20190807IPC to Staff 3-7.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
[e-mail]
RECEIVED
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August 7,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-19-17
Authority to Modify Schedule 15, Dusk to Dawn Customer Lighting, and
Schedule 41, Street Lighting Service, to Allow for Light Emitting Diode
Technology - ldaho Power Company's Response to the Second 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 Second Production Request of the Commission Staff in the above matter.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Staff's Second Production Request.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:kkt
Enclosures
P.O. 8ox 70 (83707)
1221 W. ldaho 5t.
Boise, lD 83702
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom @ ida h opower. com
RECEIVED
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO MODIFY SCHEDULE 15,
DUSK TO DAWN CUSTOMER LIGHTING,
AND SCHEDULE 41, STREET LIGHTING
SERVICE, TO ALLOW FOR LIGHT
EMITTING DIODE TECHNOLOGY.
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CASE NO. rPC-E-19-17
!DAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ny"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
Company dated July 17 , 2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 3: Please provide workpapers in Excel with formulae intact and
enabled supporting lines 4-9, page 23, of Ms. Patteson's testimony. Please include:
a. the calculation of the current revenue requirement from Schedules 15 and
41 related to the cost components at issue in this case;
b. the current revenue requirements of the business-as-usual case; and
c. the revenue requirement for the LED installation scenarios.
RESPONSE TO REQUEST NO. 3:
a. Please see the Excel file on the non-confidential CD for the calculation of
the estimated current revenues from Schedules 15 and 41 related to the cost
components at issue in this case.
b. Please see the attachment provided with the Company's Response to
Staff's Production Request No. 1 for the computation of the current revenue
requirements of the business-as-usual case. The business-as-usual case is labeled as
the HPS Rev Req.
c. Please see the attachment provided with the Company's Response to
Staff's Production Request No. 1 for the computation of the current revenue
requirements of the light emitting diode ("LED") installation scenario. The LED
installation scenario is labeled as the LED Rev Req.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, and Courtney Waites, Regulatory Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 4: Please provide manufacturer specifications, datasheets, etc.,
for the proposed lighting fixtures
RESPONSE TO REQUEST NO. 4: Please see Attachments 1 through 10 on the
non-confidential CD for the manufacturer specifications for the proposed LED lighting
fixtures. While ldaho Power has not finalized a Request for Proposal or selected a
vendor for the LED lighting fixtures, the attachments are examples of specifications for a
similar product that would be selected.
The response to this Request is sponsored by Kristy Patteson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 5: Please provide documentation and evidence supporting the
reduction in maintenance needed for the LED installation scenario referenced on page 4
of the Application.
RESPONSE TO EST NO. 5:As specified by the manufacturer (see
Attachments to Request No. 4 for the manufacturers specification sheets), the expected
system life for each of the proposed lighting fixtures is 100,000 hours or greater.
Assuming an expected life of 100,000 hours and 4,059 burn hours annually, the
projected life of the specified LED light fixtures is approximately 24.6 years (100,000
hours/4,059 hours per year burn time). By comparison, ldaho Power's most commonly
installed 100W high pressure sodium vapor bulb has an expected life of approximately
20,000 hours or 4.9 years, roughly 20 percent of the expected life of an LED fixture.
Due to the longer expected life of the new LED light fixtures, the same frequency of
routine maintenance would no longer be required.
The response to this Request is sponsored by Kristy Patteson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 6: Please provide the current cost for the lighting inventory
identified on lines 14-19, page 28, of Ms. Patteson's testimony and also the predicted
future cost of needed LED lighting inventory. Please provide evidence and justification
to support your response.
RESPONSE TO REQUEST NO. 6: The current cost for lighting inventory and
the predicted future cost of LED lighting inventory are provided in the confidential
attachment to this response. lt is assumed that the reference was to page 18 of Ms.
Patteson's testimony rather than to page 28. On lines 14-19 of page 18 of Ms.
Patteson's testimony, ldaho Power suggested that it "could reduce the number of
catalog items it stocks in inventory for lighting fixtures." As shown in the confidential
attachment, the proposed change from HID to LED lighting will reduce the number of
catalog items from 59 to 11.
The confidential attachment will be provided to those who have signed the
protective agreement in this matter.
The response to this Request is sponsored by Kristy Patteson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 7: Please explain the necessary steps and associated expense
for removal and disposal of existing lighting from inventory
RESPONSE TO REQUEST NO. 7:If ldaho Power's request to modify
Schedules 15 and 41 to allow for LED technology is approved, ldaho Power will work
with the suppliers and resellers of the existing lighting material to determine if any
unused inventory remaining at the end of the changeout cycle can be returned for
credit. Any material still on hand will be removed from inventory and sent to the
lnvestment Recovery department who will attempt to sell the product on the open
market. lf unable to sell, lnvestment Recovery will recycle what they can of the product
and dispose of the rest. !n its revenue requirement analysis, ldaho Power assumed an
average disposal cost of $3.00 per HPS lamp, which is the Company's current average
disposal cost.
The response to this Request is sponsored by Kristy Patteson, Regulatory
Analyst, ldaho Power Company.
DATED at Boise, ldaho, this 7th day of August 2019.
LISA D. NOR
Attorney for ldaho Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of August 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Gommission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered_U.S. Mail
_Overnight Mail
FAX
X Email [e-mail]
Ki Towell Assistant
o
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF. T