20140424ICL 1-14 to IPC.pdf

Benjamin Otto (ISB No. 8292)
710N6,hStreet -.-...:r.1 . -?r!!
Ph: [phone] xt2
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
BEFORT THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLTCATTON OF rDAHO POWER )
coMPANy FOR AUTHORTTY TO ) CASE NO. IPC-E-14-05
IMPLEMENT POWER COST )
ADJUSTMENT ("PCA") RATES FOR ) IDAHO CONSERVATION LEAGUE
ELECTRIC SERVICE FROM JUNE I, )
2}LA,THROUGH MAY 3t,2Ots,AND ) FIRST PRODUCTION REQUEST TO
TO UPDATE BASE RATES IN ) IDAHO POWER
COMPLTANCE WrTH ORDER NO. )33000. )
COMES NOW the Idaho Conservation League, with the following production requests.
Along with the answer to each question, please provide any supporting documents, workpapers,
calculations, or information sources Idaho Power relies upon to support its answer. As required
by IDAPA 31.01.01.228.02, please indicate the witness who can answer question regarding the
response and who will sponsor the response at any hearing. If any responses include Excel
spreadsheets or other electronic files, please provide them with all formulas intact and activated.
As allowed by IDAPA 31.01.01.228.01, if the volume of any response indicates it would be more
feasible to do so ICL agrees to the Company depositing the response in an electronic depository.
This production request is ongoing. Accordingly, we respectfully ask Idaho Power to
provide additional documents and information that may supplement any initial responses.
REQUEST NO 1: Please provide responses to any discovery requests Idaho Power has received
from any other party in this docket.
IPC-E-14-05
ICL 1" production request to IPC
April24,2014
REQUEST NO 2: Page 9 of the Application states the DSM rider balance "is currently surplus
about $12.2 million". Mr. Tatum on page 26,lines 14 through 16, states "the June 1,2014 DSM
rider balance is expected to be a surplus of about $12.2 million." Please provide:
a. Documentation of the DSM rider balance by month during the prior two years.
b. Documentation of Idaho Power's DSM energysavings during the20l3-2014 PCA
year.
c. Documentation of the expected energy savings from DSM programs during the 2013-
2014 PCA year in Idaho Power's 2013 Integrated Resource Plan.
d. Documentation of the cost effective DSM potential during the 2013-2014 PCA year in
the most recent Idaho Power Energy Efficiency Potential Study.
e. Documentation of the expected DSM energy savings during the 2013-2014 PCA year
in the Company's March 2013 Operating Plan.
REQUEST NO 3: Mr. Tatum on page 26,lines 18 through 22, states the "DSM Rider balance is
forecasted to be a surplus of $26 million by May 31,2015". Please provide:
a. All analysis, documentation, and explanation underlyrng this forecast including planned
DSM energy savings and expenses during the20l4-2015 PCA year.
b. Documentation of the expected energy savings from DSM programs during the 2014-
2015 PCA year in Idaho Power's 2013 Integrated Resource Plan.
c. Documentation of the cost effective DSM potential during the 2014-2015 PCA year in the
most recent Idaho Power Energy Efficiency Potential Study.
d. Documentation of the expected DSM energy savings during the2014-2015 PCA year in
the Company's March 2014 Operating Plan.
IPC-E-14-0s
ICL 1" production request to IPC
April24,2014
REQUEST NO 4: Page 9 of the Application and Mr. Tatum on page 26,lines 23 through 25,
proposes to transfer $16 million from the DSM rider balancing account to offset this year's PCA.
Please provide any documentation and analysis used to determine the $16 million amount.
REQUEST NO 5: Mr. Tatum on page 5lines 9 though 15, describes the DSM funds transfer as a
"one-time PCA mitigation measure". Please answer the following:
Does Idaho Power commit to never again proposing to use DSM funds to offset the PCA?
If the answer is yes, please provide any documentation or analysis used to determine the
2014-2015 PCA years is the best one in which to enact this one-time PCA mitigation.
If the answer is no, please explain what the phrase "one-time PCA mitigation measure
means".
REQUEST NO 6: Mr. Tatum on page lT,lines 19 through 23, states "Idaho Power estimates that
the two temporarily suspended programs reduced program incentive expenses by more than
$10.0 million." Please provide any documentation and analysis supporting this estimate.
REQUEST NO 7: Mr. Tatum on page 18,lines 4 through 9, states "Idaho Power estimates that it
incurred additional power supply expenses of less than $10,000 associated with the suspension of
the two programs." Please provide any documentation and analysis supporting this estimate.
REQUEST NO 8: Mr. Tatum on page 14,line 24 through page 15line 21, states the2013-2014
surplus sales forecast was $98.5 million based on a forecast hydro generation of 6.8 million mwh.
Then, Mr. Tatum on page 22,table 3, forecasts 2014-2015 surplus sales to be $126.2 million
based on forecast hydro generation of 6.9 million mwh as stated on page 24,lines 2-3. Please
IPC-E-14-0s
ICL l't production request to IPC
a.
b.
c.
April24,2014
provide any documentation and analysis used to estimate this higher level of surplus sales based
on the same level of hydro generation.
REQUEST NO 9: Mr. Tatum on page 24,lines 2 through 16, describes that the Company's
forecast for hydro generation in 2014-2015 is below the 30-year average annual hydro generation
and concludes: "The lower anticipated hydro generation will contribute to increased coal and gas
production costs and lower surplus sales revenue as compared to normal levels." Please provide
for the previous 5 years the annual hydro generation forecast used in developing the PCA and the
3O-year average annual hydro generation forecast applicable to each ofthe forecasts.
REQUEST NO 10: Mr. Tatum on page 16,lines 1 though 5, states that during the2013-2014 PCA
year "higher customer loads contributed to higher than forecasted power costs and lower surplus
sales". Please provide the following:
a. Documentation or analysis used by the Company to quantifr the impact of customer
loads on surplus sales revenues.
b. Documentation of how the Company's Operating Plan forecasts the effect of planned
energy efficiency acquisitions on customer loads, power costs, and surplus sales.
REQUEST NO 11: Mr. Tatum states on page 28 lines 1 through 4 the "Company believes that
customers would prefer a rate credit in this year's PCA rather than Idaho Power holding on to
funds that are not expected to be used in the next few years." Please provide any documentation
supporting this belief about customer preferences relied on by Idaho Power.
rPC-E-14-0s
ICL 1" production request to IPC
Apil}4,2014
REQUEST NO 12: Mr. Tatum states on page 26lines 16 through 18 "DSM Rider-funded
expenses are forecasted to be approximately $20 million per year on average over the next two
years." Please provide:
a. All documentation and analysis used to forecast annual DSM Rider-funded expenses
over the next two years.
b. All documentation and analysis used to forecast annual DSM-Rider funded energy
savings over the next two years.
REQUEST NO 13: Mr. Tatum states on page 23 lines 22-24 "regardless of the DSM Rider's
balance, the Company is committed to energy efficiency initiatives and pursuing all cost-effective
energF efficienry." Please provide all documentation of the Company's plans to pursue all cost
effective energy efEciency over the next two years.
REQUEST NO 14: Mr. Tatum describes on page 31,lines 6 through 11, the reaction of the
Energy EfficiencyAdvisory Group to the Company proposal for a one-time transfer of DSM
Rider funds. Please provide the following:
a. Documentation that Mr. Tatum was present on the conference call.
b. Documentation of the specific "clarifring questions asked, some concerns expressed, as
well as comments of support."
c. If the above documentation does not exist please explain fully Mr. Tatum's basis for this
portion of his testimony.
DATED the 24th day of Aprilz0l4.
Benjamin J. Otto
Idaho Conservation League
IPC-E-r4-05
ICL 1" production request to IPC
April24,2014
CERTIFICATE OF SERVICE
I hereby certifr that on this 24th day of April20l4I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE,
TO IDAHO POWER to the following via the method of service noted:
First Class Mail:
Jean Iewell
Commission Secretary (Original and three copies provided)
Idaho Public Utilities Commission
427W. Washington St.
Boise, ID 83702-5983
Electronic Mail Only:
Idaho Power
Lisa D. Nordstrom
Timothy E. Tatum
GregoryW. Said
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
ttatum@idahopower. com
[e-mail]
dockets@idahopower. com
rcP
Peter I. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N.27th Street
Boise, ID 83702
peter@richardsonandoleary. com
greg@richardsonandoleary. com
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
[e-mail]
IPC-E-14-0s
ICL 1" production request to IPC
April24,2014