20200825Staff 1-6 to Staff.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-O3t4
IDAHO BAR NO. 10446
IN TIIE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO MODIFY SCHEDULE 84'S
METERING REQUIREMENT AND TO
GRANDFATHER EXISTING CUSTOMERS
WITH TWO METERS
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Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.2O.26
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,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by TUESDAY,
SEPTEMBER 15, 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
3t.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 AUGUST 25,2020
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: On pages 5 and 6 of its Application, the Company explains its proposed
grandfathering policy. Please explain why the proposed changes to the grandfathering policy are
not included in the Company's proposed changes to Schedule 84.
REQUEST NO.2: Under the Company's proposal, who would pay the costs of converting
a dual metered system to a single metered system in the event that a grandfathered customer wishes
to remain on Schedule 84 after their grandfathered status has terminated? How does the Company
propose modifying its tariff to reflect this policy?
REQUEST NO. 3: For the conversion from a two-meter system to a single-meter system
capable of instantaneously netting the customer's production and consumption, please provide
estimates of:
a. The average conversion costs for customers who would currently be eligible for
grandfathering under the Company's proposal; and
b. The costs of the five most expensive conversions for customers who would be
eligible for grandfathering under the Company's proposal.
REQUEST NO.4: Do any existing customers pay a facilities charge for Schedule 84
facilities used to interconnect the customer's production system to the Company? Please explain.
REQUEST NO.5: What is the expected life of the production meters currently used in
two-meter systems?
REQUEST NO. 6: Please provide the proposed accounting treatment of the meters and
equipment being replaced and/or retired once a Schedule 84 customer is moved to a single meter
system.
FIRST PRODUCTION REQUEST
TO IDAHO POWER AUGUST 25,20202
DATED at Boise,Idaho, this 2 r+lduyof August 2O2A.
frr.-Edward Jewell
Deputy Attorney General
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FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 AUGUST 25,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF AUGUST 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-26, By E-MAILING A COpy
THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE D 83702
E-MAIL: botto@idahoconservation
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL: kelsey @kelseyjaenunez.com
ANTHONY YANKEL
I27OO LAKE AVE
UNITE 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
CONNIE G ASCHENBRENNER
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
ttatum @ idahopower.com
IDAHO SIERRA CLUB
LISA YOUNG
MIKE HECKLER
503 W FRANKLIN ST
BOISE D 83702
E-MAIL: lisa.young @ sierraclub.org
Michael.p.heckler@ gmail.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
RUSSELL SCHIERMEIER
29393 DAVIS ROAD
BRUNEAU ID 83604
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE