20030124First Production Request.pdf

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LISA NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 5733
FtECEIVED
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT A
RESIDENTIAL AIR CONDITIONER
CYCLING PILOT PROGRAM AND TARIFF
SCHEDULE 81.
CASE NO. IPC-02-
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
Lisa Nordstrom, Deputy Attorney General, requests that Idaho Power Company (Idaho Power;
Company) provide the following documents and information on or before FEBRUARY 7
2003.
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. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power 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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 24, 2003
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing if need
be.
Request No.1: Please provide the results of any research Idaho Power has done to
assess how much premature wear and lost efficiency are likely to occur as a result of increased
cycling of air conditioners.
Request No.2: How will this program measure the effect of increased cycling on
efficiency and premature wear on air conditioners?
Request No.3: Please provide the results of any research Idaho Power has done to
assess how frequently typical residential air conditioners currently cycle under various
conditions.
Request No.4: Idaho Power s Application states the goal of the AC Cycling Pilot
Program is to assess its effectiveness in reducing peak load.
a) Will Idaho Power assess the total energy used by each participant, in addition to
demand?
b) Please describe in detail how the effectiveness of each of the three forms of AC
Cycling, as defined in the tariff, will be measured.
c) Will such measurement include the use of a control group whose air conditioners
and/or thermostats are not affected by this program, but whose energy use and demand is
recorded in the same manner (increments) as those whose air conditioners and/or thermostats are
being altered by this program?
d) If measuring a control group s usage is not contemplated, please explain why not.
e) Please list the physical characteristics of landscapes, houses, and households that will
be criteria for customer participation.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 24, 2003
Request No.5: Has Idaho Power assessed the effect that poor air conditioner design,
installation and maintenance have on peak demand? Such factors include, but may not be
limited to, oversized AC units, improper charging of the AC unit, lack of cleaning, leaking or
improperly sized, imbalanced or otherwise poorly installed ducts, and inefficient housing
envelopes.
a) If so, please provide the results of such assessments.
b) If not, please explain why Idaho Power believes controlling AC units and thermostats
is potentially more cost-effective than programs to help correct other air conditioning
inefficiencies?
Request No.6: Given that temperature and humidity sometimes are significantly
different between urban and rural locations, please explain why the Company is proposing to
limit this trial to customers who live within the city limits of Boise and Meridian.
Request No.7: Please provide a breakdown of the estimated $820 000 cost ofthe AC
Cycling program, including, but not limited to: costs of meters, thermostats, installation labor
transportation, other hardware and software, labor to control air conditioners and thermostats
data analysis and program evaluation.
Request No.8: The tariff says that customers who volunteer to participate in the pilot
will be able to opt out one day each month by notifying the Company prior to 4 p.m. the day
before that customer wants to opt out.
a) How will the Company handle disputes if a customer claims to have notified the
Company, but the Company has no record of such notification?
b) How will the Company handle a situation that is deemed to be an emergency that was
not foreseen by a customer prior to 4 p.m. the day before?
Request No.9: Will the old thermostats of participating customers be left with those
customers when Idaho Power s programmable thermostat is installed?
FIRST PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 24, 2003
a) Ifnot, when a customer decides to terminate participation in the program and returns
the new thermostat to the Company according to the terms of the tariff, will the Company then
return the old thermostat to that customer?
b) Will the Company reinstall the old thermostat at no charge?
Dated at Boise, Idaho, this ,;1 day of January 2003.
Technical Staff: Lynn Anderson
Dave Schunke
i:umisc/prodreq/ipceO2,13Indesla 151 prod.req
FIRST PRODUCTION REQUEST
TO IDAHO POWER
JANUARY 24, 2003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JANUARY 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-02-
BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MONICA MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
PETER P PENGILL Y
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
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SECRETARY
CERTIFICATE OF SERVICE