20130131Staff 1-33 to IPC.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECEty
ZD3 JAN 31 PM 3: 05
IDAHO PUk%U•. 'JTILiTiE.j Co MlssIo
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY)
TO TEMPORARILY SUSPEND ITS A/C COOL )
CREDIT AND IRRIGATION PEAK REWARDS )
DEMAND RESPONSE PROGRAMS. )
)
)
)
CASE NO. IPC-E-12-29
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Donald L. Howell, II, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
THURSDAY, FEBRUARY 21, 2013. RESPONSES TO PRODUCTION REQUEST NOS.
11, 12, 13, 16, 17,22 AND 25 ARE REQUESTED BY TUESDAY, FEBRUARY 5,2013.
This Production Request is to be considered as continuing, and Idaho Power 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.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 JANUARY 31, 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. 1: Please identify and provide the peak hour load for each year from
2004 through 2012.
REQUEST NO. 2: For each IRP from 2002 to present, please indicate the amount of
peak-hour reduction the Company assumed each Demand Response (DR) program contributes
during the planning period.
REQUEST NO. 3: Please provide the verified level of DR reduction for each peak hour
identified in Production Request No. 1 by program.
REQUEST NO. 4: Please indicate the level of transmission capacity on the Company's
system available for import after accounting for market purchases during the peak hours
identified in Production Request No. 1.
REQUEST NO. 5: For each year from 2004 through 2012:
a.Please provide the dates and time periods a DR curtailment event occurred by
program.
b.Please provide the level of verified DR curtailment by program for each event.
c.Please provide the level of 'opt-outs' for each event and by each DR program.
d.Please indicate how each event restricted the ability to call the subsequent event.
REQUEST NO. 6: Please provide the cost-effectiveness evaluations for each DR
program for 2004-2012, including all assumptions used.
REQUEST NO. 7: Please explain how available transmission capacity is factored into
the load and resource balance in the IRP. Does the Company assume all firm capacity will be
utilized in the peak hour?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JANUARY 31, 2013
REQUEST NO. 8: For 2006 through 2012, please provide monthly generation output
for June, July and August for each of the Company's SCCT gas plants.
REQUEST NO. 9: For 2006 through 2012, please provide the number of hours by
month for June, July and August that each of the Company's SCCT plants ran.
IRRIGATION PEAK REWARDS
REQUEST NO. 10: For 2006 through 2012, please provide the following information
for the Irrigation Peak Rewards Program delineated by Option 1, 2, 3 and Timer:
a.Amount of load under contract
b.Number of service points
c.Number of customers
d.Amount of incentive paid (with workpapers used in the calculations)
e.Incentive payment structure
f.Non-incentive program costs, by category
g.Number and duration of dispatch events
h.Number of opt-outs
REQUEST NO. 11: Please provide a detailed cost breakdown of the $600,000 to
$900,000 in program related expenses for 2013 referenced on page 19 of Theresa Drake's
testimony. Please include a specific reference for the vendor contracts.
REQUEST NO. 12: Would the Company maximize hours and events of IPR
curtailment if there were no variable payment component? Why or why not?
REQUEST NO. 13: Ms. Drake asserts that the Company would incur $600,000-
$900,000 related to keeping load control devices operational in 2013, for website maintenance,
telecommunication costs, and minimal maintenance on the devices. Why does the Company
believe it needs to continue to provide these services?
REQUEST NO. 14: Please provide the data used for the Peak-hour Deficits without
Demand Response or B2H on page 7 of Mr. Stokes' testimony. Please provide the answer in an
executable excel file.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 JANUARY 31, 2013
REQUEST NO. 15: From the Company's perspective, has the use of DR delayed any
transmission or distribution costs due to capacity constraints either to or within its system? What
led the Company to this conclusion?
REQUEST NO. 16: On pg. 4 of Ms. Drake's testimony, she claims that the Company
investigated various short-term options for its demand response programs. Please provide all
alternatives the Company investigated that are not included in the current application.
REQUEST NO. 17: Please provide the data supporting the statement on page 6 of Ms.
Drake's testimony that recent heavy load market energy prices led the Company to conclude that
an energy only variation of DR would be approximately three percent of the capacity-based
alternative cost value. Please provide the corresponding work papers in an executable excel file.
REQUEST NO. 18: Ms. Drake claims that the Company "is aware that there may be
additional stakeholders interested in working with the Company to better understand this process
[DR suspension] and will coordinate discussions as necessary" (p. 8). Beyond the current EEAG
members, who has the Company identified that may be interested? How will the Company
solicit and encourage other diverse individuals and organizations to participate in the process?
REQUEST NO. 19: Please provide the amount of demand response incentives included
in normalized 2013-2014 PCA power supply expenses. Please separate by program.
REQUEST NO. 20: Please provide the final expense of each demand response program
booked in 2012. Please classify by customer incentive, labor/administration, materials &
equipment, other expense, and purchased services.
REQUEST NO. 21: Please provide the current Energy Efficiency Rider balance.
REQUEST NO. 22: Has the Company performed an analysis to determine the effect of
program suspension on future customer participation?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 JANUARY 31, 2013
REQUEST NO. 23: Specifically, what date did the Company decide to suspend DR
programs?
A/C COOL CREDIT
REQUEST NO. 24: Following the July 15, 2013 program vendor expiration date, and
assuming the program will be temporarily suspended, why does the Company claim that it needs
continued access to the vendor's participant database?
REQUEST NO. 25: Ms. Drake claims that the A/C Cool Credit program has an average
drop-out rate of 14% (p. 15). Over how many years was 14% average calculated? Please
provide the dropout rate for each year. Did the Company collect any information as to why
customers dropped out? If so, please provide the information.
REQUEST NO. 26: In the event that the Company is unable to renegotiate its contract
with the current vendor and a HVAC contractor must be used to remove devices, how much does
the Company estimate it will incur should a qualified HVAC company remove the load control
devices in place of the existing contractor? What are the costs associated with the Company
managing the customer service and database maintenance?
REQUEST NO. 27: What was the last date in which an A/C Cool Credit load control
device was removed, repaired or installed at a customer location in 2012? How many devices
were removed, repaired or replaced in December 2012?
REQUEST NO. 28: What was the final Company cost of upgrading AMI compatible
A/C Cool Credit switches?
REQUEST NO. 29: Did the Company alter how it operated the Mountain Home load
control program for the 2012 program year?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 JANUARY 31, 2013
REQUEST NO. 30: If the A/C Cool Credit program were to be fully eliminated, what
are the costs associated with removing all devices? What other costs would the Company incur?
REQUEST NO. 31: Please provide the dates and times that the A/C Cool Credit
program was dispatched in 2012 and the average demand reduction per unit.
FLEXPEAK
REQUEST NO. 32: Ms. Drake states that IPC has begun conversations with EnerNoc to
reduce the costs of the program for 2013. In what areas does the Company believe it can reduce
the costs associated with FlexPeak Management?
REQUEST NO. 33: What are the costs associated with maintaining the FlexPeak
program for 2013? Please delineate the PCA payments from Rider payments.
DATED at Boise, Idaho, this 3 Ij 'day of January 2013.
___ Donald L.
Deputy Attorney General
Technical Staff: Bryan Lanspery/1-12
Nikki Karpavich/ 13-33
umisc:prodreq/ipcel2.29dhblnk prod req 1
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 6 JANUARY 31, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31ST DAY OF JANUARY 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-12-29, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: [e-mail]
[e-mail]
ERIC L OLSEN
RACINE OLSON NYE BUDGE
& BAILEY
P0 BOX 1391
POCATELLO ID 83204-1391
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
EMAIL: botto(idahoconservation.org
COURTNEY WAITES
TIM TATUM
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: [e-mail]
[e-mail]
ANTHONY YANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
P0 BOX 1731
BOISE ID 83701
E-MAIL: kmi11erc2isnakeriveraI1iance.org
SECRETkY
CERTIFICATE OF SERVICE