20110113ICIP 27-30 to IPC.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richardson & O'Lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
petercmrichardsonandolear.com
gre gcmrichardsonandolear. com
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Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S REQUEST TO MODIFY
RECOVERY OF INCENTIVES PAID TO
SECURE DEMAD-SIDE
RESOURCES
)
) CASE NO. IPC-E-I0-27
)
) THIRD PRODUCTION REQUEST
) OF THE INDUSTRIAL CUSTOMERS
) OF IDAHO POWER
Pursuat to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commssion
(the "Commission"), the Industrial Customers ofIdao Power ("ICIP") hereby requests that
Idaho Power Company ("Idaho Power") provide responses to the following with supporting
documents, where applicable, within 14 days on January 27, 2011, if possible, but in any event
no later than February 3, 2011. Please follow the instructions set forth in ICIP's First
Production Request in this docket.
Page 1 - THIRD PRODUCTION REQUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER- IPC-E-IO-27
REQUEST FOR PRODUCTION NO. 27
Reference the Company's Response to ICIP's Request Nos. 15 and 22 (stating the estimated
2011 Peak for the 3 Demand Response programs (AIC Cool Credit, Flex Peak, Irrigation Peak
Rewards) is 376 MW (285+43+48=376)); and Power Point Presentation titled: "Demand Side
Management Demand Response," presented at the IRPAC Meeting November 18,2010,
available as slide 22 at http://ww.idahopower.com/pdfs/AboutUs/Planing
ForFuture/irp/20ll/2010l118IRPACMeetingPresenationSlides Web.pdf(discussing an
"operational" limit through 2020 of351 MW (330 MW for 2011) for the Company's Demand
Response programs.
Please explain why the 376 MW for 2011 provided in this case exceeds the estimated operational
limit provided in the IRP AC meeting. Wil the Company rely upon the projections in this docket
in future analysis regarding load and peak growth projections used in its IRP process?
REQUEST FOR PRODUCTION NO. 28
Reference the Company's Response to the Commission Staffs Request NO.4.
(a) Please provide a fully electronic executable spreadsheet containing all data and
calculations that were used in the calculations presented in the colum labeled "Energy-Based
Allocation % (PCA Approach)."
(b) Please provide a fully electronic executable spreadsheet containing all data and
calculations that were used in the calculations presented in the colum labeled "Energy-Based
Allocation % (Rider Approach)."
(c) Please indicate the demand response programs that are included in "allocation effects of
moving all demand response incentive payment costs from the Rider to the Power Cost
Adjustment (PCA)," as presented in the Company's spreadsheet in the referenced response. If
this does not include all programs curently in operation, please state the program(s) not included
and estimated allocation effect.
(d) Please provide the estimated dollar impact (indicating increase or decrease) for each
customer class for the 2011/2012 and 2012/2013 PCA years from shifting the DSR incentive
payments from the current Rider approach to the PCA approach. Please provide a dollar impact
also to each customer class of placing 0$ in DSR costs in the PCA, and instead increasing the EE
rider percentage of 4.75% by 1.9% to 6.65%. (1.9% was provided as the necessary percentage in
the Company's Response to ICIP Request No. 18(b).)
Page 2 -l;lIIRDrRQl1VCTION R.EqUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER- IPC-E-1O-27
REQUEST FOR PRODUCTION NO. 29
Reference Direct Testimony of Darlene Nemnich, pages 8 and 9 (stating the Company proposes
to collect DSR incentive payments though the PCA). How does the Company propose to
include the DSR incentive payments in its cost-of-service study in a rate case? Would these DSR
incentive costs be directly assigntd to the customer class that received the incentive payments or
assigned as a system resource? Would they be considered energy related or demand related?
Please explain, and estimate the impact on a cost of service study and resulting rate allocation.
REQUEST FOR PRODUCTION NO. 30
Reference the Company's Response to ICIP Request No. 22(e) (stating the with regard to
EnerNOC program, the "tagets for demand reduction for" 2009 though 2013 are 2 MW, 30
MW, 40 MW, 50 MW, and 50 MW, respectively, and that these targets were used in the table
provided in the response), and the FlexPeak Management 2009 Preliminar Report attached to
the response, at pp. 11-12.
(a) Please admit or deny that for 2009 Idaho Power projected 2 MW of peak reduction, and
EnerNOC achieved 11.1 MW of reduction, and therefore the actual reduction was over 500% of
the predicted reduction.
(b) Please admit or deny that actu costs were lower than expected for 2009.
(c) In light of (a) and (b), please explain what adjustments the Company has made to the
projections for 2011 used in the Response to ICIP Request No. 22(e). Were the projections
changed afer completion of the FlexPeak Preliminar Report on Februar 24, 20107 Is it
reasonable to assume that the reductions wil be larger and the costs lower in years 2011 though
2013, as they were in 2009? If so, what is the likely impact in the $/MW figures provided.
Than you for your prompt attention to this Second Request for Production.
(jer~
~ry M. Adams
RICHARDSON & O'LEARY, PLLC
Page 3 - THIRD PRODUCTION REQUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER - IPC-E-l 0-27
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ths I~~y of Janua, 2011, I caused a true and
correct copy of the foregoing THIRD PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER to be served by the method indicated below, and
addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street (83702)
Post Office Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(x ) Hand Delivered
( ) Overnght Mail
( ) Facsimile
( ) Electronic Mail
Lisa Nordstrom
Donovan Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707
dwalkercmidahopower.com
Inordstromcmidahopower.com
(x) U.S. Mail, Postae Prepaid
( ) Hand Delivered
( ) Overnght Mail
( ) Facsimile
(x) Electronic Mail
John R. Gale
Darlene Nemnich
Idaho Power Company
PO Box 70
Boise, ID 83707
i galecmidahopower .com
dnemnich(âidahopower .com
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Brad M. Purdy
Attorney at Law
2019 N. 17th S 1.
Boise, ID. 83702
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Nancy Hirsh
NW Energy Coalition
811 1st Ave, Suite 305
Seattle, W A 98104
nancy(ßnwenergy.org
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Page 4 - THIRD PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER- IPC-E-10-27
Ken Miler
Snake River Allance
350 N 9th St # B610
Boise, ID 83702-5473
kmilercmsnakeriveralliance.org
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
bottocmidaoconservion.org
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnght Mail
( ) Facsimile
(x) Electronic Mail
Eric 1. Olsen
Racine, Olson, Nye, Budge &
Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho
elocmracinelaw.net
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(x) Electronic Mail
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
tonya!yane1.net
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnght Mail
( ) Facsimile
(x) Electronic Mail
Si~OO¡~
Adams
Page 5 - THIRD PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER~ IPC-E-10-27