20130419Idaho Clean Energy 1-3 to IPC.pdf

McDevitt & Miller LLP
Lawyers
420 W. Bannock Streef13 19 pj t: 20
[phone] P.O. Box 2564-83701 Chas. F. McDevitt
[phone] (Fax) Boise, Idaho 83702 Dean J (Joe) Miller
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April 19, 2013
Via Hand Delivery
Jean Jewel, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Case No. IPC-E-12-27
Idaho Clean Energy Association Inc.
Dear Ms. Jewell:
Enclosed for filing, please find three (3) copies of Idaho Clean Energy Association Inc's First
Production Requests to Idaho Power Company.
Kindly return a file stamped copy to me.
Very Truly Yours,
McDevitt & Miller LLP
Dean J. Miller
DJM/hh
Encl.
ORIGINAL
Dean J. Miller (ISB No. 1968)
Chas. F. McDevitt (ISB No. 835)
Celeste K. Miller (ISB No. 2590)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
29I3APR 19 PM 4:20
- J
Attorney for Idaho Clean Energy Association Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
N THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
MODIFY ITS NET METERING
SERVICE AND TO INCREASE THE
GENERATION CAPACITY LIMIT
Case No. IPC-E-12-27
FIRST PRODUCTION REQUESTS OF
IDAHO CLEAN ENERGY
ASSOCIATION INC., TO IDAHO
POWER COMPANY
Pursuant to RP 221.02 and 221.03, Petitioner propounds the following Request
for Productions of Documents to Idaho Power Company ("Company").
Petitioner requests that the Company provide Answers on or before May 3, 2013.
This Production request is to be considered as continuing, and the Company is
requested to provide, by way of supplementary responses, additional documents or
information that it or any person acting on its behalf may later obtain.
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
FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION INC., TO
IDAHO POWER COMPANY -1
different, the witness who can sponsor the answer at hearing. Reference IDAPA
31.01.01.228.
REQUEST FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: Please provide the number of residential customers on
Schedule 1, excluding net metering customers, who had annual kWh usage in 2012 in the
following ranges:
18,000-21,000 kWh/year
21,001 —24,000
24,001 -27,000
27,001 —30,000
30,001 - 33,000
33,001 - 36,000
36,001 - 39,000
Greater than 39,000 kWh/year
Note: If data is readily available showing the distribution of residential customers
on Schedule 1 relative to annual kWh usage with a similar level of granularity, we would
be happy to use the data readily available.
REQUEST NO. 2: For the 10,000 customers on Schedule 1 who consumed the
highest level of annual kWh in 2012: Please provide calculation of the potential impact
of this filing in a format similar to the calculations provided in "(9) Confidential
Attachment - Response Staff's Request No. 9" for a representative sampling of these top
consuming 10,000 customers. For example, this includes the "Bill - Current Rates"
which would reflect the 2012 bill for customers revised to represent current rates, and
"Bill - Proposed Rates" which would reflect what these standard customers would be
billed if they were net metering customers under the rates proposed in the filing (the
energy charge, BLC charge, and service charge).
FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION INC., TO
IDAHO POWER COMPANY -2
REQUEST NO. 3: In its Application (Paragraph 6), the Company recites that
353 customers currently participate in net meter service. In response to Staff Production
Request No. 9, the Company lists 281 net meter customers. Please explain this apparent
discrepancy.
DATED this \!'\ day of April, 2013.
IDAHO CLEAN ENERGY ASSOCIATION INC.
BYXL
Dean J. Miller
Attorney for Idaho Clean Energy Association Inc.
FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION INC. TO
IDAHO POWER COMPANY -3
CERTIFICATE OF SERVICE
I hereby certify that on the Jeda y of April, 2013,1 caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary Hand Delivered
Idaho Public Utilities Commission U.S. Mail
472 West Washington Street Fax J
P.O. Box 83720 Fed. Express J
Boise, ID 83720-0074 Email
[e-mail]
Karl Klein, Deputy Attorney General Hand Delivered
Idaho Public Utilities Commission U.S. Mail J
472 West Washington Street Fax
P.O. Box 83720 Fed. Express
Boise, ID 83720-0074 Email >1
karl.kleinpuc.idaho.gov
Lisa D. Nordstrom Hand Delivered
Matt Larkin U.S. Mail J
Greg Said Fax
Idaho Power Company Fed. Express J
1221 West Idaho Street (83702) Email
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Benjamin J. Otto Hand Delivered
710N. 6th Street U.S. Mail
Boise, Idaho 83701 Fax
[e-mail] Fed. Express J
Email /
Peter J. Richardson Hand Delivered
Richardson & O'Leary, PLLC U.S. Mail
PO Box 72l8 Fax
Boise, ID 83702 Fed. Express
[e-mail] Email
FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION INC., TO
IDAHO POWER COMPANY -4
Chris Aepelbacher, Project Engineer Hand Delivered
5420 W. Wincher Road U.S. Mail
Glenns Ferry Idaho 83623 Fax
[e-mail] Fed. Express
Email 7I
R. Stephen Rutherford Hand Delivered
Boise City Attorney's Office U.S. Mail
150 N. Capital Blvd. Fax
P.O. Box 500 Fed. Express
Boise, Idaho 83701-0500 Email
[e-mail]
John R. Hammond, Jr. Hand Delivered
Batt Fisher Pusch & Alderman, LLP U.S. Mail
U.S. Bank P1aza70' Floor Fax
101 S. Capital Blvd., Suite 701 Fed. Express
P.O. Box 1308 Email
Boise, Idaho 83701
[e-mail]
Ken Miller, Clean Energy Director Hand Delivered
Snake River Alliance U.S. Mail
P.O. Box 1731 Fax
Boise, Idaho 83701 Fed. Express
[e-mail] Email
BY:
MCDEVITT & ILLER LLP
FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION INC., TO
IDAHO POWER COMPANY -5