20020419Conservation Groups Nos. 1-5 to IPC.pdf

William M.Eddie (ISB#5800)
LAND AND WATER FUND OF THE ROCKIES 2 9 FU 3P.O.Box 1612
Boise,ID 83701 -
[phone] '"
fax:[phone]
lawfü[e-mail]
Express Mail:
1320 W.Franklin St.
Boise,ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )IDAHO POWER COMPANY FOR AN ENERGY )COST FINANCING ORDER AND AUTHORITY )TO INSTITUTE AN ENERGY COST BOND )CASE NOS.IPC-E-02-02CHARGE)IPC-E-02-03
IN THE MATTER OF THE APPLICATIONOF )FIRST PRODUCTION REQUESTSIDAHOPOWERCOMPANYFORAUTHORITY)OF CONSERVATIONGROUPS
ADJUSTMENT RATE FOR ELECTRIC )SERVICE FROM MAY 16,2002 THORUGH )MAY 15,2003 )
Intervenors Idaho Rivers United,Idaho Rural Council,NW Energy Coalition,and Mary
McGown,by and through counsel,request that Idaho Power Company ("Idaho Power"or
"Company")provide the followinginformation.Given the short time frames involved in these
matters,answers to these production requests are requested on or before April 25,2002.
This Production Request is considered to by continuing,and Idaho Power Company is
requested to provide,by way of supplementary responses,additional documents or information
that it or any person acting on its behalf may later obtain that will augment the information or
documents produced.
CONSERVATIONGROUPS'FIRST PRODUCTION REQUESTS TO IDAHO
POWER COMPANY --1
In answering each request,please provide the name of the person(s)preparing the
answers,along with the title and function such individual holds with the Company and the
witness who can sponsor the answer at the hearing.
Request No.1:On July 31,2001,Idaho Power filed a "Compliance Filing"with the
Idaho Public Utilities Commission ("PUC"or "Commission")in the case of IPC-E-01-13.1 Does
the Compliance Filing accurately reflect the Company's current position with respect to the
implementation of a tariff rider to fund demand-side management ("DSM")programs?If the
Compliance Filing does not continue to reflect the Company's current position with respect to
the implementation of a tariff rider to fund DSM programs,please explain the Company's
changed position.
Request No.2:Has the Company conducted or commissioned any studies or other
analyses to determine the amount of cost-effective DSM resources that are available in its service
territory,as expressed in total potential energy and/or capacity savings?As used in this
question,the term "cost-effective DSM resources"means those DSM resources the cost of which
is lower than that of the electricity supply needed in their absence,based on a comparison of total
resource cost.
Request No.3:Has the Company conducted or commissioned any other study or
analysis to determine the extent of DSM resources that are available in its service territory,as
expressed in total potential energy and/or capacity savings?
'The term "Compliance Filing"as used throughout this Production Request means the Company's
Compliance Filing dated July 31,2001,in Case No.IPC-E-01-13.
CONSERVATION GROUPS'FIRST PRODUCTION REQUESTS TO IDAHO
POWER COMPANY --2
Request No.4:In the Compliance Filing,the Company proposed a DSM tariff rider of
0.5%of revenues,or approximately $2.6 million per year.Please briefly describe the underlying
rationale for this proposed DSM funding level.
Request No.5:In Order No.28894 ("Order"),at page 8,the Commission ordered Idaho
Power to use the BPA Conservation and Renewables Discount credit to fund certain energy
efficiency programs primarily targeted for low income and high energy usage customers.Please
briefly describe the Company's efforts to comply with this aspect of the Order,including by
identifying the Company's expenditures of the BPA Conservation and Renewables Discount
credit and other Company expenditures,and by describing the Company's implementation of
programs as directed in the Order.
Dated:April 18,2002
illiam M.Eddie,Attorney
Land and Water Èund,ef'the Rockies
On behalf of:
Idaho Rivers United
Idaho Rural Council
NW Energy Coalition
Mary McGown
CONSERVATION GROUPS'FIRST PRODUCTION REQUESTS TO IDAHO
POWER COMPANY --3
CERTIFICATE OF SERVICE
I hereby certifythat on this 18th day April 2002,true and correct copies of the
foregoing FIRST PRODUCTION REQUESTS were delivered to the followingpersons
via the method of service noted:
Via Fax and U.S.Mail:
Larry D.Ripley
Idaho Power Company
P.O.Box 70
Boise,ID 83707-0070
fax:[phone]
Via U.S.Mail
Commission Secretary (3 copies)
Idaho Public Utilities Commission
P.O.Box 83720
Boise,ID 83720-0074
Lisa Nordstrom
Deputy AttorneyGeneral
Idaho Public Utilities Commission
P.O.Box 83720
Boise,ID 83720-0074
R.Scott Pasley
Asst.General Counsel
J.R.Simplot Co.
P.O.Box 27
Boise,ID 83702-0074
Peter J.Richardson
Richardson &O'Leary
P.O.Box 1849
Eagle,ID 83616
William M.Eddie
CONSERVATION GROUPS'FIRST PRODUCTION REQUESTS TO IDAHO
POWER COMPANY --4