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Home My WebLink About20100414IPC to Staff 17-20.pdfLISA D. NORDSTROM Lead Counsel Inordstromcmidahopower.com esIDA~POR~ An IDACORP Company April 14, 2010 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-09-02 EnerNOC Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power's Response to the Second Production Request of the Commission Staff to Idaho Power Company in the above matter. In addition, four (4) disks containing an electronic file in response to Staff's Production Request No. 20 have also been enclosed. Also, enclosed in a separate envelope are an original and three (3) copies of Idaho Power's Confidential Response to the Second Production Request of the Commission Staff to Idaho Power Company. Please note this information should be handled in accordance with the Protective Agreement executed in this matter. Very truly yours,~~¿).rc~ Lisa D. Nordstrom LDN:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 BARTON L. KLINE (ISB No. 1526) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 Facsimile: (208) 388-6936 bkline(Çidahopower.com InordstromCcidahopower.com CP-f"- u"\ ':c \j t~ t .r: Zí1/O APi1 14 Pfi 12: 21 Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MA TIER OF IDAHO POWER COMPANY'S APPLICATION FOR APPROVAL OF AN AGREEMENT TO IMPLEMENT A COMMERCIAL DEMAND RESPONSE PROGRAM. ) ) CASE NO. IPC-E-09-02 ) ) IDAHO POWER COMPANY'S RESPONSE ) TO THE SECOND PRODUCTION ) REQUEST OF THE COMMISSION STAFF ) TO IDAHO POWER COMPANY ) COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the Second Production Request of the Commission Staff to Idaho Power Company dated April 7, 2010, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 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 reliabilty of EnerNOC's: committed demand reduction, committed contract target minimum and overall program responsiveness. RESPONSE TO REQUEST NO. 17: The response to this Request contains confidential information and wil be provided to those parties that have executed the Protective Agreement in place in this matter. The response to this Request was prepared under the direction of Theresa Drake, Manager, Customer Relations & Energy Effciency, Idaho Power Company, in consultation with Bart Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST NO. 18: Please explain who is affected by the fourth contract amendment regarding the addition of a non-solicitation clause intended "to discourage contractors from soliciting Idaho Power staff for employment." RESPONSE TO REQUEST NO. 18: The fourth contract amendment affects only Idaho Power and EnerNOC, Inc. The response to this Request was prepared under the direction of Theresa Drake, Manager, Customer Relations & Energy Efficiency, Idaho Power Company, in consultation with Bart Kline, Lead Counsel, Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 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. RESPONSE TO REQUEST NO. 19: The non-solicitation agreement between Idaho Power and EnerNOC, Inc., is representative of best practices among the parties. It prohibits either party from soliciting, hiring, or contracting with the other part's staff. This protects each party from "poaching" the others staff for the duration of the contract and for one year thereafter. These are very common clauses in commercial transactions such as this one. The response to this Request was prepared under the direction of Theresa Drake, Manager, Customer Relations & Energy Efficiency, Idaho Power Company, in consultation with Bart Kline, Lead Counsel, Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 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. RESPONSE TO REQUEST NO. 20: As a point of clarification, Idaho Power has not completed a full program impact evaluation. As stated on page 14 of Supplement 2: Evaluation of the Demand-Side Management 2009 Annual Report, the Company plans to implement a full evaluation of FlexPeak Management in 2011. Idaho Power has monitored the aggregate "snapback" effects of FlexPeak Management. Since 2009 was a ramp up year, it might not be representative of "snapback" overall, especially during the first few events with very few customers. However, in 2009 the data shows no "snapback" in aggregate. The spreadsheet contained on the enclosed disk shows the average aggregate baseline during each event in 2009, the average aggregate actual load, and the associated percent "snapback" for the two hours following an event. The response to this Request was prepared under the direction of Theresa Drake, Manager, Customer Relations & Energy Efficiency, Idaho Power Company, in consultation with Bart Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 DATED at Boise, Idaho this 14th day of April 2010. è£~¡Q.~LISA D. NORDSTR M Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 14th day of April 2010 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Neil Price Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Neil.price(Çpuc.idaho.gov Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -- Email peter(Çrichardsonandolearv.com greg(Çrichardsonandolearv.com ~ £J.~/døLisa D. Nordstro~~ IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7