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Home My WebLink About20130503IPC to ICEA 1-3.pdfIDAHO RZ An IDACORP Company .................................................................c. LISA D NORDSTROM IA1r tt Lead Counsel U ILi I j .ISS1 . lnordstrom(idahopower.com May 3, 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 Responses to the First Production Requests of Idaho Clean Energy Association, Inc. Dear Ms. Jewell: Enclosed for filing in the above matter are an original and three (3) copies of Idaho Power Company's Responses to the First Production Requests of Idaho Clean Energy Association, Inc., to Idaho Power Company. Very truly yours, Lisa D. Nordstro 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: (208) 388-5825 Facsimile: (208) 388-6936 lnordstromcidahopower.com IhiltonidahoDower.com 2011.MAY -3 AM 11:02 UTILITIE-3 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 RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Company"), and in response to the First Production Requests of Idaho Clean Energy Association, Inc., to Idaho Power Company dated April 19, 2013, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., TO IDAHO POWER COMPANY -1 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 I relative to annual kWh usage with a similar level of granularity, we would be happy to use the data readily available. RESPONSE TO REQUEST NO. 1: The number of Idaho Residential Schedule I service points with 2012 annual kilowatt-hour ("kWh") usage in the specific ranges requested are: 18,000-21,000 kWh/year 26,058 21,001-24,000 16,679 24,001-27,000 10,322 27,001-30,000 6,500 30,001-33,000 3,948 33,001-36,000 2,433 36,001-39,000 1,553 Greater than 39,000 kWh/year 3,615 The response to this Request was prepared by Mary Arnold, Leader of Load Research, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., TO IDAHO POWER COMPANY -2 REQUEST NO. 2: For the 10,000 customers on Schedule I 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 Staffs 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). RESPONSE TO REQUEST NO. 2: The Company is unable to perform the requested analysis with the information provided. The Company cannot calculate the estimated bill impact of a transition from Schedule I or Schedule 7 to Schedule 6 or Schedule 8 without the capacity and production of the assumed net metering systems. 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 RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., TO IDAHO POWER COMPANY -3 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. RESPONSE TO REQUEST NO. 3: Customer counts listed in the Company's initial application reflect customers under active net metering service and customers who had submitted applications for net metering service as of November 1, 2012. Customer counts listed in the Company's response to Staffs Request for Production No. 9 only reflect customers impacted by the proposed Schedules 6 and 8 with active billing data recorded in the 12 billing months of 2012. Consequently, customer counts listed in the Company's response to Staffs Request for Production No. 9 are lower than total system net metering customer counts because they are limited to Residential and Small General Service net metering customers within the Company's Idaho jurisdiction with billing data from January 2012 through December 2012. 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. DATED at Boise, Idaho, this 3rd day of May 2013. LISA D. NORDSTOM Attorney for Idaho power Company IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., TO IDAHO POWER COMPANY -4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 3 rd day of May 2013 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., 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.gov Hand Delivered U.S. Mail Overnight Mail FAX X Email bottocidahoconservation.orq Hand Delivered U.S. Mail Overnight Mail FAX X Email cacpowerworks.com Hand Delivered U.S. Mail Overnight Mail FAX X Email Pete rrichardsonandoleary.com Hand Delivered U.S. Mail Overnight Mail FAX X Email isteinerrtci.net IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., TO IDAHO POWER COMPANY -5 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 BoiseCityAftornev(,@-cityofboise.org Hand Delivered U.S. Mail Overnight Mail FAX X Email jrhcbattfisher.com Hand Delivered U.S. Mail Overnight Mail FAX X Email ioe(mcdevitt-miller.com Hand Delivered X U.S.Mail Overnight Mail FAX Email Hand Delivered U.S. Mail Overnight Mail FAX X Email kmiller(snakeriveralliance.om Elizaeth Payntet'1gal Assistant IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF IDAHO CLEAN ENERGY ASSOCIATION, INC., TO IDAHO POWER COMPANY -6