20140425Staff 1-15 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 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 AUTHORTTY ) CASE NO. IPC-E-14-05
TO TMPLEMENT POWER COST )
ADJUSTMENT (PCA) RATES FoR ELECTRIC ) rrRsr pRoDUCTToN
SERVICE FROM JUNE 1,2014 THROUGH MAY) REeUEST OF THE
31,2015, AND TO UPDATE BASE RATES IN ) COwTMISSION STAFF TO
COMPLIANCE WITH ORDER NO.33OOO ) 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, MAY 2,2014.1
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 identiff 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 I APRIL 25,2014
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 the monthly Idaho jurisdictional base sales in
megawatt hours (MWh at customer meter) which makes up the annual sales amount used to
determine Idaho base rates for the PCA defenal period (April I , 2013 through March 30, 2014) .
REQUEST NO.2: Please provide the same monthly base sales (MWh at customer
meter) referenced in Request No. 1, but for the Idaho Power system.
REQUEST NO. 3: Please provide the monthly Idaho jurisdictional load at generation
used to calculate the Load Change Adjustment Rate (denominator of LCAR) for the PCA
deferral period.
REQUEST NO. 4: Please provide the monthly base system loads (MWh's) measured at
generation that produces the base Net Power Supply Expense (NPSE) included in the Company's
filing. If there are differences between these loads and the loads shown on line 11 of Company
Exhibit No. 5, please quantiff and explain the difference. Also, please quantify and explain the
difference between these loads and the loads referenced in Request No. 3 other than differences
due to jurisdictional allocation.
REQUEST NO. 5: Please provide the monthly Idaho allocation of the loads (MWh's)
referenced in Request No. 4. Also, please describe how the figures are measured or derived and
include all calculations in a spreadsheet with formulas intact,
REQUEST NO. 6: Please provide the monthly actual system loads (MWh's) measured
at generation that produced the actual NPSE included in the Company's filing. Describe how the
figures are measured or derived and include all calculations in a spreadsheet with formulas
intact. If there are differences between these loads and the loads shown on line l0 of Company
Exhibit No. 5, please quantiff and explain the difference. Also, please explain in detail what the
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY APRIL 25,2014
Company means by "Actual Firm Load-Adjusted" as shown on line 10 of Company Exhibit No.
5 and quantify what is meant by "adjusted."
REQUEST NO. 7: Please provide the monthly Idaho allocation of the loads in the
above request. Also, please describe how the figures are measured or derived and include all
calculations in a spreadsheet with formulas intact.
REQUEST NO. 8: Please provide the actual monthly sales (MWh's measured at
customer meter) for the system and for the Idaho jurisdiction. Amounts should reflect actual
sales in the months that the loads occurred (i.e., billing cycle adjusted). Please describe how the
amounts are measured, describe the method used to adjust for the billing cycle, and include all
calculations in a spreadsheet with formulas intact.
REQUEST NO. 9: Did the Company include Qualiffing Facility costs and Demand
Response incentive payments in the LCAR numerator that the Company used to determine the
Load Change Adjustment for any part of the deferral period in the Company's filing? If so,
please provide documentation showing that the Company included these costs and payments in
the Load Change Adjustment.
REQUEST NO. 10: Did the Company include any sulfur dioxide (SO2) sales or
Renewable Energy Credits in base rates over the deferral period? If so, were any of these
amounts in the base included in the numerator of the LCAR that the Company used to determine
the Load Change Adjustment for any part of the deferral period in the Company's filing? If so,
please provide documentation showing that the Company included these costs in the Load
Change Adjustment.
REQUEST NO. 11: Please provide the workpapers used to derive the $8,290,603 in
forecasted Idaho jurisdictional demand response payments through March 2015.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY APRIL 25,2014
REQUEST NO. 12: Please provide the monthly total of actual Idaho jurisdictional
demand response payments made in the 2013 through2014 PCA year by program. As part of
this response, please state which part of the payments are "continuity payments" and which part
of the payments are related to a load-reduction product.
REQUEST NO. 13: Of the Idaho jurisdictional demand response payments made in the
2013 through2}l4 PCA year related to load reduction, please provide the amount of load
curtailment contracted by week andlor month.
REQUEST NO. 14: Please provide the monthly demand-side management (DSM) rider
revenue and DSM-related expense forecasts through May 2015 that result in $26 million surplus
cited on page26 of Mr. Tatum's testimony. Please provide DSM-related expenses by class and
program.
REQUEST NO. 15: Please provide the forecasted energy savings for Idaho Power's
energy efficiency portfolio in 2014 and 201 5. Please provide these savings by customer class
and program.
DATED at Boise, Idaho, this 2 f y day of April2}l4.
Technical Staff: Mike Louis/l-10
Stacey Donohue/l 1-15
i:umisc:prodreq/ipce l4.5kkmlsd prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
/(J //L
Karl T. Klein
Deputy Attorney General
APzuL 25,2014
I HEREBY CERTIFY THAT I
SERVED THE FOREGOING FIRST
COMMISSION STAFF TO IDAHO
IPC.E-I4.05, BY MAILING A COPY
FOLLOWING:
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
CERTIFICATE OF SERVICE
HAVE THIS 25TH DAY OF APRIL 2014,
PRODUCTION REQUEST OF THE
POWER COMPANY, N CASE NO.
THEREOF, POSTAGE PREPAID, TO THE
TIMOTHY E TATUM
GREG SAID
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
[e-mail]
CERTIFICATE OF SERVICE