determined that a doubling of the cap would provide the
opportunity for growth while maintaining the ability to evaluate this service as it
continues to grow.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -8
REQUEST NO. 6: Mr. Larkin, on page 18, states the current net metering
program creates a "potential inequity between net metering customers and standard
service customers, as net metering customers rate provided the opportunity to unduly
reduce collection of revenue requirement by receiving credit for generation at the full
retail rate while standard service customers are left to compensate for the revenue
shortfall."
a.Please quantify any current inequity between current program participants
and current customers in terms of any shift in revenue collections between participants
and non-participants.
b.Based on the Company's forecast of net metering program growth, please
quantify the "potential inequity" annually for the next three years.
RESPONSE TO REQUEST NO. 6:
a. The actual level of inequity experienced between participants and non-
participants is dependent upon a number of variable factors, including each customer's
individual usage, the size of the generation unit, and weather conditions affecting both
consumption and generation. As stated in Mr. Larkin's testimony, page 21, line 18,
- through page 22, line 8, the potential for inequity can be calculated by examining the
amount of distribution-related revenue requirement embedded in energy rates. As
stated on lines I through 3 of page 22 of Mr. Larkin's testimony, 10.025413 of the
average Schedule I energy rate is comprised of distribution-related charges, while
$0.048247 of the average Schedule 7 energy rate is comprised of distribution-related
charges." Based on average monthly usage for a Residential Service customer of 1,050
kWh, the potential for inequity resulting from a net metering customer who achieves net
zero usage is approximately $320 per customer per year ($0.025413 x 1,050 kWh x 12
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -9
months). Likewise, based on average monthly usage for a Small General Service
customer of 437 kWh, the potential for inequity resulting from a net metering customer
who achieves net zero usage is approximately $253 per year ($.048247 x 437 kWh x 12
months). These values reflect the average annual cost associated with the Company's
distribution system and customer services that are not paid for by a net metering
customer who achieves net zero consumption within each class. As described above,
the inequity that actually occurs will vary based on each customer's unique
circumstances.
b. The Company does not possess a forecast of net metering service growth
to complete the requested analysis.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -10
REQUEST NO. 7: The energy rates for Residential and Small General Service
customers currently include multiple blocks. Please explain which energy block a net
metering customer's excess energy is credited at.
RESPONSE TO REQUEST NO. 7: Excess Net Energy is billed according to the
seasonal tiered billing structure for Residential and Small General Service customers in
the same manner as consumption. The table below illustrates the current effective
rates applied to different levels of Excess Net Energy generation over the course of a
billing period:
Idaho Power Company
Residential and Small General Service
Calculation of Excess Net Energy Financial Credit
Residential Service Small General Service
Excess Net Energy Excess Net Energy
Produced Rate Produced Rate
Summer Summer
0-800 kWh $0.078428 0-300 kWh $0.090436
801-2000 kWh $0.095788 Over 300 kWh $0.109108
Over 2000 kWh $0.115166
Non-Summer Non-Summer
0-800 kWh $0.072355 0-300 kWh $0.090436
801-2000 kWh $0.080519 Over 300 kWh $0.095245
Over 2000 kWh $0.089960
To illustrate, a Residential net metering customer who produces 2,200 kWh of
Excess Net Energy over the course of his or her July billing month would receive a
financial credit or payment based on the following calculation:
800 kWh@$.078428 = $62.74
1200 kWh @ $.095788 = $114.95
200 kWh (ä' $.115166 = $23.03
Total Financial Credit = $20012
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -11
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -12
REQUEST NO. 8: Please explain how Idaho Power choose the December billing
period to eliminate accrued excess net energy credits.
RESPONSE TO REQUEST NO. 8: There are two components of the
Company's proposal regarding the expiration of Excess Net Energy credits: (1) the time
period over which kWh credits are allowed to carry over and (2) the date at which
credits will expire. In regard to the first component, as the Company stated on page 8,
section 15 of its initial application in this filing, "To ensure that its net metering program
can be fully administered at the state level in a manner that complies with federal law,
Idaho Power believes that it must cease its current practice of providing financial
payments to customers in the context of net metering." In light of this view, the
Company researched net metering services offered by utilities throughout the Northwest
to determine the appropriate modifications to its billing practices that would resolve the
compliance issues identified in its application. Through this research it was ultimately
determined that a monthly crediting mechanism with an annual expiration of unused
credits is a common and effective method for billing Excess Net Energy that complies
with federal law and allows net metering service to be administered at the state level. In
addition to resolving compliance issues, the annual expiration of credits serves the
purpose of limiting benefits to within a reasonable timeframe from the date of
generation, and encourages customers to right-size net metering systems to offset all or
a portion of their usage. Expiring credits annually also encourages customers who wish
to sell power to the Company for financial compensation to do so according to the same
rules and procedures as all other small power producers as detailed in the Company's
Schedule 86.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -13
The second component of this proposal—the December expiration of credits—
was based on currently-approved billing practices within the State of Idaho. According
to its currently-approved net metering tariff,' Avista Utilities, an investor-owned utility
that operates in the State of Idaho, bills Excess Net Energy according to the same
December cutoff date proposed in the Company's filing. By proposing the same cutoff
date, the Company believes its proposal will accomplish the objectives described above
and align its treatment of Excess Net Energy with currently-approved billing practices
within the State of Idaho.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
1 Avista Utilities, Schedule 63, Net Metering Option Schedule - Idaho.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -14
REQUEST NO. 9: Please refer to Exhibit 4 at page 40, which is a legislative
format of the proposed revisions to Schedule 72. Please document how Idaho Power
calculated the $100 application fee for new Net Metering customers.
RESPONSE TO REQUEST NO. 9: The $100 application fee is intended to
reflect costs associated with the application process, including customer service,
internal administration, distribution feasibility research, and field visit and inspection
requirements. While the Company feels this charge is commensurate to the services
provided throughout the application process, it has not prepared a study that specifically
delineates each of these costs.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -15
REQUEST NO. 10: Please refer to Exhibit 5, which is Idaho Power proposed
Schedule 84. Please document why the one meter option is limited to generation
facilities with a total name plate capacity rating of 25 kW or less and a "total nameplate
capacity rating no more than 2% of the Customer's Basic Load Capacity (BLC) or
comparable average maximum monthly Billing Demands."
RESPONSE TO REQUEST NO. 10: The two meter requirement for non-
Residential and non-Small General Service net metering customers was implemented
when net metering service was first established for these customer classes in Case No.
IPC-E-02-04. Final Order No. 29094 explains the Company's logic for utilizing two
meters to bill these customers:
A customer will pay normal demand and customer charges
each month but all of the customer's retail energy
consumption could be offset by the customer's generation.
Order No. 29094 also summarizes Staffs support of the Company's proposal,
and further explains the logic supporting the two meter requirement:
Demand charges, Staff contends, are intended to allow the
utility to recover its cost of maintaining the capability and
necessary infrastructure to serve a particular customer and
should not be subject to offset.
After these changes were approved in Case No. IPC-E-02-04, the Company filed
Case No. IPC-E-06-1 7 to further modify its net metering service. In this case, the
Company proposed to implement the one meter option described above for smaller net
metering systems. As stated on pages 5 and 6 of the Company's initial application in
Case No. IPC-E-06-1 7:
Some . . . customers find the requirement for a separate
meter to be a financial barrier to installing smaller net
metering systems. To encourage participation among non-
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -16
R1/R7 customers, the Company is proposing to expand the
options for these customers through changes to Schedule
84.
The application continued to describe the size limitations listed above that were
ultimately approved in Commission Order No. 30227. The Company felt that its
proposed size restrictions provided reasonable limitations on the impact to the demand
components of a net metering customer's bill while eliminating a potential financial
barrier for customers who wished to install smaller net metering systems.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -17
REQUEST NO. 11: Please provide the hourly load curves and data for the most
recent calendar year period for the Idaho jurisdiction of Idaho Power's system for the
following customer classes:
a.Residential
b.Small General Service
RESPONSE TO REQUEST NO. 11: Please see the confidential Excel file
provided on the confidential CD containing the hourly load data for calendar year 2012
for the Residential and Small General Service customer classes. The confidential CD
will be provided to those parties that have executed the Protective Agreement in this
proceeding. The hourly data provided in the confidential Excel file is from the
Company's Load Research Residential and Small General Service samples.
The response to this Request was prepared by Mary Graesch Arnold, Load
Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -18
REQUEST NO. 12: Please provide the monthly Idaho jurisdiction retail peak
demands and consumption for the most recent calendar year by customer class.
RESPONSE TO REQUEST NO. 12: Please see the confidential Excel file
provided on the confidential CD containing the jurisdictional retail peak demands and
consumption by customer class for 2011. The confidential CD will be provided to those
parties that have executed the Protective Agreement in this proceeding.
Jurisdictional retail peak demands and consumption by customer class for the
2012 calendar year are completed as part of the Company's year-end peak
responsibility study. Through the Company's typical course of business, this study is
completed no later than the end of February utilizing year-end data from the prior year.
Consequently, retail peak demands and consumption by class and jurisdiction for 2012
are not currently available.
The response to this Request was prepared by Mary Graesch Arnold, Load
Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -19
REQUEST NO. 13: Please provide the average monthly consumption per
customer for the residential and small general service classes for calendar years 2003
through 2012.
RESPONSE TO REQUEST NO. 13: Please see the confidential Excel file
provided on the confidential CD containing the average monthly consumption per
customer for calendar years 2003 through 2012 for the Residential and Small General
Service customer classes. The confidential CD will be provided to those parties that
have executed the Protective Agreement in this proceeding. The average monthly
consumption per customer is calculated from monthly class billed sales divided by the
number of customers in the customer class.
The response to this Request was prepared by Mary Graesch Arnold, Load
Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -20
REQUEST NO. 14: Please provide the full set of production requests and
responses that include the response referenced in Mr. Larkin's testimony page 8, lines
18-21.
RESPONSE TO REQUEST NO. 14: Please see the attached PDF of Idaho
Power Company's Response to First Production Request of Commission Staff produced
in Case No. IPC-E-01-39. The Response includes the Requests propounded by the
Idaho Public Utilities Commission Staff. The attachment will be provided on the non-
confidential disk
The response to this Request was prepared by Christa Bearry, Legal
Administrative Assistant, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -21
REQUEST NO. 15: Does the Company still believe the retail rate may be higher
than the value of generation produced under the net metering program? If so, please
provide any analysis, data, or any other documentation supporting this position.
RESPONSE TO REQUEST NO. 15: The Company's proposal in this case does
not attempt to compare retail rates to the value of generation, nor does it attempt to
quantify the value of generation provided by net metering systems. As stated in the
Company's initial application in this case, the intent of its net metering service is to
provide customers with an avenue to offset all or a portion of their monthly energy
usage with their own generation, not to sell their excess power to the Company.
Therefore, the financial compensation provided to customers through net metering rates
is intended to allow for the offset of costs that are embedded in retail energy rates.
Using the results of the Company's most recently reviewed class cost-of-service study,
the Company is proposing to leave all cost recovery associated with generation and
transmission in the variable energy rate that is subject to offset, while eliminating the
ability to offset cost recovery associated with the Company's distribution system and
customer services that are utilized by all customers. Customers who wish to sell power
to the Company for financial compensation should appropriately procure a power
purchase agreement according to the same rules and requirements that all other small
power producers must follow.
Notwithstanding this view, a comparison between current retail rates and market-
based compensation for small power producers indicates that retail rates are higher
than market-based prices for non-firm energy. As stated in Mr. Larkin's testimony, page
28, lines 18 through 20, "Customers wishing to sell generation to the Company for
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -22
financial payment can continue to do so by procuring a sales agreement through
Schedule 86." Small power producers are compensated according to market-based
rates reflecting 85 percent of the volume-weighted average of the daily on-peak and off-
peak Dow Jones Mid-Columbia Electricity Price Index prices for non-firm energy as
published in the Wall Street Journal. Based on market prices over the course of 2012,
monthly Schedule 86 rates peaked at $0.01769 per kWh in the month of October, and
reached their minimum of $0.00051 per kWh in the month of June. A straight average
of the twelve monthly Schedule 86 rates from 2012 results in a rate of $0.00983 per
kWh. As detailed in the Company's response to ICL's Production Request No. 7, retail
rates for the Residential and Small General Service classes range between $0.072355
and $0.115166 per kWh. Comparing retail rates to average Schedule 86 rates indicates
that the retail rate is between seven and eleven times greater than the market-based
compensation paid to small power producers for non-firm power provided outside of the
Company's net metering service. While the Company maintains that retail rates are not
designed to value energy procured through wholesale power transactions, a
comparison of current net metering compensation under retail rates to compensation
under Schedule 86 indicates that retail rates exceed the market-based rates paid for
non-firm generation several times over.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Mark Stokes, Water and
Resource Planning Director, Idaho Power Company, and Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -23
REQUEST NO. 16: Please reference Mr. Larkin's testimony on page 8, line 26
through page 9, line 5. Please provide any analyses performed by or for the Company
addressing the administrative costs and benefits of applying the retail rate for both
consumption and generation by net metering customers.
RESPONSE TO REQUEST NO. 16: The Company is not in possession of any
analyses that attempt to quantify the administrative costs and benefits of applying the
retail rate for both consumption and generation by net metering customers.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -24
REQUEST NO. 17: Please reference Mr. Larkin's testimony on page 12, lines 8-
9. To what circumstances does IPC attribute the sharply increased growth since 2010
(page 12, lines 8-9)?
RESPONSE TO REQUEST NO. 17: Idaho Power has not done research into
the causes of the growth since 2010. However, anecdotal evidence suggests lower
component prices, more dealers resulting in lower installation costs, and federal tax
credits contributing to the increase in installations. In addition, federal stimulus funding
may have accounted for an increase in solar generation installed in Idaho Power's
service area.
The response to this Request was prepared under the supervision of Pete
Pengilly, Customer Research and Analysis Leader, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -25
REQUEST NO. 18: Please provide any and all studies, analyses, polling,
information from focus groups, or any other support for Mr. Larkin's statement (starting
on page 14, line 23) that the pricing proposal balances the interests of net metering
customers and standard service customers.
RESPONSE TO REQUEST NO. 18: The Company's statement that its pricing
proposal balances the interests of net metering customers and standard service
customers is based in part on the embedded class cost-of-service study reviewed in
Case No. IPC-E-11-08. As detailed in the Company's response to Staffs Production
Request No. 1, the results of this study were utilized to develop a rate design for net
metering that accurately reflects the cost of providing this service. Under the proposed
rates, the Company is confident that its net metering service can continue to expand,
allowing net metering customers to install new systems or expand current systems
beyond the existing 2.9 MW cap. From the standpoint of standard service customers,
the Company's proposal ensures that net metering customers will pay for their utilization
of the Company's distribution system and customer services, thus limiting the potential
negative financial impact on customers without the means or desire to install net
metering systems. This balances the interests of standard service customers by limiting
upward pressure on rates that could be caused by the growth of net metering service
under current rates with the interests of net metering service customers who wish to
offset all or a portion of their usage through self-owned generation.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -26
REQUEST NO. 19: Please provide any and all studies, analyses, or any other
support for Mr. Larkin's statement (on page 15, line 1-2) that the proposed changes will
achieve the objective of "applying charges to net metering customers that accurately
reflect the cost to serve them."
RESPONSE TO REQUEST NO. 19: Please see the Company's response to
Staffs Production Request No. 1.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -27
REQUEST NO. 20: Please reference the questions an answers in Mr. Larkin's
testimony beginning on page 15, line 3 through page 18, line 16. Is the core issue
being identified the total sales reductions due to on-site generation, the exports of
electricity (net energy leaving the customer's premises on a moment by moment basis),
or the non-simultaneous netting of excess generation with consumption?
RESPONSE TO REQUEST NO. 20: The core issue described on the above-
mentioned pages is the potential inequity that arises from applying Schedule I and
Schedule 7 rates to customers taking net metering service. Rates contained in
Schedule I and Schedule 7 were designed to be applied to customers taking standard
service from the Company; i.e., those customers who only utilize the electrical grid to
take power. Because net metering customers take service differently than standard
service customers through the interconnection of their own generation resources, the
potential for inequity arises because Schedule I and Schedule 7 rates were not
designed to appropriately price this type of service. This potential inequity is driven by
the ability of net metering customers under standard service rates to unduly reduce or
completely eliminate recovery of costs associated with the Company's distribution
system and customer services.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -28
REQUEST NO. 21: Please refer to Mr. Larkin's testimony at page 22, line 19-
22. Please separately identify and quantify the benefits provided to IPC by the
installation of customer-sited generation that were considered in developing the
charges.
RESPONSE TO REQUEST NO. 21: As stated on page 22 of Mr. Larkin's
testimony, lines 18-22, "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." For a quantification of
generation and transmission-related revenue requirement embedded in the Company's
proposed rates, please see the Company's response to Staffs Production Request No.
1.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -29
REQUEST NO. 22: Please provide a list of all generating resources and the
associated capacity used by IPC to serve its retail load, whether each is owned in whole
or in part by IPC, and for those from which IPC purchases energy whether the purchase
is firm or non-firm.
RESPONSE TO REQUEST NO. 22: Below is a table of Idaho Powers
resources from its 2011 IRP, page 27.
Table 3.3 Existing Resources
Resource Type
Generator
Nameplate
Capacity (MW) Location
American Falls ..................................................................................... Hydro 92.3 Upper Snake
Bliss..................................................................................................... Hydro 75.0 Mid-Snake
Brownlee.............................................................................................. Hydro 585.4 Hells Canyon
C.J. Strike ............................................................................................ Hydro 82.8 Mid-Snake
Cascade ............................................................................................... Hydro 12.4 North Fork Payette
Clear Lake ............................................................................................ Hydro 2.5 South Central Idaho
Hells Canyon ........................................................................................ Hydro 391.5 Hells Canyon
Lower Malad ....................................................................................... .Hydro 13.5 South Central Idaho
Lower Salmon ...................................................................................... Hydro 60.0 Mid-Snake
Milner................................................................................................... Hydro 59.4 Upper Snake
Oxbow.................................................................................................. Hydro 190.0 Hells Canyon
Shoshone Falls .................................................................................... Hydro 12.5 Upper Snake
Swan Falls .......................................................................................... .Hydro 27.2 Mid-Snake
Thousand Springs ................................................................................ Hydro 8.8 South Central Idaho
Twin Falls ............................................................................................. Hydro 52.9 Mid-Snake
Upper Malad ....................................................................................... .Hydro 8.3 South Central Idaho
Upper Salmon A .................................................................................. Hydro 18.0 Mid-Snake
Upper Salmon B.................................................................................. Hydra 17.0 Mid-Snake
Boardman ............................................................................................ Coal 64.2 North Central
Oregon
Jim Bridger ........................................................................................... Coal 770.5 Southwest Wyoming
Valmy ................................................................................................... Coal 283.5 North Central
Nevada
Bennett Mountain ................................................................................ Natural 172.8 Southwest Idaho
Gas
Danskin ............................................................................................... Natural 270.9 Southwest Idaho
Gas
Salmon Diesel..................................................................................... Diesel 5.0 Eastern Idaho
Total Existing Nameplate Capacity .................................................................... 3,276.4
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -30
Idaho Power has added one generation resource since publication of the 2011
IRP: Langley Gulch, natural gas fuel, 318 MW nameplate capacity.
Please see the attached PDF for a list of the purchased power resources.
The response to this Request was prepared by Tom Noll, Senior Planning
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -31
REQUEST NO. 23: Does [PC dispatch its generating resources on an economic
basis?
RESPONSE TO REQUEST NO. 23: Yes, Idaho Power dispatches its generating
resources on an economic basis.
The response to this Request was prepared by John Anderson, Balancing
Operations Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -32
REQUEST NO. 24: Are the retail rates of IPC cost-based? Is the basis long
term or short term costs?
RESPONSE TO REQUEST NO. 24: As stated on page 33, lines 10 through 13,
of the Direct Testimony of Matthew T. Larkin in the Company's last general rate filing,
Case No. IPC-E-1 1-08, "The Company's primary approach to ratemaking in the last
several general rate cases has been to establish rates that reflect costs as accurately
as possible." The cost basis utilized in the Company's most recent general rate case
was determined through the embedded class cost-of-service study provided in the
Company's response to Staffs Production Request No. 1. Costs utilized in the class
cost-of-service study reflect a one-year period known as a "test year."
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -33
REQUEST NO. 25: Please identify and quantify each cost category (both
expenses and return on capital) the Company considers appropriately included in the
current monthly service charges.
RESPONSE TO REQUEST NO. 25: Please see the Company's attachment
provided in its response to Staff's Production Request No. I titled FC Model - ST/P
IPC-E-1 1-08.XLS. On the Unit Cost by Schedule worksheet, the revenue requirement
of each rate class is detailed by operating function (generation, transmission,
distribution) and classification (energy-related, demand-related, customer-related).
Each row that contributes to column I, "SERVICE ($/CUST/MO)," is considered by the
Company to be appropriately included in the monthly service charge. Return and
expenses are separately identified for each line item in columns A and B, respectively.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -34
REQUEST NO. 26: For the proposed $20.92 and $22.49 customer charges for
schedules 6 and 8, please identify what portion of fixed costs attributable to the
residential and small general service customers will be recovered through these
charges. Also, please identify the portion of fixed charges for the residential and small
general service classes that will be recovered from the proposed basic load charge for
Schedules 6 and 8.
RESPONSE TO REQUEST NO. 26: Based on the results of the class cost-of-
service study reviewed in Case No. IPC-E-1 1-08 and provided in the attachments to the
Company's response to Staffs Production Request No. 1, the Company's proposed
customer charges for net metering customers would collect 35 percent of total fixed
costs for the Residential class and 64 percent of total fixed costs for the Small General
class. The proposed basic load capacity charges for net metering customers would
collect 18 percent of total fixed costs for the Residential class and 11 percent of total
fixed costs for the Small General class.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -35
REQUEST NO. 27: Please reference Mr. Larkin's testimony on page 21 line 21
through page 22, line 5. Please explain in detail why the cents-per-kwh figure for the
distribution related costs collected through the energy rate for Schedule 7 is nearly twice
as high as that for Schedule 1.
RESPONSE TO REQUEST NO. 27: While a number of factors can impact the
results of the class cost-of-service study, a primary reason why distribution-related costs
collected through energy charges are higher per-kWh for Small General Service
compared to Residential Service is the average kWh use per customer for each rate
class. As stated in the Company's response to ICL's Production Request No. 6,
average monthly kWh usage for a Small General Service customer is 437 kWh, while
average monthly kWh usage for a Residential Service customer is 1,050 kWh. Within
the class cost-of-service study, the distribution-related components of revenue
requirement are primarily allocated to rate classes according to each class's peak
demand and/or the total number of customers within each class. When rates are set,
however, these allocated costs are divided by each class's total kWh consumption to
determine the appropriate cents-per-kWh rate. Because use per customer for the Small
General class is less than half that of the Residential class, customer-allocated and
demand-allocated costs are divided by a proportionately lower amount of kWh, thus
increasing the resulting cents-per-kWh rate.
The Company's complete class cost-of-service study illustrates this concept in
detail, as well as any other factors that impact cost recovery, including class energy
usage, load profiles, contributions to system paks, customer counts, etc. This study
was provided in the Company's response to Staffs Production Request No. 1.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -36
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -37
REQUEST NO. 28: In connection with the "two-meter solution" discussed by Mr.
Larkin on at page 23, line 12, did the Company perform any studies that might be used
for the generation-specific rate? If so, please provide the studies and any related data.
RESPONSE TO REQUEST NO. 28: Please see the Company's response to
ICL's Production Request No. 15. As indicated in that response, the intent of the
Company's net metering service is to provide customers with an avenue to offset all or a
portion of their monthly usage with their own generation, not to sell power to the
Company. Consequently, the Company does not believe that the introduction of a
second meter and applying a generation-specific rate falls within the scope of net
metering service. Installing a second meter and applying a generation-specific rate is
no different than any other small power producer who wishes to sell the Company, as
the intent of such an installation shifts from the desire to offset usage to the desire to
receive financial compensation based on the value of generation. For this reason, the
Company did not perform the aforementioned analysis regarding generation-specific
rates for its net metering service.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -38
REQUEST NO. 29: Please refer to Mr. Larkin's testimony on page 25 lines 14-
21. Please identify the portion of fixed cost recovery excluded from the energy rates
applied to Schedules 9, 19, and 24. Please compare this result to Schedules 1, 7 and
the proposed 6, and 8.
RESPONSE TO REQUEST NO. 29: Please see the table below.
Rate Schedule % Fixed Cost Recovery Excluded from Energy Rates
Schedule 1 8%
Schedule 6 53%
Schedule 7 14%
Schedule 8 75%
Schedule 9 38%
Schedule 19 60%
Schedule 24 35%
The percentages in this table reflect the Company's class cost-of-service study
and approved rates from its most current general rate case, Case No. IPC-E-1 1-08.
The embedded class cost-of-service study used in this filing was provided in the
Company's response to Staffs Production Request No. 1.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -39
REQUEST NO. 30: Please reference Mr. Larkin's testimony on page 26, line 23
through page 27 line 3. Please provide the determination of the "generation-related
revenue requirement" embedded in rates, and the cost/kWh or cost/kW included in each
rate schedule 1, 6, 7, and 8.
RESPONSE TO REQUEST NO. 30: Please see attached Excel file. The table
details the generation-related revenue requirement embedded in the Company's current
and proposed energy rates. Column A of this table contains the generation-related
revenue requirement calculated in the class cost-of-service study reviewed in Case No.
IPC-E-11-08 and provided in the Company's response to Staffs Production Request
No. 1. Column B contains the incremental revenue requirement for each rate class
resulting from the inclusion in rates of decommissioning costs associated with the
Boardman generation plant, and column C contains the incremental revenue
requirement for each rate class resulting from the inclusion in rates of the Langley Gulch
generation plant. Column D calculates total generation-related revenue requirement by
class by summing columns A through C. Column E contains the Company's most
current test year kWh usage for each class, and column F calculates the rates per kWh
associated with the Company's total generation-related revenue requirement. Please
note the amounts embedded in energy rates for Schedules I and 6, and the amounts
embedded in energy rates for Schedules 7 and 8, are identical because all four
schedules include 100 percent of generation-related revenue requirement in energy
rates. It should also be noted that these figures reflect total generation-related revenue
requirement, including both fixed and variable components.
In regard to the proposed basic load capacity charges, the Company is only
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -40
proposing to collect the demand-related costs associated with the distribution system
through this component; consequently, the proposed generation-related revenue
requirement to be collected through these charges is $0 per kilowatt for Schedules 6
and 8.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -41
REQUEST NO. 31: Does IPC consider net-metered customers to be wholesale
generators?
RESPONSE TO REQUEST NO. 31: Idaho Power objects to this Request as
being contrary to RP 225.02(a) by asking for a conclusion of law or statement of policy
not previously written or published. However, based upon the Federal Energy
Regulatory Commission's ("FERC") findings in the cases cited on pages 7-8 of Idaho
Power's Application in this docket, one can conclude that the FERC considers non-QF
net metering customers who generate in excess of their needs and make a net sale of
the excess energy to a utility to be wholesale generators.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -42
REQUEST NO. 32: Is it IPC's position that net-metered systems are not
qualifying facilities under PURPA?
RESPONSE TO REQUEST NO. 32: Idaho Power objects to this Request as
being contrary to RP 225.02(a) by asking for a conclusion of law or statement of policy
not previously written or published. Nonetheless, Idaho Power believes that generators
may elect to sell energy to Idaho Power under the terms of either Schedule 84
(Customer Energy Production Net Metering), or if they meet FERC's requirements to be
a PURPA qualifying facility, may elect to sell energy at PURPA avoided cost rates under
Schedule 86 (Cogeneration and Small Power Production Non-Firm Energy), or with a
fixed price contract.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -43
REQUEST NO. 33: Please reference Mr. Larkin's testimony on page 32, line 15.
Which planning process(es) are being referenced?
RESPONSE TO REQUEST NO. 33: Page 32, line 15, of Mr. Larkin's testimony
is referencing the planning process associated with the construction and maintenance
of its electrical system.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 20th day of February 2013.
x,
LISA D. NORDSTIOM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -44
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 20 th day of February 2013 I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE TO
IDAHO POWER COMPANY upon the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Karl T. Klein
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
PowerWorks LLC
Chris Aepelbacher, Project Engineer
PowerWorks LLC
5420 West Wicher Road
Glenns Ferry, Idaho 83623
Pioneer Power, LLC
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
John Steiner
24597 Collett Road
Oreana, Idaho 83650-5070
Hand Delivered
U.S. Mail
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FAX
X Email Karl. KIeinpuc. idaho.qov
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X Email bottoidahoconservation.orq
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X Email ca(äpowerworks.com
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qreqcrichardsonandoleary.com
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X Email isteinerrtci.net
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -45
City of Boise
R. Stephen Rutherford
Chief Deputy City Attorney
Boise City Attorney's Office
150 North Capital Boulevard
P.O. Box 500
Boise, Idaho 83701-0500
John R. Hammond, Jr.
BATT FISHER PUSCH & ALDERMAN, LLP
U.S. Bank Plaza, 7th Floor
101 South Capitol Boulevard, Suite 701
P.O. Box 1308
Boise, Idaho 83701
Idaho Clean Energy Association Inc.
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
Board of Directors
Idaho Clean Energy Association Inc.
P.O. Box 1212
Boise, Idaho 83701
Snake River Alliance
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
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X Email BoiseCityAttorneycityofboise.orq
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X Email kmillercsnakeriveralliance.om
Elizab?ynter; al Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE IDAHO CONSERVATION LEAGUE TO IDAHO POWER COMPANY -46