20191216IPC to Sierra Club 2-34.pdf

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RECEIVED
Cl! 0EC l6 Ail 9: 32
. lllt-' I r',:lr,{lsslcil
December 16, 2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re.Case No. IPC-E-18-16
Study of Fixed Costs of Providing Electric Service to Customers
ldaho Power Company's Response to the Second Production Request ofthe
ldaho Sierra Club
Dear Ms. Hanian
Enclosed for filing are an original and three (3) copies of ldaho Power Company's
Response to the Second Production Request of the ldaho Sierra Club. Also enclosed is
one copy of a disk containing information being produced in response to the request.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
L2-t-A(^W*"^-
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NOROSTROM
Lead Counsel
[e-mail]
LISA D. NORDSTROM (lSB No. 573s)
ldaho Power Company
1221 West ldaho Street (83702)
P.O, Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
RECEIVED
,019 OEC l5 All 9: 32
., i J IJLIU'il ; r-t tlOi,lMlSSlON
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY TO
STUDY FIXED COSTS OF PROVIDING
ELECTRIC SERVICE TO CUSTOMERS
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)
)
)
)
)
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CASE NO. rPC-E-18-16
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the ldaho Siena Club to ldaho Power
Company dated November 27,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE IDAHO SIERRA CLUB - 1
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REOUEST OF
THE IDAHO SIERRA CLUB
REQUEST NO. 2: Reference Appendix K, Schedule 1 of IPC-E-18-16 FIXED
COST REPORT dated September 2019. References in subsequent REQUESTS to
Figures, Appendices etc. are from this same report. Both a table and a bar graph are
used to show Percentage of Residential Customer Average Monthly lmpacfBase Case
to 5:1 TOU (p 83). ln the bar graph, the percentage of "All customers" impacted by a bill
increase of $0-10 appears to be about 48%, while in the table (4th and 5th rows -
collectively greater than $0; 3rd column - less than $10), the percentage of customers
totals about 32%. This appears to be a discrepancy in the data. Please explain the
discrepancy, or explain why there is not one.
RESPONSE TO REQUEST NO. 2: After the fili ng was made on September 30,
2019, it was discovered that Figure 2'l in the report (pages 35-36) and Appendix K to
the report (page 83), was incorrectly referencing a prior version of the studied rate
design. ldaho Power submitted replacement pages with the corrected information in
both final and legislative formats on December 10, 2019.
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 2
REQUEST NO. 3: Reference Figure 9. For each of the eight customer classes,
(Residential, Residential On-Site, Small General, Small General On-Site, Large
General, Large General P/T, lndustrial, and lrrigation) please provide the dollar amounts
for both the Cost and Scenario 1 entries in the reference figure.
RESPONSE TO REQUEST NO. 3: Please see the table below for the dollar
amounts for the eight customer classes under the Cost and Scenario 1 entries in Figure
9.
Cost Scenario I
Residential $439,s04,1s3 54t3,242,394
Residential On-Site 51,434,22o s 1,238,390
Small General 514,622,961 s14,089,698
Small General On-Site S3s,3s3 S30,914
Large General s208,3ss,620 5797 ,23L,s80
Large General P/T 53L,847 ,440 s30,670,641
lndustrial 5123,524,1,49 572O,267,7 88
lrrigation 5Ls4,284,967 S 198,340,123
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE IDAHO SIERRA CLUB - 3
I
REQUEST NO. 4: Reference Figure 10. For each of the eight customer classes
(Residential, Residential On-Site, Small General, Small General On-Site, Large
General, Large General P/T, lndustrial, and lrrigation), please provide the dollar
amounts for Energy, Demand, and Service Charge components of the Revenue, Cost,
and Scenario 1 entries in the reference figure.
RESPONSE TO REQUEST NO. 4:Please see the attachment provided in
response to this request for the dollar amounts for Energy, Demand, and Service
Charge components of the Revenue, Cost, and Scenario 1 entries for the eight
customer classes in Figure 1 0,
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.4
REQUEST NO. 5: Reference Figure 11. For each of the eight customer classes,
(Residential, Residential On-Site, Small General, Small General On-Site, Large
General, Large General P/T, lndustrial, and lrrigation), please provide the dollar
amounts for both the Cost and Scenario 2 entries in the reference figure.
RESPO NSE TO REQUEST NO. 5: Please see the table below for the dollar
amounts for the eight customer classes under the Cost and Scenario 2 entries in Figure
11.
Cost Scenario Z
Residential 5439,504,1s3 s394,072,001
Residential On-5ite 5L,434,22O S 1,3s3,282
Small General 5r4,622,96L s 11,431,s98
Small 6eneral On-5ite 53s,3s3 527 ,136
Large General s208,3ss,620 5222,2L0,379
Large General P/T 537,847,440 $34,O29,O29
lndustrial 5123,s24,t49 5r3s ,244 ,os7
lrrigation 5154,284,967 5r7 7,600,263
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COIVIPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 5
REQUEST NO.6: Reference Figure 12 - for each of the eight customer classes,
(Residential, Residential On-Site, Small General, Small General On-Site, Large
General, Large General P/T, lndustrial, and lrrigation), please provide the dollar
amounts for Energy, Demand and Service Charge components of the Revenue, Cost,
and Scenario 2 entries in the reference figure.
RESPONSE TO REQUEST NO. 6:Please see the attachment provided in
response to this request for the dollar amounts for Energy, Demand, and Service
Charge components of the Revenue, Cost, and Scenario 2 entries for the eight
customer classes in Figure 12.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 6
RESPONSE TO REQUEST NO. 7: Please see the attachment provided in
response to this request for the dollar amounts for Energy, Energy-"Fixed", Demand,
and Service Charge components of the Revenue, Cost, and Scenario 3 entries for the
eight customer classes in Figure 13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COIVIPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 7
REQUEST NO. 7: Reference Figure 13. For each of the eight customer classes
(Residential, Residential On-Site, Small General, Small General On-Site, Large
General, Large General P/T, lndustrial, and lrrigation), please provide the dollar
amounts for Energy, Energy-'Fixed", Demand, and Service Charge components of the
Revenue, Cost, and Scenario 3 entries in the reference figure,
REQUEST NO. 8: Reference Figure 15. For both of the customer classes,
Schedule 1 and Schedule 7, please provide the dollar amounts for Energy, Demand,
and Service Charge components of the Cost of Service and Three-Part, Tiered Rate
entries in the reference figure.
RESPONSE TO REQUEST NO. 8: Please see the table below for the Cost of
Service dollar amounts for Energy, Demand, and Service Charge components for
Schedule 1 and Schedule 7 within Figure 15.
Schedule 1 Schedule 7
E ne rgy s149,109,ss 1 S3,988,628
Demand s200,87s,782 54,397,623
service charge s89, s 18,819 56,236,709
The table below includes the Three-Part, Tiered Rate dollar amounts for Energy,
Demand, and Service Charge components for Schedule 1 and Schedule 7 within Figure
15.
Schedule 1 Schedule 7
Energy 5248,333,067 S6,137,308
Demand 5L07,6s2,266 Sz,zz8,t88
Service Charge s89,s 18,819 56,2s7,464
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.8
REQUEST NO. 9: Reference Figure 18. For both of the customer classes,
Schedule 1 and Schedule 7, please provide the dollar amounts for Energy, Demand,
and Service Charge components of the Cost of Service and TOU (Cost Based) entries
in the reference figure.
RESPONSE TO REQUEST NO. 9: Please see the table below for the Cost of
Service dollar amounts for Energy, Demand, and Service Charge components for
Schedule 1 and Schedule 7 within Figure 18.
Schedule 1 Schedule 7
Energy 5149, r.09,551 s3,988,628
oemand 52OO,87s,7 82 54,397,623
Service Charge s89,s18,819 56,236,7o9
The table below includes the Time-of-Use ("TOU") (Cost Based) dollar amounts
for Energy, Demand, and Service Charge components for Schedule 1 and Schedule 7
within Figure 18.
Schedule 1 Schedule 7
Energy 5?97 ,242,4s3 57 ,1s9,322
Demand 5s2,742,880 5r,206,774
Service Charge s89,s18,8r.9 56,257,464
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 9
REQUEST NO. 10: Reference Figure 20. For both of the customer classes,
Schedule 1 and Schedule 7, please provide the dollar amounts for Energy, Demand,
and Service Charge components of the Cost of Service and TOU (5:1) in the reference
figure.
RESPONSE TO REQUEST NO. 10: Please see the table below for the Cost of
Service dollar amounts for Energy, Demand, and Service Charge components for
Schedule 1 and Schedule 7 within Figure 20.
Schedule 1 Schedu le 7
Energy S 149,109,ss1 s3,988,628
Demand 5200,87s,7 82 54,397,623
Service Charge s 89,518,8 r.9 56,236,709
The table below includes the TOU (5:1) dollar amounts for Energy, Demand, and
Service Charge components for Schedule 1 and Schedule 7 within Figure 20.
Schedule 1 Schedule 7
Energy 5349,98s,334 S8,36s,496
Demand so So
Service Charge s89,s18,819 56,2s7,464
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 1O
REQUEST NO. 11: Reference Figure 23. For both of the customer classes,
Schedule 6 and Schedule 8, please provide the dollar amounts for Revenue Deficit,
Demand, Energy (Net Metering), Service Charge, and Additional Net Hourly Revenue
components of the Cost of Service and Net Hourly entries in the reference figure.
RESPONSE TO REQUEST NO. 11 : Please see the table below for the Cost of
Schedule 6 Schedule 8
Energy (Net Metering)s456,339 S8,170
Demand 5737 ,074 578,4s7
Service Charge s240,866 5g,tza
Additional Net Hourly Revenue So so
Revenue Deficit $o So
The table below includes the dollar amounts for Energy (Net Metering), Demand,
Service Charge, Additional Net Hourly Revenue, and the Revenue Deficit components
for Schedule 6 and Schedule I within Figure 23.
Schedule 6 Schedule 8
Energy (Net Metering)5917,s39 S1s,514
So So
Service Charge 56s,747 S2,o6o
Additional Net Hourly Revenue s328,36s S9,so2
Revenue Deficit $(122,s69)s(8,177)
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB. 11
Service dollar amounts for Energy (Net Metering), Demand, Service Charge, Additional
Net Hourly Revenue, and the Revenue Deficit components for Schedule 6 and
Schedule 8 within Figure 23.
Demand
REQUEST NO. 12: Reference Figure 29. For the lrrigation customer class
please provide the dollar amounts for Energy, Demand, and Service Charge
components of the Cost of Service and BLC entries in the reference figure.
RESPONSE TO REQUEST NO. 12: Please see the table below for the Cost of
Service and Basic Load Capacity ('BLC') dollar amounts for Energy, Demand and
Service Charge components for Schedule 24 within Figure 29.
Cost of Service BLC
Energy 56r,946,127 s80,601,801
Demand s86,s89,217 567 ,6s8,1O7
5ervice Charge 5s,7 49,623 S6,o2s,os9
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE IDAHO SIERRA CLUB - 12
UEST N 1 : Reference Appendix E Scenario 1 - Modification 1. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General P/T, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 1 - Modification 1 enhies in the
reference bar graph.
RESPONSE TO REQUEST NO. 13:Please see the attachment provided in
response to this request for the dollar amounts for the eight customer classes. The
attachment includes each of the four modifications for Scenario 1 in Appendix E, and
Scenario 2 in Appendix F.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - ,I3
REQUEST NO. 14: Reference Appendix E Scenario 1 - Modification 2. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General P/T, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 1 - Modification 2 entries in the
reference bar graph.
RESPONSE TO REQUEST NO. 14: Please see the attachment provided in
Response to Request No. 13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB. ,I4
REQUEST NO. 15: Reference Appendix E Scenario 1 - Modification 3. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General P/T, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 1 - Modification 3 entries in the
reference bar graph.
RESPON RE EST NO. 15: Please see the attachment provided in
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE IDAHO SIERRA CLUB. 15
Response to Request No. 13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
REQUEST NO. 16: Reference Appendix E Scenario 1 - Modification 4. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General Pff, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 1 - Modification 4 entries in the
reference bar graph.
RESPONSE TO REQUEST NO. 16:Please see the attachment provided in
Response to Request No. 13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 16
REQUEST NO. 17: Reference Appendix F Scenario 2 - Modification 1. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General P/T, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 2 - Modification 1 entries in the
reference bar graph.
RESPONS RE UEST NO. 17: Please see the attachment provided in
Response to Request No. 13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 17
REQUEST NO. '18: Reference Appendix F Scenario 2 - Modification 2. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General P/T, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 2 - Modification 2 entries in the
reference bar graph.
RESPONSE TO REQUEST NO. 18: Please see the attachment provided in
Response to Request No. '13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 18
REQUEST NO. 19: Reference Appendix F Scenario 2 - Modification 3. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General P/T, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 2 - Modification 3 entries in the
reference bar graph.
RESPONSE TO REQUEST NO. 19:Please see the attachment provided in
Response to Request No. 13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 19
REQUEST NO. 20: Reference Appendix F Scenario 2 - Modification 4. For each
of the eight customer classes (Residential, Residential On-Site, Small General, Small
General On-Site, Large General, Large General P/T, lndustrial, and lrrigation), please
provide the dollar amounts for the COS and Scenario 2 - Modification 4 entries in the
reference bar graph,
RESPONSE TO REQUEST NO. 20: Please see the attachment provided in
Response to Request No. 13.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 20
REQUEST NO. 21: Reference Appendix G Residential. Please provide the
dollar amounts for each of the cost categories, Energy, Energy "Fixed", Demand, and
Customer for the Revenue, Cost, Scenario 1, Scenario 2 and Scenario 3 entries in the
reference bar graph.
RESPONSE TO REQUEST NO. 21: Please see the table below for dollar
amounts for each of the cost categories for the Residential customer class in Appendix
G
Revenue Cost Scenario 1 Scenario 2 Scenario 3
Demand So 5200,87s,7 82 5168,697,770 s149,645,s10 5200,875,782
EnerBy 5432,7s7,28L $ 149,109,ss1 S 1s7,010,684 5792,2OO,7 sO 578,34s,936
Customer s26,082,114 s89,s18,819 587,s33,939 552,22s,74L s89,s18,819
Energy "Fixed"So So So So 570,763,67s
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.21
REQUEST NO. 22: Reference Appendix G Residential On-site Generation.
Please provide the dollar amounts for each of the cost categories, Energy, Energy
"Fixed", Demand, and Customer for the Revenue, Cost, Scenario 1, Scenario 2 and
Scenario 3 entries in the reference bar graph.
RESPONSE TO REQUEST NO. 22: Please see the table below for dollar
amounts for each of the cost categories for the Residential On-Site Generation
customer class in Appendix G.
Revenue Cost Scenario 1 Scenario 2 Scenario 3
Demand $o 5737,O74 Ss2o,s 14 $622,987 5737 ,OL4
E nergy S9 r.7,s39 s4s 6,339 5487 ,27 4 s606,634 522L,288
Customer 56s,747 S240,866 5230,601 5723,66L s240,866
Energy "Fixed"So so 5o so 5 23s,052
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.22
REQUEST NO. 23: Reference Appendix G Small General Service. Please
provide the dollar amounts for each of the cost categories, Energy, Energy "Fixed",
Demand, and Customer for the Revenue, Cost, Scenario 1, Scenario 2 and Scenario 3
entries in the reference bar graph.
RESPONSE TO REQUEST NO. 23: Please see the table below for dollar
amounts for each of the cost categories for the Small General Service customer class in
Appendix G.
Revenue Cost Scenario 1 Scenario 2 Scenario 3
Demand So 54,397,623 53,718,734 52,845,357 54,397,623
Energy 54,22O,93O s4,86s,895 52,707 ,847
Customer S 1,692,s99 56,236,709 S6,1s0,034 53,720,34s 56,236,7o9
Energy "Fixed"So so So so S1,880,781
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.23
I
I Srs,sos,o:s / Sa,saa,oza I
REQUEST NO. 24: Reference Appendix G Small General Service On-Site
Generation. Please provide the dollar amounts for each of the cost categories, Energy,
Energy "Fixed'', Demand, and Customer for the Revenue, Cost, Scenario 1, Scenario 2,
and Scenario 3 entries in the reference bar graph.
RESPONSE TO REQUEST NO. 24: Please see the table below for dollar
amounts for each of the cost categories for the Small General Service On-Site
Generation customer class in Appendix G.
Revenue Cost Scenario 1 Scenario 2 Scenario 3
$o S18,4s7 573,s27 S 11,9s0 578,4s7
E nergy S 1s,614 58,170 S8,944
'to,67
4 53,791
Customer 52,060 5a,tza S8,443 s4,s12 58,726
Energy "Fixed"So 5o So So s4,379
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 24
oemand
REQUEST NO. 25: Reference Appendix G Large General Service - Secondary
Please provide the dollar amounts for each of the cost categories, Energy, Energy
"Fixed", Demand, and Customer for the Revenue, Cost, Scenario 1, Scenario 2, and
Scenario 3 entries in the reference bar graph.
RESPONSE TO REQUEST NO. 25: Please see the table below for dollar
amounts for each of the cost categories for the Large General Service - Secondary
customer class in Appendix G.
Revenue Cost Scenario 1 Scenario 2 Scenario 3
Demand S36,920,663 9101,ss2,068 585,537,717 s101,552,068
Energy s179,408,460 596,s10,s44 5101,603,170 s 130,161,3s0 ss1,030,680
Customer 56,527,393 s10,293,008 s10,096,693 57,s74,093 S10,293,008
Energy "Fixed"So So so 5o 54s,479,86s
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.25
584,474,876
REQUEST NO. 26: Reference Appendix G Large General Service - Primary
and Transmission. Please provide the dollar amounts for each of the cost categories,
Energy, Energy "Fixed", Demand, and Customer for the Revenue, Cost, Scenario '1 ,
Scenario 2, and Scenario 3 entries in the reference bar graph.
RESPONSE TO REQUEST NO. 26: Please see the table below for dollar
amounts for each of the cost categories for the Large General Service - Primary and
Transmission customer class in Appendix G.
Revenue Cost Scenario 1 Scenario 2 Scenario 3
Demand s8,340,764 s 16,118,992 S 13,883,374 s 13,008,718 s16,118,992
Energy s21,041,913 s 14,873,900 s 1s,938,437 s20,169,808 57,778,322
Customer $767,729 s8s4,s49 $848,830 $8so,so3 S8s4,s49
Energy "Fixed"so So 5o 5o s7,1ss,s78
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 26
REQUEST NO. 27: For Appendix G Large Power Service. Please provide the
dollar amounts for each of the cost categories, Energy, Energy "Fixed", Demand, and
Customer for the Revenue, Cost, Scenario 1, Scenario 2, and Scenario 3 entries in the
reference bar graph.
RESPONSE TO REQUEST NO. 27: Please see the table below for dollar
amounts for each of the cost categories for the Large Power Service customer class in
Appendix G.
Revenue Cost Scenario I Scenario Z Scenario 3
Demand s28,01s,187 557,763,974 s49,ss0,092 54s,680,864 ss7,763,974
Energy 586,s47,64s 56s,100,699 570,os6,777 s88,896,729 s33,s00,702
5392,4s7 5659,477 56s4,92s 5666,464 56s9,477
Energy "Fixed"So 5o So 5o 531,s99,997
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE IDAHO SIERRA CLUB - 27
Customer
REQUEST NO. 28: For Appendix G lrrigation. Please provide the dollar
amounts for each of the cost categories, Energy, Energy "Fixed", Demand, and
Customer for the Revenue, Cost, Scenario 1, Scenario 2, and Scenario 3 entries in the
reference bar graph.
RESPONSE TO REQUEST NO. 28: Please see the table below for dollar
amounts for each of the cost categories for the lrrigation customer class rn Appendix G
Revenue Scenario 1 Scenario 2 Scenario 3
Demand s27,869,485 s86,s89,217 s 119,862,911 582,96t,733 s86,s89,217
E nergy s 103,236,852 567,946,t27 572,299,43t 584,42s,484 s31,3s0,034
Customer $2,776,O47 5s,749,623 56,777,787 54,2t3,046 5s,749,623
Energy "Fixed"So $o 5o $o s30,s96,093
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 28
Cost
REQUEST NO. 29: Reference Appendix H Histogram of Occurrences of Hours
90% of Peak. Please provide the month, day, year, and load value and for all hours and
formulas used to calculate the number of occurrences displayed in this histogram.
RESPONSE TO REQUEST NO. 29: Please see the attachment provided in
response to this request. The Histogram of Occurrences of Hours 90 percent of Peak
charts that are included in Appendix H are shown on the "SYrFreq" worksheet on the
attachment.
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.29
REQUEST NO. 30: Reference Figure 16. Please provide peak monthly demand
for the total Residential customer class for each month of the 2014 through 2019 period
for which a rolling 12-month average demand is displayed in Figure 16
RESPONSE TO REQUEST NO. 30: Please see the attachment provided in
response to this request for the load research statistical sample results for the ldaho
Residential customer class peaks for each month from 2014 through 2018. The
information in the attachment represents the class peak in kilowatts and removes
participants in demand response programs for estimation. This data differs from the
data portrayed in Figure 16 as it represents the Residential class total. Data in this
fashion is only current through calendar year 2018.
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.30
REQUEST NO. 31: Reference Appendix D - Class cost of service study results
Please provide the information supplied in Appendix D calculated using the cost of
service with the Scenario 1 modification 3 included.
RESPON RE UEST N 1 : Please see the attachment provided in
response to this request for the class coslof-service study results in Appendix D
calculated using Scenario 1 modification 3.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE IDAHO SIERRA CLUB - 31
REQUEST NO. 32:Reference Appendix M - Schedules 9P Base Case
compared to Full COS. Please provide the information supplied in Appendix M
calculated using the cost of service with the Scenario 1 modification 3 included.
RESPONSE TO REQUEST NO. 32: The requested analysis has not been
prepared by ldaho Power. However, ldaho Power has provided the Scenario 1
modification 3 cost-of-service input file as Attachment 1, and the Schedule 9P rate
development and bill impact workpapers as Attachment 2 to this request.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 32
REQUEST NO.33: For Appendix M - Schedules 19P Base Case compared to
Full COS, Please provide the information supplied in Appendix M calculated using the
cost of service with the Scenario 1 modification 3 included.
RESPONSE TO REQUEST NO. 33: The requested analysis has not been
prepared by ldaho Power. However, ldaho Power has provided the Scenario 1
modification 3 coslof-service input file as Attachment 1, and the Schedule 19P rate
development and bill impact workpapers as Attachment 2 to this request.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB.33
REQUEST NO. 34: Reference Appendix M - Schedules 24 Base Case
compared to Basic Load Charge. Please provide the information supplied in Appendix
M calculated using the cost of service with the Scenario 1 modification 3 included.
RESPONSE TO REQUEST NO. 34: The requested analysis has not been
prepared by ldaho Power. However, ldaho Power has provided the Scenario 1
modification 3 coslof-service input file as Attachment 1, and the Schedule 24 @te
development and bill impact workpapers as Attachment 2 to this request.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
DATED at Boise, ldaho, this 16th day of December 2019.
L4.t--,
LISA , NORDSTR
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 34
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of December 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A(83714)
Boise, ldaho 83720-007 4
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW 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
NW Energy Coalition
F. Diego Rivas
NW Energy Coalition
1101 8th Avenue
Helena, Montana 59601
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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X FTP SiteX Email edwa rd. iewell@ puc. idaho qov
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tavlor. pestell@arkoosh. com
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X FTP SiteX Email d ieqo@nwenerqv. orq
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 35
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio44107
Vote Solar
Briana Kobor
Vote Solar
358 South 700 East, Suite 8206
Salt Lake City, Utah 84102
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 5371 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
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x Email aluna@earth iustice-oro
[e-mail]
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Email aoermaine@ci tvofboise.orq
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X Email orestoncarte (Oo ivensourslev. comI
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 36
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Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC
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
141 1 East Mission Avenue, MSC 27
P.O Box3727
Spokane, Washi ngton 99220-37 27
Patrick D. Ehrbar
Avista Corporation
'1411 East Mission Avenue, MSC 27
P.O. Box3727
Spokane, Washin gton 99220-37 27
PacifiCorp d/b/a Rocky Mountain Power
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Ted Weston
Rocky Mountain Power
'1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
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X Email kelsey@kelseyiaen u nez.com
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FTP Site
Email [e-mail]
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X
X
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 37
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m ichael. o. [e-mail]
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ioe. [e-mail]
lndustrial Customerc of ldaho 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
lndividual
Russell Schiermeier
29393 Davis Road
Bruneau, ldaho 83604
Ki rly Towe cutive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE IDAHO SIERRA CLUB - 38
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