20130903Staff 17-19 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. 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. rpC-E-12-27
TO MODIFY ITS NET METERING SERVICE )
AND TO INCREASE THE GENERATION ) TOURTH pRODUCTION
CAPACITY LIMIT. ) nnQuEST oF THE) covtMrssloN srAFF 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 TUESDAY,
SEPTEMBER 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.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 SEPTEMBER 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. 17: Please explain how the Company calculates a customer's excess
net energy when the customer has multiple meters on one or more rate schedule at one or more
premises. As part of your response, please explain how the Company tracks these situations in
its billing system and ultimately calculates the bill. To the extent this will change when the new
billing system is deployed, please explain the changes.
REQUEST NO. 18: Please explain the capabilities of the Company's new billing
system with regard to net metering aggregation. Specifically, for customers having a separate
meter from the existing retail load, please explain if the new billing system can net usage across
multiple schedules and customer accounts.
REQUEST NO. 19: The Company's Schedule 84 compliance tariff says service applies
to "a Generation Facility with a total nameplate capacity rating of 100 kilowatts (kW) or smaller
that is interconnected at a Generation Interconnection Point that is adjacent to the Customer's
Point of Delivery." Please explain what "adjacent" means as used in this tariff. As part of your
response, please explain if a Generation Interconnection Point must be within a certain distance
of the customer's Point of Delivery before the Company considers it "adjacent." Also, if one
customer has several Points of Delivery, please explain whether one Generation Interconnection
Point can be considered "adjacent" to multiple Points of Delivery.
DATED at Boise, Idaho, this 3 fl au1of Septemb er 2013.
Karl T. Klein
Deputy Attorney General
Technical Staff: Mau Elam/17-19
i:umisc:prodreq/ipce I 2.27kkme prod req4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 3,20I3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY oF SEPTEMBER 2013,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-12-27, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
LISA NORDSTROM MATT LARKIN
REGULATORY DOCKETS GREG SAID
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOrSE rD 83707-0070
EMAIL: [e-mail] EMAIL: [e-mail]@idahopower.com [e-mail]
BENJAMIN J. OTTO PAPERWORKS LLC
IDAHO CONSERVATION LEAGUE CHRIS AEPELBACHER
7IO N. 6TH ST. PROJECT ENGINEER
BOISE ID 83702 5420 W WICHER RD
EMAIL: [e-mail] GLENNS FERRY ID 83623
EMAIL: [e-mail]
PETER J RICHARDSON
RICHARSON & O'LEARY JOHN STEINER
PO BOX 7218 24597 COLLETT ROAD
BOISE ID 83702 OREANA ID 83650-5070
EMAIL: [e-mail] EMAIL: [e-mail]
JOHN R. HAMMOND JR
R. STEPHEN RUTHERFORD BATT FISHER PUSCH
CITY OF BOISE CITY, ID & ALDERMAN LLP
PO BOX 500 PO BOX 1308
BOISE ID 83701-O5OO BOISE ID 83701
EMAIL: [e-mail] EMAIL: [e-mail]
KEN MILLER DR
CLEAN ENERGY PROGRAM
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 8370I
EMAIL: kmiller@snakeriveral liance.org
DEAN J MILLER
MoDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
EMAIL: [e-mail]
CERTIFICATE OF SERVICE
BOARD OF DIRECTORS
ID CLEAN ENERGY ASSOC INC
PO BOX 1212
BOISE ID 83701
CERTTFICATE OF SERVICE