20090317Staff 1-16 to IPC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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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 APPROVAL )
OF AN AGREEMENT TO IMPLEMENT A )
COMMERCIAL DEMAND RESPONSE )PROGRAM. )
)
)
)
CASE NO. IPC-E-09-2
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,
Neil Price, Deputy Attorney General, requests that Idaho Power Company (Company; IPC)
provide the following documents and information as soon as possible, but no later than
TUESDAY, APRIL 7,2009.
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 and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY MARCH 17, 2009
Please provide answers to each question,.:supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
REQUEST NO.1: On page 2 of the Application Idaho Power (Company) says th t
"EnerNOC has been selected by Idaho Power through a competitive RFP process to imple ent
the Program on a turn-key basis." Please identify all RFP paricipants and explain why
EnerNOC was chosen.
REQUEST NO.2: On page 2 of the Application the Company says that "EnerNOC has
successfully implemented similar programs for other utilities throughout the country." Please
list utilties for which EnerNOC has implemented similar programs and describe the success of
those programs.
REQUEST NO.3: On page 3 of the Application the Company says that "A load
reduction plan wil be created for each paricipant with the goal of achieving the desired load
reduction without negatively impacting business operations." Please provide examples of such
load reduction plans. Wil Idaho Power have access to these plans? If not, why not? If so, how
wil Idaho Power be able to utilze this information in future operations?
REQUEST NO.4: On page 3 of the Application the Company says that "EnerNOC wil
reimburse Idaho Power for all costs associated with installng the pulse initiated metering
devices, including the cost of the metering devices themselves." Please explain how often the
Company is estimating these pulse initiated meter installations to occur, what the time period
wil be before EnerNOC reimburses Idaho Power for its installation costs, and what the
estimated costs associated with installng pulse initiated metering devices wil be.
REQUEST NO.5: Does the "pulse initiated metering device" differ from the AMI
metering that the Company is currently installng and the meters that Transmission and Primar
Schedule 9 and Schedule 19 customer curently have? If so, fully explain the differences.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 MARCH 17, 2009
REQUEST NO.6: Please describe the Company's interim and long-term evaluation
process and evaluators for the Commercial Demand Response Program. Based on interim
evaluation results, wil Idaho Power be able to end the program prior to the five-year term?
REQUEST NO.7: The agreement allows "Idaho Power to require demand reduction up
to sixty hours per season with up to twenty events per season." What strategy wil the Company
use to determine the total events called, the timing of each event, and the duration of each event
in order to maximize the Programs benefit?
REQUEST NO.8: How wil Idaho Power "monitor and confirm" EnerNOC's reported
"event" results?
REQUEST NO.9: Please provide lists of the invitees to and attendees at the Februar
25,2008 Industrial Customer program meeting. What was the consensus of the group regarding
the anticipated success of the Program? Please provide copies of Idaho Power's notes taken at
this meeting and subsequent correspondence among Idaho Power employees related to this
meeting.
REQUEST NO. 10: Idaho Power's proposed contract with EnerNOC states that up to
twenty events may be called from June 1 sl to August 31 st of each year. Why did Idaho Power
determine 20 events as the maximum negotiated limit instead of the anticipated 15 events it
expects wil occur? Why did the Company negotiate 60 event hours per season that would result
in event durations of 4 hours?
REQUEST NO. 11: Was a cost/enefit analysis completed comparing EnerNOC
managing this Program vs. the Company? If yes, please provide this analysis in executable
electronic format.
REQUEST NO. 12: Explain how variable energy payments made to EnerNOC affect
cost-effectiveness. In addition, provide detail on how the Company plans to strategically utilze
its number of events and event durations in order to maximize utility net benefit.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 MARCH 17, 2009
REQUEST NO. 13: Please provide an explanation outlining the chances that the third
scenaro ("fewer than eight events per month") in the Company's Application would occur?
REQUEST NO. 14: Please explain the logic behind the '3 in 10' model for determining
baseline energy usage.
REQUEST NO. 15: Please provide the EnerNOC reports and methods used to
determine 5% as an accurate approximation of 'snapback' given actual events with other utilties.
REQUEST NO. 16: Please provide information by customer class on the number of
Primar, Secondary, and Transmission level customers anticipated to participate in the Program.
What are the current total number of customers in each group and each group's estimated peak
demand between the hours of 2 p.m. and 8 p.m. during June, July and August of 2008? What
percentage of load reductions (losses) were assumed for each group? Include an explanation of
how the Company has estimated the loss coefficients associated with each level of service in
determining the Program's cost-effectiveness.
DATED at Boise, Idaho, this , -rP-. day of March 2009.
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Neil Price
Deputy Attorney General
Technical Staff: Matt Elam/l -.w Il.
i:umisc:prodreq/ipce09.2npme prod reql
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 MARCH 17, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF MARCH 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF, IN CASE NO. IPC-E-09-2, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bklineaYidahopower.com
InordstromaYidahopower .com
JOHNRGALE
VICE PRESIDENT, REG. AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgaleaYidahopower.com
CERTIFICATE OF SERVICE