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Home My WebLink About20181212IPC to Staff 1.pdf3Effi*o An IDACORP Company LISA D. NORDSTROM Lead Counsel I nordstrom@ida hopower.com n r- (.:il i\1iil i \l-_ *- ''_ - ; i-,ri l? Pt'i q: 35i:i U; z '- December 12,2018 VIA HAND DELIVERY Diane Hanian, Secretary ldaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re Case No. !PC-E-18-16 Study of Fixed Costs of Providing Electric Service to Customers ldaho Power Company's Response to the First Production Request of the Commission Staff Dear Ms. Hanian Enclosed for filing are an original and three (3) copies of ldaho Power Company's Response to the First Production Request of the Commission Staff. Also enclosed are four (4) copies of a disk containing information being produced in response to Staff's Request No. 1. lf you have any questions about the enclosed documents, please do not hesitate to contact me. Very truly yours, X^l (,,U,r,* 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: (208) 388-5825 Facsimile: (208) 388-6936 lnordstrom@ idahopower. com r.l I in r.: i\ / i: [] ['\[*\./':-l ! dv r rr lffr I /) i.-r ULt, I L Fi'i h: 35 Attorney for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION !N THE MATTER OF THE PETITION OF IDAHO POWER COMPANY TO STUDY FIXED COSTS OF PROVIDING ELECTRIC SERVICE TO CUSTOMERS ) ) ) ) ) ) ) ) CASE NO. |PC-E-18-16 IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in response to the First Production Request of the Commission Staff to ldaho Power Company dated November 21,2018, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 1 REQUEST NO. 1: ln Order No. 34046, the Commission ordered the Company to "undertake a comprehensive customer fixed cost analysis" to include "exploring fixed- cost recovery in basic charges and other rate design options." See Order No. 34046 at 23. Please provide all relevant studies and reports conducted by the Company or on its behalf within the last 3 years. RESPONSE TO REQUEST NO. 1: After receiving final Order No. 34046 issued in Case No. !PC-E-17-13, ldaho Power prepared a preliminary class cost-of-service ('CCOS') study for its ldaho jurisdiction to facilitate the examination of issues raised by the ldaho Public Utilities Commission ("Commission") in its order. This study was developed consistent with the methodology most recently approved by the Commission in Case No. IPC-E-08-10 ('2008 GRC") and filed in Case No. IPC-E-11-08 ("2011 GRC'). Because the ldaho jurisdictional revenue requirement is not an issue in this case, ldaho Power did not prepare a test year with forecasted components per recent rate case methodology. Rather, as described in more detail in this response, the Company utilized its historical ldaho Results of Operations ("ldaho ROO") from 2017 as the basis for the CCOS study. The following paragraphs provide a summary of the process by which the Company developed these initial studies, and outline the overall organization of the Company's response to Staffs Request No. 1. .. 2017 CCOS STUDY To arrive at the CCOS study results, the Company first developed the ldaho ROO based on 2017 actual data, then applied typical rate case adjustments such as normalization for weather and annualization of certain revenues and expenses. A IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 2 detailed description of the process the Company used to develop the 2017 ldaho ROO is included as Attachment 1 - Development of 2017 Results of Operations, which includes the working Excel file as Attachment 1a. The jurisdictional separation study ("JSS") results calculated in Attachment 1a were then used as an input to the CCOS study. After the 2017 ldaho ROO was determined and the JSS results finalized, the Company used a methodology consistent with that approved by the Commission in the 2008 GRC and filed by the Company in the 2011 GRC. The study is a three-step process in which the jurisdictionalized ldaho ROO is (1) categorized by function, (2) classified based on the utility service being provided, and finally, (3) allocated to customer classes. The CCOS process guide, Attachment 2, describes the methodology utilized in the 2008 and 2011 rate cases and highlights changes necessary to incorporate the on-site generation Schedules 6 and 8. The CCOS, workpapers, and input derivation are included and described in the files contained within the folders titled Attachments 2 through 7: . Attachment 2 - Class Cost-of-Service Study . Attachment 3 - Normalized Energy . Attachment 4 - Normalized Demand and Energy Derivation . Attachment 5 - Net Hourly Billing Determinant Derivation . Attachment 6 - Normalized Retail Revenue Derivation . Attachment 7 - Summary of Cost-of-Service Study Results IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 3 II. CONCLUSION The studies ldaho Power has developed and supplied in response to Staff's Production Request No. 1 in this current proceeding, Case No. IPC-E-18-16, are not intended to be presented as final studies; rather, they were developed to facilitate discussion with Commission Staff and parties as consideration is given to the Commission's directive in Order No. 34046 to undertake a comprehensive customer fixed-cost analysis to determine the proper methodology and 'spread' of fixed costs as they relate to the Company's customers. The 2017 ldaho ROO and the preliminary CCOS results provided with this response are the same as provided in ldaho Power's Response to Staff's Request No. 1 in Case No. IPC-E-18-15. The response to this Request is sponsored by Connie Aschenbrenner, Rate Design Manager, ldaho Power Company, and Matt Larkin, Revenue Requirement Senior Manager, ldaho Power Company. DATED at Boise, ldaho, this 1 2th day of December 2018. LI D. NOR Attorney for lda Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 12th day of December 20181 served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Sean Costello Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, ldaho 83720-0074 IdaHydro C. Tom Arkoosh ARKOOSH IAW OFFICES 802 West Bannock Street, Suite LP 103 P.O. Box 2900 Boise, ldaho 83701 ldaho Conservation League and NW Energy Coalition Benjamin J. Otto ldaho Conservation League 710 North 6th Street Boise, ldaho 83702 ldaho lrrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, ldaho 83205 X Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email sean.costello@puc.idaho.qov _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email tom.arkoosh@arkoosh.com erin. cecil@arkoosh. com _Hand DeliveredX U.S. Mail _Overnight Mail FAXX Email botto@idahoconservation.o rg _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email elo@echohawk.com Anthony Yankel 12700 Lake Avenue, Unit 2505 Lakewood, Ohio 44107 Vote Solar Briana Kobor Vote Solar 358 South 700 East, Suite 8206 Salt Lake City, Utah 84102 _Hand DeliveredX U.S. Mail _Overnight Mail_FAXX Email tonv@vankel.net _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email briana@votesolar.orq IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 5 David Bender Earthjustice 3916 Nakoma Road Madison, Wisconsin 537 1 1 Al Luna Nick Thorpe 1625 Massachusetts Avenue, NW, Suite 702 Washington, DC 20036 City of Boise Abigail R. Germaine Deputy City Attorney Boise City Attorney's Office 150 North Capitol Boulevard P.O. Box 500 Boise, ldaho 83701 -0500 ldaho Clean Energy Association Preston N. Carter GIVENS PURSLEY LLP 601 West Bannock Street Boise, ldaho 83702 Sierra Club Kelsey Jae Nunez KELSEY JAE NUNEZLLC 920 North Clover Drive Boise, ldaho 83703 Zack Waterman Michael Heckler ldaho Sierra Club 503 West Franklin Street Boise, ldaho 83702 Avista Corporation David J. Meyer Avista Corporation 1411 East Mission Avenue, MSC 27 P.O. Box 3727 Spokane, Was h i n gto n 99220-37 27 _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email dbender@earthiustice.orc _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email aluna@earthiustice.orq nthorpe@earthj ustice. orq _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email aqermaine@citvofboise.org _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email prestoncarter@qivenspurslev.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email kelsev@kelseyjaenunez.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email zack.waterman@sierraclub.orq michael.p qmail.com _Hand DeliveredX U.S. Mail _Overnight Mail FAXX Email david.meve istacoro.com IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF.6 Patrick D. Ehrbar Avista Corporation 1411 East Mission Avenue, MSC 27 P.O. Box 3727 Spokane, Wash i n gt on 99220 -37 27 _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email patrick.ehrbar@avistacorp.com ioe. m iller@avistacorp. com PacifiCorp d/b/a Rocky Mountain Power Yvonne R. Hogle Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 84116 _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email yvonne.hoqle@pacificorp.com Ted Weston Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email ted.weston@pacificorp.com berly T , Executive Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 7