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Home My WebLink About20130424IPC to Staff 10-16.pdfLISA D. NORDSTROM Lead Counsel lnordstrom(äidahopower.com • HO iPNER® An IDACORP company 10-41 ±t April 24, 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 Third Production Request of the Commission Staff 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 Third Production Request of the Commission Staff to Idaho Power Company. Very truly yours, Lisa D. Nordstrom LDN :csb 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: (208) 388-5825 Facsimile: (208) 388-6936 Inordstromcidahopower.com ihiItonidahopower.com ZO3R2 AMtO'12 .i fc) rrii c 'c IL if Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR AUTHORITY TO MODIFY ITS NET METERING SERVICE AND TO INCREASE THE GENERATION CAPACITY LIMIT. CASE NO. IPC-E-12-27 IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Third Production Request of the Commission Staff to Idaho Power Company dated April 3, 2013, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -1 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." RESPONSE TO REQUEST NO. 10: Idaho Powers Open Access Transmission Tariff defines "Good Utility Practice" as: Any of the practices, methods and acts engaged in or approved by a significant portion of the electric utility industry during the relevant time period, or any of the practices, methods and acts which, in the exercise of reasonable judgment in light of the facts known at the time the decision was made, could have been expected to accomplish the desired result at a reasonable cost consistent with good business practices, reliability, safety and expedition. Good Utility Practice is not intended to be limited to the optimum practice, method, or act to the exclusion of all others, but rather to be acceptable practices, methods, or acts generally accepted in the region, including those practices required by Federal Power Act section 215(a)(4). The response to this Request was prepared by Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -2 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. RESPONSE TO REQUEST NO. 11: The intent of the above-referenced provision is to indicate that customers may be charged for expenses of disconnection and reconnection incurred by the Company if the expenses were incurred as the result of a customer's net metering system and/or the customer's failure to abide by the provisions contained in Schedule 72. This provision is not intended to apply to any situation involving disconnects and/or reconnects associated with planned or unplanned maintenance or repair of the Company's system. The response to this Request was prepared by Matthew Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -3 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. RESPONSE TO REQUEST NO. 12: Yes. Whenever the Company disconnects and locks a system, a laminated yellow tag explaining the reason for disconnection and providing Company contact information will be placed on the device. A door hanger or card will also be left at the front door at the time of disconnection. Within 24 hours of the disconnection, the customer will be called and written notification will be sent via U.S. Mail. The response to this Request was prepared by Scott Gates, Renewable Energy Specialist, Idaho Power Company, and Patti Best, Program Specialist, Idaho Power Company, at the direction of Matthew Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -4 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. If a customer's net metering system fails inspection, the system is locked and a laminated yellow tag providing Company contact information is placed on the device. Idaho Power also leaves a door hanger or card at the time of disconnection. A Company representative then follows up via telephone with the customer regarding the reason(s) for the failure, and assists the customer in steps needed to bring the system into compliance with inspection requirements. Once all issues have beeh addressed and the customer indicates that the system has passed all applicable federal, state, and local inspection requirements, Idaho Power will re-inspect the system. The response to this Request was prepared by Scott Gates, Renewable Energy Specialist, ldahc Power Company, and Patti Best, Program Specialist, Idaho Power Company, at the direction of Matthew Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -5 REQUEST NO. 14: By schedule, please provide the number of net metering customers currently on a budget payment plan. RESPONSE TO REQUEST NO. 14: Six residential net metering customers are currently enrolled in Budget Pay. Two of these customers have been enrolled in Budget Pay for less than 12 months. No non-residential net metering customers are enrolled in Budget Pay. The response to this Request was prepared by Maggie Brilz, Customer Service Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -6 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. RESPONSE TO REQUEST NO. 15: Four net metering customers have been enrolled in Budget Pay for 12 months or more. All four customers take residential service. The anniversary month in which the Budget Pay amount was most recently recalculated is noted and highlighted below. Customer - 8605 BALANCE BUDGET ACTUAL AT END BILL PAY BILLED NET OF PLAN DATE AMOUNT AMOUNT KWH PERIOD 20130315 115.00 138.01 1619 20130213 115.00 146.65 1719 20130114 115.00 193.34 2234 20121214 115.00 149.48 1752 20121114 115.00 128.19 1505 20121012 115.00 104.29 1228 20120912 115.00 130.65 1429 20120713 122.00 142.02 1535 20120613 122.00 98.50 1181 20120514 122.00 107.33 1344 20120413 122.00 106.11 1329 IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -7 Customer - 3893 BALANCE BUDGET ACTUAL AT END BILL PAY BILLED NET OF PLAN DATE AMOUNT AMOUNT KWH PERIOD 20130315 55.00 41.44 466 20130213 55.00 61.09 719 20130114 55.00 65.45 775 20121214 55.00 53.8 625 20121114 55.00 49.05 564 20121012 55.00 54.4 633 20120912 55.00 87.08 974 20120813 55.00 125.96 1324 20120713 55.00 86.06 965 20120613 55.00 47.3 560 20120514 55.00 35.48 416 Customer - 8644 BALANCE BUDGET ACTUAL AT END BILL PAY BILLED NET OF PLAN DATE AMOUNT AMOUNT KWH PERIOD 20130312 55.00 48.19 553 20130208 55.00 48.04 551 20130109 55.00 87.82 1037 20121108 46.00 34.44 376 20121009 46.00 53.94 627 20120907 46.00 58.38 644 20120808 46.00 80.09 875 20120710 46.00 58.66 667 20120608 46.00 48.5 583 20120509 46.00 43.05 520 20120410 46.00 48.21 591 IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -8 Customer - 1600 BALANCE BUDGET ACTUAL AT END BILL PAY BILLED NET OF PLAN DATE AMOUNT AMOUNT KWH PERIOD 20130328 74.00 58.34 673 20130227 74.00 63.40 737 20130129 74.00 69.50 813 20121228 74.00 77.81 908 20121127 74.00 66.17 772 20121025 74.00 45.09 505 20120824 69.00 145.97 1503 20120726 69.00 150.12 1556 20120626 69.00 52.36 602 20120525 69.00 36.04 418 20120426 69.00 44.15 528 The response to this Request was prepared by Maggie BriIz, Customer Service Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -9 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. RESPONSE TO REQUEST NO. 16: Idaho Power intends to extend the option to enroll in Budget Pay to net metering customers served under the proposed Schedules 6 and 8. If the Idaho Public Utilities Commission ("Commission") approves the Company's request to implement Schedules 6 and 8, a revised Rule I will be submitted to the Commission with language specifying the availability of this option to customers taking service under Schedules 6 and 8. The response to this Request was prepared by Maggie Brilz, Customer Service Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 24th day of April 2013. LISA D. NORDSTAOM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24 th day of April 2013 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF 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 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 Overnight Mail FAX X Email Karl. Kleincpuc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAX X Email bottoidahoconservation.orq Hand Delivered U.S. Mail Overnight Mail FAX X Email cacpowerworks.com Hand Delivered U.S. Mail Overnight Mail FAX X Email Pete r(richardsonandoleary.com Hand Delivered U.S. Mail Overnight Mail FAX X Email jsteiner(rtci.net IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -11 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 Hand Delivered U.S. Mail Overnight Mail FAX X Email BoiseCityAttorney(äcityofboise.org Hand Delivered U.S. Mail Overnight Mail FAX X Email irhbattfisher.com Hand Delivered U.S. Mail Overnight Mail FAX X Email ioe(mcdevitt-milIer.com Hand Delivered X U.S.Mail Overnight Mail FAX Email Hand Delivered U.S. Mail Overnight Mail FAX X Email kmiIIer(äsnakeriveralliance.orc ON~'NtCA Jz;k 011 Christa Bearry, Legal Assistant - IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -12