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Home My WebLink About20100315ICIP 1-10 to IPC.pdfR Ff .ia~~~.A~~~"1~IOMAR 15 PM 1:38 Peter Richardson Tel: 208-938-7901 Fax: 208-938-7904 pete rli r ichardso nan dol eary. com P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702 March 15,2010 Ms. Jean Jewell Commission Secretar Idaho Public Utilities Commission 472 W. Washington Boise,ID 83702 RE: IPC-E-IO-04 Dear Ms. Jewell: We are enclosing an original and three (3) copies ofthe INDUSTRIAL CUSTOMERS OF IDAHO POWER'S FIRST PRODUCTION REQUEST in the above case. An additional copy is enclosed for you to stamp for our records. encl. Peter 1. Richardson ISB # 3195 Gregory M. Adams ISB # 7454 RICHARDSON & O'LEARY PLLC 515 N. 27th Street Boise, Idaho 83702 Telephone: (208) 938-2236 Fax: (208) 938-7904 peter(frichardsonandoleary.com greg(frichardsonandoleary .com RECEl ZOiU MAR' 5 PM i: 38 \()l~~rlC; UTILITIES Attorneys for the Industrial Customers of Idaho Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICA TIONOF IDAHO POWER COMPANY FOR AN ENERGY EFFICIENCY RIDER FUND PARTICIPATION INNW ENERGY ALLIANCE ) CASE NO. IPC-E-IO-04 ) ) FIRST PRODUCTION REQUEST OF ) THE INDUSTRIAL CUSTOMERS OF ) IDAHO POWER ) Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), the Industrial Customers of Idaho Power ("ICIP") hereby requests that Idaho Power Company ("Idaho Power") provide responses to the following with supporting documents, where applicable. This production request is to be considered as continuing, and the 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 responses or documents produced. Please provide one physical copy and one electronic copy, if available, of your answer to Mr. Adams at the address noted above. Page 1 - FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC- E-l 0-04 F or each item, please indicate the name of the person( s) preparing the answers, along with the job title of such person(s) and the witness at hearng who can sponsor the answer. Some of the following requests may include disclosures deemed by Idaho Power to be confidentiaL. Attorneys for the Industrial Customers of Idaho Power are prepared to sign any such agreement to obtain the materials relevant to this proceeding, and expect that executing such a confdentiality agreement will not delay Idaho Power's responses to these Requests for Production. Page 2 - FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER- IPC-E-I0-04 REQUEST FOR PRODUCTION NO.1 How much is Idaho Power curently paying to NEEA on an annual basis? REQUEST FOR PRODUCTION NO.2 How much are Schedule 19 customers in Idaho currently paying into NEEA through Idaho Power's energy effciency rider? Please explain, and provide supporting documentation. REQUEST FOR PRODUCTION NO.3 How much will Schedule 19 customers pay into NEEA through Idaho Power's energy efficiency rider if the Commission grants the requested approval in the Application in this docket? Please explain, and provide supporting documentation. REQUEST FOR PRODUCTION NO.4 How do NEEA's efforts address energy efficiency and demand side reductions at facilties of large power users, such as Schedule 19 customers in Idaho. Please explain, and provide supporting documentation. REQUEST FOR PRODUCTION NO.5 How will increasing fuding for NEEA benefit Schedule 19 customers in Idaho? Please explain, and provide supporting documentation. Page 3 - FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-l 0-04 REQUEST FOR PRODUCTION NO.6 Please explain whether any other state Public Utility Commissions in the Northwest have approved NEEA's 2010-2014 business plan or its increased fuding discussed in the application in this docket. REQUEST FOR PRODUCTION NO.7 Please explain why Idaho Power requires an independent, third-pary audit ofNEEA's use of Idaho ratepayer fuds collected through the energy effciency rider (as discussed on page 14 of the Application in this docket). Please include explanation of why in the Memorandum of Understanding submitted in Case No. IPC-E-09-09 Idaho Power does not employ an independent, third-party to audit Idaho Power's use of ratepayer fuds collected through the energy efficiency rider. Please explain this discrepancy. REQUEST FOR PRODUCTION NO.8 How are ratepayers represented on the NEEA board? REQUEST FOR PRODUCTION NO.9 Please provide the minutes of NEE A board meetings for the last 12 months. REQUEST FOR PRODUCTION NO. 10 How is the NEEA board organized and how are board members selected? Page 4 - FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-l 0-04 Thank you for your prompt attention to this First Request for Production. Sincerely yours, ams RDSON & O'LEARY, PLLC Page 5 - FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC- E-l 0-04 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 15th day of March 2010, a true and correct copy of the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER was served in the manner shown to: Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission PO Box 83720 Boise, I D 83720-0074 lL Hand Delivery _ U.S. Mail, postage pre-paid Facsimile Electronic Mail Claire Fulenwider Executive Director I Northwest Energy Efficiency Alliance 529 SW Third Avenue, Suite 6 Portland, Oregon 97204 CF ulenwider~nwallance.org _ Hand Delivery _ U.S. Mail, postage pre-paid Facsimile 2S Electronic Mail Lisa Nordstrom Barton L. Kline Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 Inordstrom~idahopower.com bkline~idahopower.com _ Hand Delivery U.S. Mail, postage pre-paid Facsimile X Electronic Mail