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HomeMy WebLinkAbout20130425IPC to IIPA 17-28.pdfR"joMDAHO POWER® - An IDACORP Company LISA D. NORDSTROM Lead Counsel Inordstromcidahopower.com . . •1 ITIES CO M1SS April 25, 2013 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-12-29 Temporary Suspension of Demand Response Programs - Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s Second Data Request 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 Idaho Irrigation Pumpers Association, Inc.'s Second Data Request to Idaho Power Company. Also enclosed are four (4) copies of a non-confidential disk containing data responsive to the Idaho Irrigation Pumpers Association, Inc.'s Request. 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 Inordstrom(idahopower.com jhiItonidahopower.com ThT? APP 25 PM 4: 46 - ...,. Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO TEMPORARILY SUSPEND ITS NC COOL CREDIT AND IRRIGATION PEAK REWARDS DEMAND RESPONSE PROGRAMS CASE NO. IPC-E-12-29 IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Second Data Request to Idaho Power Company dated April 4, 2013, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -1 REQUEST NO. 17: With respect to the Response to Irrigator Request 1, was the sales data provide [sic], actual or normalized, and was it calendar or billing data? If available, please provide this same data as actual, calendar data. RESPONSE TO REQUEST NO. 17: The retail sales data provided in the Company's response to IIPA's Data Request No. I represents actual billing month sales. Please see the attached Excel file containing actual calendar month sales from June 2005 through December 2012. Calendar-converted sales are not available for the time period January through May 2005. Wholesale sales are recorded on a calendar month basis only. Therefore, the wholesale sales data provided in the Company's response to IIPA's Data Request No. I reflects actual calendar month data. The response to this Request was prepared under the direction of Tami White, Manager of Rate Design, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -2 REQUEST NO. 18: Please supply the same data as in the Response to Irrigation Request 2, for the Idaho jurisdiction. RESPONSE TO REQUEST NO. 18: Historical billing determinants for the Company's Idaho jurisdiction are provided in electronic format for 2008-2012 in the attached Excel file. Please note that these detailed monthly billing determinants reflect weather normalized usage and are prepared for the specific purpose of deriving normalized test year retail revenues. Revenue associated with each category of billing determinant reflects annualized historical rates in effect as of December 31 of each historical year applied to normalized billing determinants. The response to this Request was prepared by Matthew Larkin, Regulatory Analyst II, Idaho Power Company in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -3 REQUEST NO. 19: With respect to the Response to Irrigator Request 3 (Attachments 5, 6, and 7), are the kWh figures normalized or actual and are they billing or calendar data? RESPONSE TO REQUEST NO. 19: As indicated in the Attachments' worksheet headers, the kilowatt-hour ("kWh") figures provided in the Company's confidential Attachments 5, 6, and 7 to IIPA's Data Request No. 3.w reflect actual values. The data was calendar month data. The response to this Request was prepared by Mary Arnold, Load Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -4 REQUEST NO. 20: With respect to the Response to Irrigator Request 3, (Attachment 3), please explain how to identify each of what appears to be five different gas fired units in Column "P". Please explain how to separate the data for each unit, or provide another copy of this response with these individual units identified. RESPONSE TO REQUEST NO. 20: Please see column 3B of the attachments provided in the Company's response to IIPA's Data Request No. 28[sic], which reflects the breakout of the individual gas plants. Currently, there are four plants active at any given time. These plants include Bennett Mountain, Danskin, Langley Gulch (after April 2012), and Salmon Diesel. Please see the information provided in the Company's response to IIPA's Data Request No. 28[sic] subsections c and d regarding plant usage. The response to this Request was prepared by Philip DeVol, Resource Planning Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -5 REQUEST NO. 21: With respect to the Response to Irrigator Request 4, what is the reason that 0.75% of the residential customers do not have AMI meters? RESPONSE TO REQUEST NO. 21: Idaho Power's Advanced Metering Information ("AMI") system is a Power Line Communication ("PLC") system that requires specific equipment to be installed within each distribution substation to facilitate automation. Each of these substation PLC installations would require, at a minimum, $100,000 in equipment. Approximately 3,000 non-AMI residential customers are served by 56 distribution substations. Thus, a $100,000 investment would not be cost- effective. Additionally, many non-AMI residential customers' service locations are in remote, low density locations, which can also increase costs. The response to this Request was prepared by Mark Heintzelman, Regional Operations Support Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -6 REQUEST NO. 22: With respect to the Response to Irrigator Request 5, what is the reason that 6.5% of the irrigation customers do not have AM[ meters? Is this 6.5% of the customers generally representative of the irrigation population with respect to size and usage? RESPONSE TO REQUEST NO. 22: The Company's AMI system is a PLC system that requires specific equipment to be installed within each distribution substation to facilitate automation. Each of these substation PLC installations would require, at a minimum, $100,000 in equipment. Approximately 1,000 non-AMI irrigation customers are served by 40 distribution substations. Thus, a $100,000 investment is not cost-effective. Additionally, many non-AMI irrigation customers' service locations are in remote, low density locations, which can also increase costs. No, these customers are not representative of the irrigation population with respect to size and usage. The non-AMI distribution substations that serve these irrigation customers are located primarily in outlying areas and these customers tend to derive their irrigation from ground water wells. As a result, the average size of irrigation service points is larger and would use more kWh than an average Idaho Power irrigation customer. The response to this Request was prepared by Mark Heintzelman, Regional Operations Support Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -7 REQUEST NO. 23: With respect to the Response to Irrigator Request 6, it is stated: "Residential customers billing data is captured via several methods, including AMI as well as...". Please explain how the AMI data is used to capture Residential customer billing data. RESPONSE TO REQUEST NO. 23: AMI meters represent 99.25 percent of Idaho Power's residential customer meters. Both daily register reads and hourly consumption data is recorded from all AMI meters. Residential customers on Schedule 1, "Residential Service," are billed for energy usage calculated by taking the difference in monthly register reads. Residential customers on Schedule 5, "Residential Service Time-of-Day," are billed from hourly consumption data for the monthly billing period separated into the applicable time-of-use periods for the month. The response to this Request was prepared by Mark Heintzelman, Regional Operations Support Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -8 REQUEST NO. 24: With respect to the Response to Irrigator Request 6, it states that the "residential hourly mean load shape [is] derived from the sample and scaled to the customer class." Please provide the load shapes that were derived from the sample. Also please provide the scalar values used. RESPONSE TO REQUEST NO. 24: The load shape derived from the load research sample and the associated scalar values are provided in the attached Excel file. Both the load shape and the scalar values reflect residential hourly loads absent any demand response ("DR") reductions. After the hourly sample data was scaled to the class level utilizing the attached data, the resulting hourly load shape was adjusted by actual hourly DR reductions to calculate the hourly residential load shape provided in the Company's response to IIPA's Data Request No. 6. The response to this Request was prepared by Mary Arnold, Load Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -9 REQUEST NO. 25: With respect to the Response to Irrigator Request 6, please provide for each of the summer monthly peak hours the residential load as derived from the AMI data. RESPONSE TO REQUEST NO. 25: The demand at monthly system peak for 2012 summer months derived from the load research sample for the residential rate class at the meter level can be found in the confidential Excel file provided with the Company's response to IIPA's Data Request No. 3.w, Demands2012Actual, worksheet "SCDkWCus." The hours and demands are listed below, hour ending: 6/28/2012 8:00 PM 7/12/2012 4:00 PM 8/7/2012 6:00 PM 917,080 kilowatts ("kW") 1,036,948 kW 1,168,224 kW The response to this Request was prepared by Mary Arnold, Load Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -10 REQUEST NO. 26: With respect to the Response to Irrigator Request 7, please provide for each of the summer monthly peak hours the irrigation load as derived from the AMI data. RESPONSE TO REQUEST NO. 26: The demand at monthly system peak for 2012 summer months derived from the load research sample for irrigation rate class at the meter level can be found in the confidential Excel file provided with the Company's response to IIPA's Data Request No. 3.w, Demands2012Actual, worksheet "SCDkWCus." The hours and demands are listed below, hour ending: 6/28/2012 8:00 PM 730,421 kW 7/12/2012 4:00 PM 656,180 kW 8/7/2012 6:00 PM 581,699 kW The load research sample used to determine the demand at monthly peak is based on a combination of AMI and MV90 interval data. The response to this Request was prepared by Mary Arnold, Load Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -11 REQUEST NO. 27: With respect to the Response to Irrigator Request 8, please supply for all summer hours the entire residential load (Air conditioning and non-air conditioning) for those customers on the A/C Cool Credit program. It would be preferred that this data come from AMI metering, but it [sic] unavailable, please supply it on the basis of load research data. RESPONSE TO REQUEST NO. 27: The hourly load of residential customers on the A/C Cool Credit program is provided in the attached Excel file. The response to this Request was prepared by Mary Arnold, Load Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -12 REQUEST NO. 28: With respect to the Response to Irrigator Request 9, please answer the following: a.What was the number of total participant meters? b.What was the summer kWh of the customers that did have interval meters, but not AMI meters? C. Please provide the combined interval data for those customers that did not have AMI data, but had interval data. d.What was the combined billing demand for those customers that had AMI metering? e.What was the combined billing demand for those customers that had interval metering? f.What was the combined billing demand for those customers that had neither AMI nor interval metering? g.What was the monthly kWh of the customers that did not have interval meters, nor AMI meters? h.What was the number of customers that had interval data, and how many customers had neither interval nor AM[ data? RESPONSE TO REQUEST NO. 28: a. The total number of irrigation demand response participants is 2,433. There are 2,125 participants with data read via AMI, four which are read via MV90, and 23 read via manual reads from interval recorders. In addition, there are 281 participants which are read via manual reads from meters which do not record intervals. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -13 While preparing the response to this Request, Idaho Power discovered that it used an outdated list of AMI-read participants when responding to IIPA's Data Request No. 9. Therefore, Idaho Power has supplemented its response to IIPA's Data Request No. 9 to include the data for the updated list of 2,125 participant meters, which are identified as currently being read via AMI. As noted before, the combined irrigation hourly load of all customers on the Irrigation Peak Rewards Dispatchable Program is not available because several of the participants are not metered via AMI and several participants do not have meters which capture interval data. Also, the AMI data included in these totals contain both normally read interval values as well as any estimates or un-scaled estimates for intervals that are provided by the Company's Meter Data Management System algorithms. No distinction or special handling of the estimated intervals was conducted. b. The summer kWh of the customers that did have interval meters, but not AMI meters, is 83,558,529 kWh on a billing month basis. C. The combined interval data for those customers that did not have AMI data, but had interval data, is contained in the attached Excel file. These participants are read via MV90 or via a manually probed interval recorder. Summing this hourly data, the total calendar summer consumption for the customers that did have interval meters but no AMI meters is 87,457,101 kWh. d-g. Please see the attached Excel file. h. The number of customers that had interval data was 2,152, which included 2,125 participants read via AMI, four which are read via MV90, and 23 read via manual IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -14 reads from interval recorders. The number of customers which had neither interval nor AMI data is 281. The response to this Request was prepared by Mary Arnold, Load Research Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 15 REQUEST NO. 28fsic1: Regarding Attachment 3 of the Response to IIPA Request 3.a to 3.v_2012, please answer the following: a.On July 26, 2012 there are six gas units listed. Please give the name/designation for each. b.On a day such as July 25, 2012 when there are only four gas units listed, what is the status of the two gas units that are not listed? Do they in any way contribute to the Company's reserves? C. On a day such as July 25, 2012 there are two units listed that have a negative output of 3 MWH. What is the status of these two gas units? Do they in any way contribute to the Company's reserves? d. On a day such as July 25, 2012 there is one unit listed that has a negative output of 118 MWH. What is the status of this unit? Does it in any way contribute to the Company's reserves? RESPONSE TO REQUEST NO. 28fsicJ: Please see the attached updated versions of the Excel files previously provided with the Company's response to IIPA's Data Request No. 3.a to 3.v which identify the individual gas plants. a. Below is a table identifying the gas plants that were included in the data for July 26, 2012. Please note that although six categories of information are provided, the information only relates to four plants: Salmon Diesel, Danskin, Bennett Mountain, and Langley Gulch. Data reflects both generation and local plant usage. Plant Name Date Total MWh Salmon Diesel Generation 07/26/12 5 Danskin Local Plant Usage 07/26/12 (3) Bennett Mountain Generation 07/26/12 1,101 Bennett Mountain Local Plant Usage 07/26/12 (3) Langley Gulch Generation 07/26/12 6,580 Langley Gulch Local Plant Usage 07/26/12 (118) IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -16 Three units were operating on July 26, 2012: Langley Gulch, Bennett Mountain, and Salmon Diesel. See additional information in 28[sic] subsections c and d regarding plant usage. b. The only plant operating on July 25, 2012, was Langley Gulch; other gas plants were not operating and did not contribute to reserves. However, they did show plant usage. Below is a table identifying the data for July 25, 2012. Plant Name Date Total MWh Danskin Local Plant Usage 07/25/12 (3) Bennett Mountain Local Plant Usage 07/25/12 (3) Langley Gulch Generation 07/25/12 5,678 Langley Gulch Local Plant Usage 07/25/12 (115) C. The negative output noted in this Request is local plant use at Danskin and Bennett Mountain. These two plants were not operating on July 25, 2012, and did not contribute to reserves. Please note that local plant use is entered into the hourly record not as actually occurring, but simply to match observed monthly local plant use totals. The assignment of three megawatt-hours ("MWh") of local plant use per day for Danskin and Bennett Mountain results in the July 2012 monthly local plant use total for each plant. d. The Company assumes that IIPA is referring to negative 115 MWh rather than negative 118 MWh in this Request. With that correction, the negative output noted in this Request is local plant use at Langley Gulch. Please note that local plant use for Langley Gulch (similar to Danskin and Bennett Mountain) is entered into the hourly record not as actually occurring, but simply to match observed monthly local plant use. Therefore, the noted plant use may not exactly match the actual local plant use occurring on July 25, 2012. As an operating gas plant on July 25, 2012, Langley Gulch IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -17 can contribute to reserves, depending on the amount of undispatched capacity and the ramp rate. The response to this Request was prepared by Philip DeVol, Resource Planning Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 25 th day of April 2013. LI A D. NORDSTROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -18 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25th day of April 2013 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED 201 East Center P.O. Box 1391 Pocatello, Idaho 83204-1391 Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street Boise, Idaho 83702 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 don. howell(uc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAX X Email eIocracinelaw.net _Hand Delivered U.S. Mail _Overnight Mail FAX X Email tony(ãyankeI.net Hand Delivered U.S. Mail Overnight Mail FAX X Email bottocidahoconservation.orq Hand Delivered U.S. Mail Overnight Mail FAX X Email kmiIIersnakeriveralliance.orp Christa Bearry, Legal Assistant j IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -19