20200401Staff 1-7 to Staff.pdf

FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 1, 2020
JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5470

Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT FIXED COST
ADJUSTMENT (“FCA”) RATES FOR
ELECTRIC SERVICE FROM JUNE 1, 2020,
TRHOUGH MAY 31, 2021
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CASE NO. IPC-E-20-14

FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY

The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond Jr., Deputy Attorney General, request that Idaho Power Company (“Company”)
provide the following documents and information as soon as possible, or by WEDNESDAY,
APRIL 22, 2020.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
RECEIVED
2020 April 1,PM2:09
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 1, 2020
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.

REQUEST NO. 1: Please provide the monthly kilowatt-hour (“kWh”) sales forecast for
the 2019-2020 FCA year for the residential and small general service classes.

REQUEST NO. 2: Please provide the monthly kWh sales forecast for the 2020-2021 FCA
year for the residential and small general service classes.

REQUEST NO.3: Please separate the 2019 incremental DSM energy efficiency savings
cited in Pawel Goralski’s testimony (page 3, line 19 through page 4, line 2) into residential and
small general service components and provide supporting workpapers.

REQUEST NO. 4: For the residential and small general service classes, please provide
actual monthly energy usage from June 1, 2018 through May 31, 2019.

REQUEST NO. 5: Please provide supporting documentation for the customer counts listed
in Exhibit No. 3 and explain how the monthly customer counts were calculated.

REQUEST NO. 6: Please provide supporting documentation for the billed kWh sales that
was provided in Exhibit No. 3.

REQUEST NO. 7: Please provide a schedule showing monthly kWh sold per month from
January 2018 to March 2020.

DATED at Boise, Idaho, this 1st day of April 2020.

_______________________________________
John R. Hammond
Deputy Attorney General
i:umisc:prodreq/ipce20.14jhbejk prod req1
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 1st DAY OF APRIL 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-14, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:

LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]

PAWEL P GORALSKI
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]

/s/ Reyna Quintero __
SECRETARY