20140404Staff 1-10 to IPC.pdf

KARL T. KLEIN
DEPUTYATTORNEYGENERAL _ ",".-..,,._i, i:.. _:.nr
IDAHO PUBLIC UTILITIES COMMISSION i ': u: i-r-"i
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.5156
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLTC UTILITIES COMMISSION
IN THE MATTER OF rDAHO POWER )
coMPANy'S APPLTCATTON FOR ) CASE NO. IPC-E-14-03
AUTHORITY TO IMPLEMENT FIXED COST )
ADJUSTMENT RATES FOR SERVICE FROM ) rrnsr pRODUCTTON
JUNE 1,2014 THROUGH MAY 31,2015. ) nreUEST OF THE) couMIssION srAFF To
) IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Company; IPC) provide the following documents and information as soon as possible, by
FRIDAY, APRIL 18, 2014.1
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 identifr the name, job title, location and telephone
number of the record holder.
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 APzuL 4,2014
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 provide all executable electronic models used to calculate the
weather-normalized energy for both the Fixed Cost Adjustment (FCA) deferral period and the
forecasted FCA collection period. As part of the response, please include a detailed explanation
of all the modeling variables, and provide the descriptive statistics used to evaluate the predictive
accuracy of each model. If third party economic or demographic projections were utilized,
please provide all the data used for the adjustment and the names of the primary data vendors.
REQUEST NO.2: On page 3 of Zach Harris's testimony, he discusses each component
of the FCA mechanism. Specifically, he describes the following formula: FCA: (CUST X
FCC) - (NORM X FCE). Because the weather-normalization adjustment affects the Company's
estimation of actual fixed cost recovery, please explain how the Company verifies the accuracy
of its weather-normalization model.
REQUEST NO. 3: On page 5 of Zach Harris's testimony, he says: "the Company began
using a prorated customer count based on the number of active meters at the end of each month."
Please explain how the Company defines an account and how it determines whether the account
is considered inactive, and consequently, must be removed from the jurisdictional customer
count. As part of the response, please provide the number of Idaho accounts deemed inactive
over the last five years. Please provide this on a monthly basis.
REQUEST NO.4: Please provide the number of residential and small commercial
customer accounts considered active with no energy usage over the last five years and the
percentage of total accounts the number represents. Please provide this on a monthly basis for
each rate schedule.
REQUEST NO. 5: On page 5 of Zach Harris's testimony, he discusses how the
Company's implementation of its new Customer Relationship and Billing system has caused it to
change how it calculates customer counts. Please explain how the change impacts the accuracy
of the Company's customer count. As part of the response, please also explain how the
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 4,2014
Company calculated the prorated customer count, given that the methodology changed
2013.
REQUEST NO. 6: On page 7 of Zach Harris's testimony, he says: "the difference
between this year-end determination of the FCA balances and the sum of the 12 monthly
reported estimates of the FCA balances required adjustments to arrive at the annual FCA
amount." Please explain each adjustment and its corresponding impact on the deferral balance.
Please provide all applicable workpapers in executable format with this response.
REQUEST NO. 7: On page 8 of Zach Harris's testimony, he says: "As customer growth
increases, fixed costs also increase, impacting the level of authorized fixed cost recovery." Has
the Company completed any recent studies to evaluate how other factors such as weather,
building codes and standards and schedule type effect the fixed cost of serving customers? If so,
please provide a copy of each study to which you refer.
REQUEST NO. 8: How many residential customers participated in Idaho Power's DSM
programs during the FCA defenal year?
REQUEST NO. 9: What level of energy savings was generated by residential customers
who participated in Idaho Power's DSM programs during the FCA defenal year?
REQUEST NO. 10: How many small commercial customers participated in Idaho
Power's DSM programs during the FCA deferral year?
DATED at Boise, Idaho, this 4AOu, of April 2014.
Technical Staff: Matt Elam/ | -7
Stacey Donohue/8-l0
i:umisc:prodreq/ipcel4.3kkmesd prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
T.
APRIL 4,2014
I HEREBY CERTIFY THAT I
SERVED THE FOREGOING FIRST
COMMISSION STAFF TO IDAHO
IPC.E.I4-03, BY MAILING A COPY
FOLLOWING:
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
d ockets (E idahooower. com
CERTIFICATE OF SERVICE
HAVE THIS 4TH DAY OF APRIL 2014,
PRODUCTION REQUEST OF THE
POWER COMPANY, N CASE NO.
THEREOF, POSTAGE PREPAID, TO THE
ZACHARY L HARRIS
GREG SAID
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE