20100407Staff 17-20 to IPC.pdf

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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 83702-5918'
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
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties 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
WEDNESDAY, APRIL 14,2010.
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 supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 APRIL 7, 2010
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. 17: Please explain how the third contract amendment significantly
decreasing the "penalty EnerNOC incurs for failng to commit to a demand reduction that is at
least the contract target minimum" influences the reliability of EnerNOC's: committed demand
reduction, committed contract target minimum and overall program responsiveness.
REQUEST NO. 18: Please explain who is affected by the fourh contract amendment
regarding the addition of a non-solicitation clause intended "to discourage contractors from
soliciting Idaho Power staff for employment."
REQUEST NO. 19: Please explain why it is beneficial to have a non-solicitation
agreement between Idaho Power and EnerNOC, as opposed to having an agreement between
each respective organization and its employees or contractors.
REQUEST NO. 20: In prior Production Request No. 15 regarding the measurement of
'snapback,' the Company says that this "wil be closely monitored on an aggregate and
individual level during the first event season and wil be adjusted accordingly as actual Idaho
Power load data is compiled and analyzed. The snapback effect is also a key piece of the full
program impact evaluation." Using Idaho Power actual load data, please explain the results of
the 'snapback' analyses from the first event season, and describe how it influenced the full
program impact evaluation. In your response, please provide electronic copies of your analyses.
DATED at Boise, Idaho, this ~day of April 2010.V0~
Neil Price
Deputy Attorney General
Technical Staff: Matt Elaml17 - 20
i:umisc:prodreq/ipce09.2npme prod req2
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 APRIL 7, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF APRIL 2010,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-09-02, 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: bkline($idahopower.com
Inordstrom($idahopower .com
GREG SAID
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: gsaid($idahopower.com
PETE PENGILLY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: PPengily($idahopower.com
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SECRETARY
CERTIFICATE OF SERVICE