200412201st Request of Staff to ID Power.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
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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 THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO IMPLEMENT A RESIDENTIAL AIR
CONDITIONER CYCLING PROGRAM.
CASE NO. IPC-04-
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
Donald L. Howell, II, Deputy Attorney General, requests that Idaho Power Company (Idaho
Power; Company) provide the following documents and information as soon as possible, but no
later than TUESDAY, JANUARY 4, 2005.
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.
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.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
DECEMBER 20, 2004
Reference IDAPA 31.01.01.228. For documents provided please include the name and phone
number of the person preparing the document, and the name, location and phone number of the
record holder.
For all responses to the following requests, please provide all workpapers, diskettes
(3.5 in.) and all underlying formulas in Excel (version 5) language.
REQUEST NO.1: Please provide the following:
a. Please provide a copy Summit Blue Consulting, Inc.' s evaluation of the
potential load reduction impacts associated with the operation of the AC Cycling Pilot Program.
b. Please provide copies of all data, assumptions, analyses and instructions that
Idaho Power provided to Summit Blue for the purpose of this evaluation.
c. Please provide a copy of the signed contract between Idaho Power and Summit
Blue.
d. Please describe the process Idaho Power used to select Summit Blue for this
evaluation.
REQUEST NO.2: Please provide the following:
a. Idaho Power s Application states that "The Company reserves the right to
select and reject Program participants at its sole discretion based on criteria the Company
considers necessary to ensure the effective operation of the Program. Selection criteria may
include, but will not be limited to, energy usage, residential location, size of home or other
factors." Please describe tentative selection thresholds for the criteria specifically listed.
b. Please list and describe selection thresholds of "other factors" that the
Company is considering using.
REQUEST NO.3: Please provide detailed cost forecasts for the program for each of the
next five years. These forecasts should list individual cost components in greater detail than is
provided in either the Application or in the company s October 20, 2004, presentation to its
Energy Efficiency Advisory Group.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
DECEMBER 20, 2004
REQUEST NO.4: Please provide a copy of all calculations and assumptions used to
estimate the cost-effectiveness of this program.
, DATED at Boise, Idaho, this ?J:)~y of December 2004.
Donald L. How ll, I
Deputy Attorney eneral
Technical Staff: Lynn Anderson
i:umisc:prodreq/ipceO4.27dhla prod reql
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
DECEMBER 20, 2004
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF DECEMBER 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-04-
BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE FOLLOWING:
MONICA MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
TIM OTHY TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
CERTIFICATE OF SERVICE