20130403Staff 10-16 to IPC.pdf

KARL T. KLEIN Ell
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 2C I APR 3 AM 10: 11
P0 BOX 83720
BOISE, IDAHO 83720-0074 I JT !'s - '-
[phone]
IDAHO BAR NO. 5156
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 ) THIRD 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 WEDNESDAY,
APRIL 24, 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.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 APRIL 3, 2013
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. 10: Proposed Schedules 6 and 8 and revised Schedule 84 contain
references to "prudent electrical practices," which is defined in those schedules as "those
practices, methods and equipment that are commonly used in prudent electrical engineering and
operations to operate electric equipment lawfully and with safety, dependability, efficiency and
economy." Schedule 72 refers to the term "good utility practices," which is not defined. Please
provide a description of what constitutes "good utility practices."
REQUEST NO. 11: In proposed Schedule 72, Second Revised Sheet No. 72-5, Section
5, includes the provision that "All expenses of disconnections and reconnections incurred by the
Company will be billed to the Seller." Does this apply to any situation where the seller is
disconnected or reconnected by the Company, including instances where the Company
disconnects for planned or unplanned maintenance or repair of the Company's system? Please
explain.
REQUEST NO. 12: If the Company discovers an unauthorized net metering system
installation and proper disconnection equipment is present, will written notice be provided to the
customer following disconnection if the Company is unable to contact the customer either in
person or by telephone? Please explain. See Proposed Second Revised Sheet No. 72-9, Section
2.a.
REQUEST NO. 13: If a customer's net metering system fails the on-site inspection as
described in Schedule 72, what process does the Company intend to follow? See Proposed
Second Revised Sheet No. 72-7 & 8, Section 5.
REQUEST NO. 14: By schedule, please provide the number of net metering customers
currently on a budget payment plan.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 3, 2013
REQUEST NO. 15: For each of those customers identified in Production Request No.
14 who have been on a budget payment plan for 12 months or more, please provide the following
information for the most recent 12-month plan period: (a) the monthly net kWh (used or excess
energy) billed, the actual billed dollar amount, and the budget pay dollar amount; (b) the credit or
debit balance remaining at the end of the 12-month plan period; and (c) the anniversary month
during which the new budget pay amount was or will be recalculated.
REQUEST NO. 16: Idaho Power's Rule I offers customers served under Schedules 1, 4,
5 & 7 the option of enrolling in a budget pay plan, and net metering customers are not prohibited
from enrollment. Does Idaho Power intend to extend this option to net metering customers
served under the proposed Schedules 6 & 8? Please explain.
DATED at Boise, Idaho, this 3- day of April 2013.
)t,l I /----
Karl T. Klein
Deputy Attorney General
Technical Staff: Beverly Barker/10-13
Daniel KleinI14-16
i:umisc:prodreq/ipce 12.27kkbabdk prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 APRIL 3, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF APRIL 2013,
SERVED THE FOREGOING THIRD 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: [e-mail]
[e-mail]
BENJAMIN J. OTTO
IDAHO CONSERVATION LEAGUE
710N. 6TH ST.
BOISE ID 83702
EMAIL: botto(2iidahoconservation.org
MATT LARKIN
GREG SAID
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: [e-mail]
gsaid(idahopower.com
SECRETAR
CERTIFICATE OF SERVICE