20200422IPC to Staff 1-7.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

April 22, 2020

VIA ELECTRONIC FILING

Diane Hanian, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-20-14
Fixed Cost Adjustment Rates for June 1, 2020, through May 31, 2021 –
Idaho Power Company’s Response to the First Production Request of the
Commission Staff

Dear Ms. Hanian:

Attached for electronic filing in the above matter is Idaho Power Company’s
Response to the First Production Request of the Commission Staff. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.

If you have any questions about the enclosed documents, please do not hesitate to
contact me.

Very truly yours,

Lisa D. Nordstrom

LDN:kkt
Enclosures
RECEIVED
2020 April 22,PM12:16
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER FOR AUTHORITY TO
IMPLEMENT FIXED COST ADJUSTMENT
RATES FOR ELECTRIC SERVICE FROM
JUNE 1, 2020, THROUGH MAY 31, 2021

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CASE NO. IPC-E-20-14

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power”), and in response to the
First Production Request of the Commission Staff to Idaho Power Company dated April
1, 2020, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
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.
RESPONSE TO REQUEST NO. 1: Please see the attachment provided for this
response.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 2: Please provide the monthly kWh sales forecast for the 2020-
2021 FCA year for the residential and small general service classes.
RESPONSE TO REQUEST NO. 2: Please see the attachment provided for this
response.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
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.
RESPONSE TO REQUEST NO. 3: Idaho Power achieved 203,041 megawatt-
hours (“MWh”) of incremental annual demand-side management (“DSM”) energy
efficiency savings in 2019. 184,934 MWh from Idaho Power’s energy efficiency
programs and an estimated 18,108 MWh in Northwest Energy Efficiency Alliance
(“NEEA”) market transformation savings.
The Idaho residential savings from programs administered by Idaho Power for
2019 is 39,117 MWh and the energy savings specific to Idaho small general service
participants is 889 MWh.
The system-wide market transformation savings from programs and initiatives
administered by NEEA are estimated each year by NEEA prior to issuing final year-end
reports. The Idaho allocation of NEEA net market effect savings across residential and
commercial classes for 2019 is 14,926 MWh, comprised of 7,161 MWh of residential
savings and 7,765 MWh of commercial savings. The net market effect savings
estimates provided by NEEA include small general service savings with the commercial
savings. Idaho Power is unable to distinguish the small general service savings from
the total commercial savings.
The DSM 2019 Annual Report, available on-line via the following link
https://www.idahopower.com/energy-environment/ways-to-save/energy-efficiency-
program-reports, contains jurisdiction-level breakouts of savings in Appendix 4. In
addition, a copy is contained in the attachment provided in response to Staff’s Request
No. 3.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
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.
RESPONSE TO REQUEST NO. 4: Please see the attachment provided for this
response.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
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.
RESPONSE TO REQUEST NO. 5: Please see the two attachments provided for
this response.
Monthly customer counts are calculated by multiplying Number of Customers
(“NCUST”) customer count against a relationship between the number of meters and
active Utility Service Agreements (“USAs”). The monthly NCUST customer count is
provided from the respective month’s NCUST Report, which is a count of customers
receiving service the day cycle 21 billing is generated and includes partial-month
customers. The relationship between the historical number of meters and active USAs
is from the Company’s last general rate case, IPC-E-11-08, test year. Application of the
relationship of meter counts and USAs to NCUST customer counts which include partial
month customers approximates equivalent full month only customers.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 6: Please provide supporting documentation for the billed kWh
sales that was provided in Exhibit No. 3.
RESPONSE TO REQUEST NO. 6: Please see the attachment provided for this
response.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
REQUEST NO. 7: Please provide a schedule showing monthly kWh sold per
month from January 2018 to March 2020.
RESPONSE TO REQUEST NO. 7: Please see the confidential attachment
provided for this response. The confidential attachment will be provided to those parties
who have signed the Protective Agreement in this matter.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
Idaho Power Company.
DATED at Boise, Idaho, this 22nd day of April 2020.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 22nd day of April 2020 I 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
John R. Hammond
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email [e-mail]

________________________________
Kimberly Towell, Executive Assistant