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Home My WebLink About20130508IPC to Boise City 1-8, 1-2.pdfIo An IDACORP Company 7I4 7 FM 14 514 LISA D. NORDSTROM Lead Counsel ES Inordstromidahopower.com May 7, 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 - Idaho Power Company's Responses to the First Production Requests of the City of Boise to Idaho Power Company 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 the City of Boise to Idaho Power Company. Also, enclosed in a separate sealed envelope are an original and three (3) copies of Idaho Power Company's CONFIDENTIAL Attachment to the City of Boise's Interrogatory No. 7 to Idaho Power Company. In addition, enclosed are four (4) copies of a non-confidential disk containing data responsive to this Request. 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: (208) 388-5825 Facsimile: (208) 388-6936 Inordstromidahopower.com ihiItoncidahopower.com j - PM 54 :1) F iES r1JiIsSft),. 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 THE CITY OF BOISE TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Requests of the City of Boise to Idaho Power Company dated April 26, 2013, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE TO IDAHO POWER COMPANY -1 INTERROGATORY NO. 1: Please provide Idaho Power Company's system- wide load factor for 2008-2012. ANSWER TO INTERROGATORY NO. 1: The table below contains the Company's system-wide load factor for each year 2008 through 2012. The load factors below were calculated utilizing weather normalized historical data as detailed in the attached Excel file. Weather Normalized System Load Factor Year Load Factor 2008 57% 2009 54% 2010 53% 2011 57% 2012 56% The answer to this Interrogatory 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 THE CITY OF BOISE TO IDAHO POWER COMPANY -2 INTERROGATORY NO. 2: Please provide Idaho Power Company's reserve margin for 2008-2012, and the reserve margin projected for 2013-2022. It is the City's understanding that any reserve margin is determined by an analysis involving the Company's peak load during a critical water year. ANSWER TO INTERROGATORY NO. 2: The reserve margin projected for 2013-2022 as provided in the 2011 Integrated Resource Plan ("IRP") is contained in the following table. Year 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Reserve margin (%) 12.7 9.8 9.9 17.8 15.6 13.6 11.5 9.6 9.3 11.9 During the 2008-2012 period, Idaho Power met customer loads and operating reserve requirements in compliance with mandatory reliability standards. Idaho Power calculates reserve margin on a forward-looking basis, allowing it to provide projected reserve margin for 2013-2022 from the most recent IRP released in 2011. Reserve margin is a planning metric that is used to evaluate projected resource adequacy over a long-term planning horizon, such as the planning horizon considered for the IRP. A review of earlier IRPs can provide reserve margins as projected for 2008-2012. The reserve margin as projected in the 2006 IRP for 2008-2009, and in the 2009 IRP for 2010-2012 is provided in the following table: Year 2008 2009 2010 2011 2012 Reserve margin (%) 2.6 3.3 10.6 8.7 1 16.1 The reserve margin from the 2013 IRP will be available upon release of the report in June 2013. Idaho Power calculates the reserve margin resulting from the resource development identified in the preferred resource portfolio. The City's IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE TO IDAHO POWER COMPANY -3 understanding is incorrect; reserve margin is calculated assuming median conditions for load and hydro. The answer to this Interrogatory was prepared by Phil DeVol, Resource Planning Leader, 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 THE CITY OF BOISE TO IDAHO POWER COMPANY -4 INTERROGATORY NO. 3: With reference to Mr. Larkin's testimony (page 21, line 10), what is meant by the term "unduly reduce"? ANSWER TO INTERROGATORY NO. 3: Within the context of Mr. Larkin's testimony, the term "unduly reduce" is used in reference to the ability of net metering customers to avoid paying for certain costs they impose on the Company's system. The answer to this Interrogatory 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 THE CITY OF BOISE TO IDAHO POWER COMPANY -5 INTERROGATORY NO. 4: Idaho Power Company's Application defines NEM as a service for "transfer of electricity to the Company through customer-owned generation facilities...." Please provide any statute or rule upon which this definition is based that reflects similar language. ANSWER TO INTERROGATORY NO. 4: The full sentence referenced in the above interrogatory reads, "Net metering is a service which provides for transfer of electricity to the Company through customer-owned generation facilities with the intent of offsetting all or a portion of a customer's energy usage." The Company's currently- approved Schedule 84, Customer Energy Production Net Metering, reads, "Service under this schedule is available throughout the Company's service territory within the State of Idaho for Customers intending to operate as Sellers under this schedule to generate electricity to reduce all or part of their monthly energy usage." The currently- approved Schedule 84 is publicly available on the Company's website at: http://www.idahopower.com/pdfs/BusinessToBusiness/tariffPdf84 . pdf. The answer to this Interrogatory 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 THE CITY OF BOISE TO IDAHO POWER COMPANY -6 INTERROGATORY NO. 5: Is it Idaho Power Company's position that all excess generation, including any excess remaining at the end of the year, is in effect, purchased by the Company? (Please reference Mr. Larkin's testimony at page 26, line 25.) ANSWER TO INTERROGATORY NO. 5: Using current treatment of excess net energy, the financial compensation of net metering customers for excess net energy is executed on a monthly basis. The Company is in effect purchasing power from net metering installations at the full retail rate. The answer to this Interrogatory 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 THE CITY OF BOISE TO IDAHO POWER COMPANY -7 INTERROGATORY NO. 6: Please provide Idaho Power Company's hourly load profiles for all customer classes for the years 2010, 2011, and 2012. ANSWER TO INTERROGATORY NO. 6: The individual hourly load profiles for all Idaho customer classes for 2010-2012 are included in the attached Excel file. The answer to this Interrogatory 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 THE CITY OF BOISE TO IDAHO POWER COMPANY -8 INTERROGATORY NO. 7: Please provide the total cost of Idaho Power Company's new billing system. ANSWER TO INTERROGATORY NO. 7: The confidential table, provided separately, presents Idaho Power's current forecast of the total cost of its new billing system. There are three major projects associated with the purchase and implementation of the Company's new Customer Relationship and Billing System ("CR&B"). The three projects include the procurement and implementation of CR&B, the integration of CR&B with existing Company systems, and the implementation of an "Enterprise Data Warehouse" to facilitate the storage of and access to historical billing data. The cost of each of these new billing system projects was offset entirely or in part by a Smart Grid Investment Grant funded by the U.S. Department of Energy ("DOE") Because the information contained in the table is confidential, it will be provided separately to those parties that have signed the Protective Agreement in this proceeding. The answer to this Interrogatory 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 RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE TO IDAHO POWER COMPANY -9 INTERROGATORY NO. 8: What does Idaho Power Company charge for a new meter hookup for a new customer? ANSWER TO INTERROGATORY NO. 8: Rule D provides that "The Company will install and maintain the metering equipment required by the Company to measure power and energy supplied to the Customer. Meter installations will be done at the Company's expense except as specified below or otherwise specified in a schedule." Rule D can be found at: http://www. idahopower.com/AboutUs/RatesRegulator-y/Tanffs/tariffPDF.cfm?id=28 The answer to this Interrogatory was prepared by Connie Aschenbrenner, 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 THE CITY OF BOISE TO IDAHO POWER COMPANY -10 REQUEST NO. 1: Please produce a copy of each and every document responsive to Interrogatory Nos. 1-8. RESPONSE TO REQUEST NO. 1: The responsive documents are included in the Company's responses to the City of Boise's Interrogatory Nos. 1-8. The response to this Request was prepared by Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE TO IDAHO POWER COMPANY -11 REQUEST NO. 2: Please provide Idaho Power Company's allocation manual from the most recent rate case. RESPONSE TO REQUEST NO. 2: The attached PDF file contains Mr. Larkin's Exhibit No. 30 from the Company's most recent Idaho general rate case, Case No. IPC- E-1 1-08. This exhibit details the class allocation process utilized to calculate the Company's revenue requirement by rate class. The class cost-of-service models described in this document were provided in the Company's response to Staffs Request for Production No. 1. 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 7th day of May 2013. i14SAD. NORDSTROM Attorney for Idaho-Power Company IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE TO IDAHO POWER COMPANY -12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 7 th day of May 2013 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE 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. KleinDuc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAX X Email bottoidahoconservation.orq Hand Delivered U.S. Mail Overnight Mail FAX X Email ca(powerworks.com Hand Delivered U.S. Mail Overnight Mail FAX X Email petercrichardsonandoleary.com Hand Delivered U.S. Mail Overnight Mail FAX X Email jsteiner(ãrtci.net IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE TO IDAHO POWER COMPANY -13 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 Hand Delivered U.S. Mail Overnight Mail FAX X Email BoiseCityAttorneycityofboise.ora John R. Hammond, Jr. Hand Delivered BATT FISHER PUSCH & ALDERMAN, LLP U.S. Mail U.S. Bank Plaza, 7th Floor Overnight Mail 101 South Capitol Boulevard, Suite 701 FAX P.O. Box 1308 X Email irhcbatffisher.com 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 ioemcdevitt-miIIer.com Hand Delivered X U.S. Mail Overnight Mail FAX Email Hand Delivered U.S. Mail Overnight Mail FAX X Email kmiIIer(àsnakeriveraI1iance.org Elizabeth Paynter, LLAsgiint IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF THE CITY OF BOISE TO IDAHO POWER COMPANY -14 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-12-27 IDAHO POWER COMPANY ANSWER TO THE CITY OF BOISE'S INTERROGATORY NO. 7 THIS ATTACHMENT IS CONFIDENTIAL AND WILL BE PROVIDED TO THOSE PARTIES THAT HAVE SIGNED THE PROTECTIVE AGREEMENT