20060808NWEC to IPC 1-10.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ID 83701
[phone] x 3
fax: [phone]
beddi e~advocatesw est. org
RECEIVED
2006 AUG -8 AM":
UTIL'8~~O ~~~I~SION
Express Mail:
1320 W. Franklin St.
Boise, ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR
MODIFICATION OF THE LOAD GROWTH
ADJUSTMENT FACTOR WITHIN THE POWER)
COST ADJUSTMENT (PCA) METHODOLOGY
CASE NO.IPC-06-
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION TO IDAHO
POWER COMPANY
Intervenor NW Energy Coalition, by and through counsel, requests that Idaho Power
Company ("Idaho Power" or "Company ) provide the following information.
This Production Request is considered to be continuing, and the 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 infonnation or documents
produced.
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.
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION --
REQUEST NO.1: Please state Idaho Power Company s normalized system
loads for each year starting with year 1995 through 2005.
REQUEST NO.2: Please explain the basis for Witness Greg Said's use of
normalized system load to calculate the current embedded PCA-related cost of serving
load (which he states to be $6.81/MWh), as opposed to using normalized firm system
sales to calculate the same figure.
REQUEST NO.3: Please state Idaho Power Company s current average unit
cost of serving load growth..
REQUEST NO.4: Please state Idaho Power Company s total amount of
spending on demand-side management ("DSM") programs or initiatives (including
payments to the Northwest Energy Efficiency Alliance ("NEEA")) for each year starting
with year 1995 through 2005.
REQUEST NO.5: Please state an estimate 6fIdaho Power Company
expected total amount of spending on DSM programs or initiatives (including payments
to NEEA) in 2006.
REQUEST NO.6: Please state the total amount collected by Idaho Power.
Company under Schedule 91 ("Energy Efficiency Rider ) for each year starting with year
2002 through 2005.
REQUEST NO.7: Please state an estimate ofIdaho Power Company s expected
total collections under the Energy Efficiency Rider in 2006.
REQUEST NO.8: Please state the total amount of estimated energy savings
(expressed as average megawatts) Idaho Power Company and its customers have
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 2
achieved as a result of DSM programs (including any savings achieved as a result of
NEEA programs) for each year starting with year 1995 through 2005.
REQUEST NO.9: Please state the total amount of estimated energy savings
(expressed as average megawatts) Idaho Power Company and its customers are expected
to achieve as a result ofDSMprograms (including any savings achieved as a result Of
NEEA programs) in 2006.
REQUEST NO. 10: Please provide any studies, reports, memoranda, or similar
analyses which estimate the potential energy or peak demand savings which may be
achievable through DSM programs in Idaho Power s service territory.
DATED this 8th day of August, 2006.
--------
William M. Eddie
On behalf ofNW Energy Coalition
. FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this 8TH day of August 2006, true and correct copies of the
foregoing 'FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION were
delivered to the following persons via hand delivery (for PUC and Idaho Power
recipients) and U.S. Mail (for all others):
Jean Jewell (3 copies)
Idaho Public Utilities Commission
472 W.Washington St.
Boise, ID 83702
Barton Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ID 83703
Lawrence Gollomp
Assistant General Counsel
S. Dept. of Energy
1000 Independence Ave., SW
Washington, DC 20585
Dale Swan
Exeter Assoc., Inc.
5565 Sterret Place, Suite 310
Columbia, MD 21044 'K---
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 4