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Home My WebLink About20071213IPC to ICIP 12.pdfeslDA~POR~ An IDACORP Company BARTON L. KLINE Senior Attorney December 13, 2007 Jean D. Jewell, Secretary Idaho Public Utiliies Commission 472 West Washington Street P. O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-07-8 General Rate Case Filing Dear Ms. Jewell: Please find enclosed an original and two (2) copies of Idaho Power's Response to the Fifth Production Request of the Industrial Customers of Idaho Power in the above- referenced matter. Please be advised that the attachment to this request is confidentiaL. i would appreciate it if you would return a stamped copy of this transmittal letter in the enclosed self-addressed, stamped envelope. Very truly yours,(l~ Barton L. Kline BLK:sh Enclosure P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 BARTON L. KLINE ISB #1526 LISA D. NORDSTROM ISB #5733 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 FAX Telephone: (208) 388-6936 201n DEC' 3 Pl'Î 4: 44 Attorney for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE TO ELECTRIC CUSTOMERS IN THE STATE OF IDAHO ) ) CASE NO. IPC-E-07-8 ) ) RESPONSE OF IDAHO POWER TO ) THE FIFTH PRODUCTION REQUEST ) OF THE INDUSTRIAL CUSTOMERS ) OF IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company") and, in response to the Fifth Production Request of the Industrial Customers of Idaho Power to Idaho Power Company dated December 3, 2007, herewith submits the following information: RESPONSE OF IDAHO POWER TO THE FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, Page 1 REQUEST FOR PRODUCTION NO. 12: Please describe in detail the efforts Idaho Power has made with respect to connecting customer owned emergency generators to its electric distribution system. Such description should include copies of all correspondence with customers regarding the program as well as a list of companies participating in the program and a list of companies who were approached about the program. RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Idaho Power objects to this request for production on the grounds that the request was made long after the cutoff date for additional discovery. The cutoff date was agreed to by all of the parties, including the ICIP, and was memorialized in the Scheduling Order issued by the Commission on August 8,2007. Without waiving the objection, Idaho Power is willng, in a spirit of cooperation, to provide the requested information. To gauge customer interest in the Virtual Peaking Program, Idaho Power's Delivery Service Representative's (DSRs) in spring 2007 contacted those customers whom they knew had existing generation, those who had expressed an interest in adding generation, and those they thought might have generation. After soliciting customer interest utilizing the DSRs, the Company held numerous customer meetings and conference calls in May and June 2007 detailing the potential program. Additionally, in an effort to gain more awareness of the program, the Company asked the Industrial Customers of Idaho Power to forward the names of any customers who might be interested in participating. The Company also described the program during RESPONSE OF IDAHO POWER TO THE FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, Page 2 customer meetings held in June to explain the recently filed general rate case and energy efficiency opportunities. In addition to gauging customer interest in the program, the Company performed an initial feasibility analysis, identifying the various costs involved in the interconnection of back-up generators as well as operations and maintenance costs. Both initial generator installations and existing retrofits were considered. Because of the investment size and the potential complexity of the interconnection of some generators, the Company determined it was necessary to do an in-depth analysis of the interconnection costs, targeting generators of different sizes, ages, and locations in order to refine its initial analysis. The Company contracted with Power Engineers to conduct the in-depth interconnection cost analysis. Five Idaho Power customers committed to taking part in this study and allowed Idaho Power and Power Engineers personnel on site to inspect their equipment or site plans for future generators. The on-site interconnection analyses were performed in September 2007. Upon receipt of the interconnection cost data from Power Engineers, the Company updated its financial analysis. Results from this updated analysis indicate there is enough potential benefit associated with the program to continue pursuing its investigation. Idaho Power is now undertaking the next phase of the project in which air quality and permitting issues with respect to diesel generators wil be investigated. The Company has had initial discussions with the Department of Environmental Quality to better understand the permitting process and requirements. Currently, Idaho Power is RESPONSE OF IDAHO POWER TO THE FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, Page 3 gathering information on diesel generator emissions to better assess the potential permitting costs and air qualiy issues. Idaho Power has talked to fort-five customers about the potential for a "virtual peaket' program. Of those customers, twelve expressed an interest to have more in- depth talks, with five committing to the on-site interconnection cost analysis. Attached is a confidential list of the customers the Company talked with regarding the Virtual Peaker Program. Idaho Power takes its obligation to protect the privacy of its customers seriously and appreciates the parties' efforts to also protect the privacy of our customers by ensuring that the attached information is securely maintained in accordance with the Protective Agreement. The only correspondence sent regarding the Virtual Peaker Program was a copy of the report that was filed with the Idaho Public Utilities Commission on June 1, 2007; all other communication with customers has been verbaL. This report was sent to one customer at their request. The response to this request was prepared by Maggie Brilz, Pricing Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney and/or Lisa D. Nordstrom, Attorney Ii, Idaho Power Company. ~ DATED at Boise, Idaho, this l~ day of December, 2007. w~ BARTON L. KLINE Attorney for Idaho Power Company LISA D. NORDSTROM Attorney for Idaho Power Company RESPONSE OF IDAHO POWER TO THE FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, Page 4 CERTIFICATE OF SERVICE ~ I HEREBY CERTIFY that on this ~ day of December, 2007, I served a true and correct copy of the within and foregoing document upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Weldon Stutzman Deputy Attorney General Idaho Public Utilties Commission 472 W. Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Donovan Walker Deputy Attorney General Idaho Public Utilties Commission 472 W. Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson, Esq. Richardson & O'Leary 515 N. 2yth Street P.O. Box 7218 Boise, Idaho 83702 Don Reading Ben Johnson Associates 6070 Hill Road Boise, Idaho 83702 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen Racine, Olson, Nye, Budge & Bailey P.O. Box 1391 201 E. Center Pocatello, Idaho 83204 -2Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Weldon. stutzman Ci puc.idaho.gov -2Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Donovan.walkerCipuc.idaho.gov Hand Delivered -LU.S.Mail _ Overnight Mail FAX X Email peterCirichardsonandolearv.com Hand Delivered -LU.S.Mail _ Overnight Mail FAX -X Email dreadingCimindspring.com Hand Delivered -LU.S.Mail _ Overnight Mail FAX X Email eloCiracinelaw.net RESPONSE OF IDAHO POWER TO THE FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, Page 5 Anthony Yankel 29814 Lake Road Bay Village, OH 444140 Kroger Co. I Fred Meyer and Smiths Michael L. Kurtz Kurt J. Boehm Boehm, Kurtz & Lowry 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 The Kroger Co. Attn: Corporate Energy Manager (G09) 1014 Vine Street Cincinnati, Ohio 45202 Micron Technology Conley Ward Michael C. Creamer Givens Pursley 601 W. Bannock Street P.O. Box 2720 Boise, Idaho 83701 Dennis E. Peseau, Ph.D. Utilty Resources, Inc. 1500 Libert Street SE, Suite 250 Salem, OR 97302 Department of Energy Lot Cooke Arthur Perry Bruder Office of the Attorney General United States Department of Energy 1000 Independence Ave., SW Washington, DC 20585 Routing Symbol GC-76 Hand Delivered -LU.S.Mail _ Overnight Mail FAX -X Email tonyCiyankel.net Hand Delivered -LU.S.Mail _ Overnight Mail FAX -X Email mkurtzCibkllawfirm.com kboehm Ci bkllawfirm .com Hand Delivered -LU.S.Mail _ Overnight Mail FAX Email Hand Delivered -LU.S. Mail _ Overnight Mail FAX X Email cewCigivenspursley.com mcc Ci givenspursley.com Hand Delivered -LU.S.Mail _ Overnight Mail FAX -- Email dpeseauCiexcite.com Hand Delivered U.S. Mail -2 Overnight Mail FAX -- Email lot.cookeCi hq.doe.gov arthur.bruderCi hq.doe.gov RESPONSE OF IDAHO POWER TO THE FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, Page 6 Dennis Goins Potomac Management Group 5801 Westchester Street P.O. Box 30225 Alexandria, VA 22310-8225 Hand Delivered -LU.S.Mail _ Overnight Mail FAX -- Email DGoinsPMGCicox.net Dale Swan Exeter Associates 5565 Sterrett Place, Suite 310 Columbia, MD 20904 Hand Delivered -1 U.S. Mail _ Overnight Mail FAX -1 Email dswanCiexeterassociates.com aansari Ci exeterassociates.com (JL Barton L. Kline RESPONSE OF IDAHO POWER TO THE FIFTH PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER, Page 7