20140502IPC to Staff 1-15.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counse!
[e-mail]
May 2,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-05
2014-2015 Power Cost Adjustment - ldaho Power Company's Response to
the First Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff to ldaho Power Company.
Also, enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to Staffs production requests. Please handle the
confidentia! information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
X;0f|uu*
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnord strom@ idahopower. com
Attorney for ldaho Power Company
r--' ;,. !(]r- t . -' i.-l
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE APPLTCATTON )
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
COST ADJUSTMENT ('PCA") P,q15g
FOR ELECTRIC SERVICE FROM JUNE 1,
2014, THROUGH MAY 31,2015, AND TO
UPDATE BASE RATES tN COMPLIANCE )
WITH ORDER NO. 33OOO.
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated April 25, 2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
CASE NO. |PC-E-14-05
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
REQUEST NO. 1: Please provide the monthly ldaho jurisdictional base sales in
megawatt hours (MWh at customer meter) which makes up the annual sales amount
used to determine ldaho base rates for the PCA deferra! period (April 1, 2013 through
March 30,2014).
RESPONSE TO REQUEST NO. 1: PIease see the attached Excel file
containing monthly megawatt-hour ('MWh") sales for the June 1,2012, through May 31,
2013, forecast year used to calculate base rates in Case No. IPC-E-12-14 ("Langley
Gulch Case"). Base rates established in the Langley Gulch Case were effective
throughout the entire April 2013 through March 2014 deferra! period.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please provide the same monthly base sales (MWh at
customer meter) referenced in Request No. 1, but for the ldaho Power system.
RESPONSE TO REQUEST NO. 2: Please see the attached Excel file to the
Company's Response to Staffs Request No. 1.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: Please provide the monthly ldaho jurisdictiona! load at
generation used to calculate the Load Change Adjustment Rate (denominator of LCAR)
for the PCA deferral period.
RESPONSE TO REQUEST NO. 3: Please see the attached Excelfile containing
ldaho jurisdictional loads at the generation level from the Company's last general rate
case, Case No. IPC-E-11-08 (2011 Rate Case"). This load denominatorwas used in
the Langley Gulch Case to determine the cunent Load Change Adjustment Rate
('LCAR") of $17.64/MWh that remained in effect throughout the April 2013 through
March 2014 defenal period.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
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. lf there are differences between these loads and the
loads shown on line 11 of Company Exhibit No. 5, please quantify 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.
RESPONSE TO REQUEST NO. 4: Please see the attached Excel file which
contains the system loads for Case No. IPC-E-13-20 used to determine the base NPSE
included in the Company's filing, and the system loads from the Company's 2011 Rate
Case, shown on line 11 of Exhibit No. 5 to the Direct Testimony of Scott Wright in this
case. The differences between the two system loads are attributed to two different
forecast periods. The ldaho jurisdictional loads referenced on Staffs Request No. 3 are
also from the 2011 Rate Case.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 5: Please provide the monthly ldaho 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.
RESPONSE TO REQUEST NO. 5: ldaho Power did not calculate an ldaho-
specific allocation of the generation-level load forecast utilized in Case No. IPC-E-13-
20.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
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. lf there are differences between these loads and
the loads shown on Iine 10 of Company Exhibit No. 5, please quantify and explain the
difference. Also, please explain in detail what the Company means by "Actual Firm
Load-Adjusted" as shown on line 10 of Company Exhibit No. 5 and quantify what is
meant by "adjusted."
RESPONSE TO REQUEST NO. 6: Please see the confidential Excel file
provided on the confidential CD. "Actual Firm Load-Adjusted" refers to loads that have
been adjusted by line losses, financial losses, and interchanges. The loads shown on
line 10 of Exhibit 5 were the actualfirm loads that drove the actual NPSE included in the
Company's filing.
The attachment provided in response to this request is confidential and will be
provided on the confidentia! CD to those parties that have executed the Protective
Agreement.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO. 7: Please provide the monthly ldaho allocation of the loads in
the above request. Also, please describe how the figures are measured or derived and
include al! calculations in a spreadsheet with formulas intact.
RESPONSE TO REQUEST NO. 7: ldaho Power did not catculate an Idaho
allocation of the loads provided in the Company's Response to Staffs Request No. 6.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. S
REQUEST NO. 8: Please provide the actua! monthly sales (MWh's measured at
customer meter) for the system and for the ldaho 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 a!! calculations in a spreadsheet with formulas intact.
RESPONSE TO REQUEST NO. 8: Per the Company's discussion with Staff on
April 29, 2014, the attached Exce! file contains actual billing month sales for the ldaho
jurisdiction and total system for the April 2013 through March 2014 PCA deferral period.
MWh sales included in this attachment are identical to the ldaho jurisdictional sales
listed on line 5 of Exhibit No. 5 to the Direct Testimony of Scott Wright in this case, with
the exception of the months of April, May, June, and July. Apri! and May do not reflect
actual ldaho jurisdictional billed sales due to the methodology change, effective June 1,
2013, directed by the Commission in Order No. 32821. ln that Order, the Commission
directed the Company to apply the PCA forecast rate to actual ldaho jurisdictional
energy sales, modifying the Company's then-current methodology of utilizing weather
normalized sales for this purpose. Because the change became effective June 1,2013,
April and May reflect normalized ldaho jurisdictiona! sales per the Company's prior
methodology. To appropriately account for the transition to actual billing month sales
with a June 1,2013, effective date, sales listed on line 5 of Exhibit No. 5 for the months
of June and July reflect only the portion of the total billed sales that was applicable to
the June 2013 through May 2014 forecast rate.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
The actual monthly sales included in the attached Excel
Company's actual billed sales within each month as recorded in
Customer Relationship and Billing System.
file
the
reflect the
Company's
The response to this Request is sponsored by Tim Tatum, Sr. Manager of Cost
of Service, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O
REQUEST NO. 9: Did the Company include Qualifying 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 defenal period in the
Company's filing? lf so, please provide documentation showing that the Company
included these costs and payments in the Load Change Adjustment.
RESPONSE TO REQUEST NO. 9: Only the energy-related portion of Qualifying
Facility ("QF") costs was included in the LCAR numerator, while Demand Response
('DR') incentive payments were entirely excluded. As detailed on page 6 of the
settlement stipulation approved by Order No.32426 in the Company's 2011 Rate Case,
in regard to the LCAR calculation: "the Signing Parties agree[d] to use ldaho Poweds
filed class cost-of-service study methodology to determine the generation-related ldaho
jurisdictional revenue requirement that has been classified as energy-related." Because
the Company's filed cost-of-service study classified DR incentive payments as 100
percent demand-related, these costs were not included in the energy-related numerator
of the LCAR calculation. A portion of QF costs, however, were included in the
numerator of the LCAR, as ldaho Power's filed cost-of-service methodology apportioned
QF costs between the energy-related and demand-related classifications according to
the Company's ldaho jurisdictional load factor. This methodology resulted in
approximately 54 percent of test year QF costs being classified as energy-related.
Attachments 1 and 2 provide supporting documentation for the methodology
detailed above. Attachment 1 contains page 66 of Exhibit No. 31 to the Direct
Testimony of Matthew T. Larkin filed in the 2011 Rate Case. This page demonstrates
the classification of QF costs and DR incentive payments according to the Company's
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. 11
filed cost-of-service methodology that served as the basis for the LCAR calculation. As
detailed on lines 405 through 412 of Attachment 1, purchased power expenses
(including QF costs) were classified as demand-related and energy-related according to
the "PP-KWH" allocation factor, which reflects the Company's Idaho jurisdictional load
factor of approximately 54 percent. As detailed on line 407, DR incentive payments
were classified as 100 percent demand-related. Attachment 2 contains page 1 of Mr.
Larkin's Exhibit No. 39 filed in the 2011 Rate Case, demonstrating the expenses
included in the numerator of the LCAR calculation. As detailed in Attachment 2, only
the energy-related portion of the generation function revenue requirement was included
in the numerator of the LCAR.
It should be noted that the LCAR established in the 2011 Rate Case was
approved at $18.16/MWh, while the LCAR in effect during the April 2013 through March
2014 deferral period was the $17.64/MWh rate established in the Company's Langley
Gulch Case. Although the LCAR changed in the Langley Gulch Case, this was solely
due to the incremental change in net power supply expenses resulting from the addition
of the Langley Gulch plant, which did not impact the level of QF costs included in the
LCAR calculation.
The response to this Request is sponsored by Tim Tatum, Sr. Manager of Cost
of Service, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST NO. 10: Did the Company include any sulfur dioxide (SO2) sales or
Renewable Energy Credits in base rates over the deferral period? lf 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? lf so, please provide documentation showing that the Company
included these costs in the Load Change Adjustment.
RESPONSE TO REQUEST NO. 10: No. However, the benefits associated with
sulfur dioxide sales and renewable energy credits are included as a customer benefit on
the power cost adjustment defenal expense report, which is described in the Direct
Testimony of Scott Wright on page 10, line 20.
The response to this Request is sponsored by Scott Wright, Regulatory Analyst,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
REQUEST NO. 11: Please provide the workpapers used to derive the
$8,290,603 in forecasted ldaho jurisdictional demand response payments through
March 2015.
RESPONSE TO REQUEST NO. 11: Please see the confidential Excel file
provided on the confidential CD which details projected ldaho jurisdictional demand
response payments from April 1, 2014, through March 31, 2015, by program. This
forecast was compiled based on the participant enrollment as of April 7, 2014, for the
summer 2014 season. The estimated $8,290,603 assumes that demand response
incentives will include only fixed incentive payments for three demand response events
for each program throughout the year based on projected peak hour capacity and
deficits.
The attachment provided in response to this request is confidential and will be
provided on the confidential CD to those parties that have executed the Protective
Agreement.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
REQUEST NO. 12: Please provide the monthly total of actual ldaho
jurisdictional demand response payments made in the 2013 through 2014 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.
RESPONSE TO REQUEST NO. 12: The confidential Excel file provided on the
confidentia! CD contains ldaho jurisdictional demand response payments by month and
program for the 2013-2014 PCA deferral year. Total payments made were $4,197,214.
Of the total payments made $2,497,589 were for load reduction and $1,699,625 were
considered "continuity payments".
The attachment provided in response to this request is confidential and will be
provided on the confidential CD to those parties that have executed the Protective
Agreement.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
REQUEST NO. 13: Of the ldaho jurisdictional demand response payments
made in the 2013 through 2014 PCA year related to Ioad reduction, please provide the
amount of load curtailment contracted by week and/or month.
RESPONSE TO REQUEST NO. 13: The amount of generation-level load
curtailment made available through the FlexPeak Management program, or the
"Effective Monthly Capacity", during June, July, and August of 2013 was 37.44
megawatts ("MW"), 40.44 MW and 38.71 MW, respectively.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST NO. 14: Please provide the monthly demand-side management
(DSM) rider revenue and DSM-related expense forecasts through May 2015 that result
in $20 million surplus cited on page 26 of Mr. Tatum's testimony. Please provide DSM-
related expenses by class and program.
RESPONSE TO REQUEST NO. 14: The confidential Excel file provided on the
confidential CD shows the forecasted ldaho Rider revenues and expenses for April 1,
2014, through May 31 ,2015.
The attachment provided in response to this request is confidential and will be
provided on the confidential CD to those parties that have executed the Protective
Agreement.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
REQUEST NO. 15: Please provide the forecasted energy savings for ldaho
Powe/s energy efficiency portfolio in 2014 and 2015. Please provide these savings by
customer class and program.
RESPONSE TO REQUEST NO. 15: The table below includes the 2014 energy
savings targets by program in MWh.
Prooram
Residential
ENERGY STAR@ Homes Northwest
Home lmprovement
Energy House Calls
Rebate Advantage
Home Products
Weatherization Assistance fo r Qua I ified Customers
Weatherization Solutions for Eligible Customers
Energy Efficient Lighting
See Ya Later Refrigerator
Heating & Cooling Efficiency
Commercial/l nd ustrial
Custom Efficiency
Building Efficiency
Easy Upgrades
lrrioation
I rrigation Efficiency Rewards
A!! Program Total
2014
Prooram
Taroets
(MWh)
72
499
641
149
109
641
174
14,016
846
1,542
55,450
10,536
22,180
11.645
118,500
The Company does not develop an estimate of energy savings at the program
level for more than a year in advance. As an alternative, the table below provides the
2015 incremental non-cumulative forecasted energy savings in MWh from ldaho
Power's 2013 lntegrated Resource Plan ("lRP") by customer sector. The 2013 IRP
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
energy efficiency forecast is listed by sector only because the forecast was based on
the ldaho Power Energy Efficiency Potential Study, February 15,2013, by ENERNOC
Utility Solutions Consulting, which does not estimate potential energy savings at the
program level.
2015
Forecasted
Savinos
(2013IRP)
MWh
Residential 44,658
Commercial/lndustrial 71,657
lrrigation 8.112Tota! 124,427
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 2nd day of May 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
Attomey for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of May 2014 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Karl T. Klein
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
U.S. Mail
X Email [e-mail]
X Email [e-mail]
X Email [e-mail]
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1 391
Overnight Mail
FAX
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
_FAXX Email [e-mail]
ldaho lrrigation Pumpers Association _Hand Delivered
Eric L. Olsen U.S. Mail
RACINE, OLSON, NYE, BUDGE, & _Overnight Mail
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 4140
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21