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Home My WebLink About20110505ICIP 1-8 to IPC.pdfPeter J. Richardson (lSB # 3195) Gregory M. Adams (lSB # 7454) Richardson & O'Lear, PLLC 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter($richardsonandolear .com greg($richardsonandolear .com RECEIVFI)._..- 20U HAY -5 PM a: 30 Attorneys for the Industral Customers of Idao Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION )IN THE MATTER OF IDAHO POWER ) COMPANY'S REQUEST FOR A PRUDENCY ) DETERMINATION OF ENERGY ) EFFICIENCY RIDER FUNDS SPENT IN 2010 ) ) CASE NO. IPC-E-ll-05 FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF IDAHO POWER Puruat to Rule 225 of the Rules of Procedur of the Idaho Public Utilities Commission (the "Commission"), the Industral Customers of Idaho Power ("ICIP") hereby requests that Idaho Power Company ("Idaho Power") provide responses to the followig with supporting documents, where applicable, as soon as possible. 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 will augment the responses or documents produced. Page 1 - FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-II-05 Please provide one physical copy and one electronic copy, if available, of your answer to Mr. Adams at the address noted above. Please provide an additional electronic copy, or if unvailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel: (208) 342-1700; Fax: (208) 384-1511; dreadingêmindspring.com. For 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. Page 2 - FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-II-05 REQUEST FOR PRODUCTION NO.1 Please provide in electronic format Exhibits NO.1 and No.2 attached to Darlene Nemich's Direct Testimony. REQUEST FOR PRODUCTION NO.2 On pages 12 and 13 of Darlene Nemich's Direct Testimony she stated: According to the National Action Plan for Energy Efficiency's Understanding Cost- Effectiveness of Energy Effciency Programs: Best Practices, Technical Methods, and Emerging Issues for Policy-Makers, ths test is tyically a secondar test used to evaluate relative impacts on rates. It should be noted that Staff, in Attchment No.1 to the DSM MOU, while stating an expectation that programs should pass the TOU, UC, and PCT tests (and if not provide an explanation), there was no stated expectation that programs must pass the RIM test. (a) Please explain what is meant by a "secondar test used to evaluate relative impact on rates." (b) Does the Company believe the RIM test should be used to evaluate DSM program costs effectiveness? Please explain why or why not. (c) Please provide a copy of" Understanding Cost-Effectiveness of Energy Effciency Programs: Best Practices, Technical Methods, and Emerging Issues for Policy-Makers. " REQUEST FOR PRODUCTION NO.3 On page 17 of Darlene Nemich's Direct Testimony she states, "These studies, along with market effects evaluations conducted by NEEA (provided in the CD included in Attchment NO.1 to the application) are included in Supplement 2." Please provide a copy of the CD that was included as an attchment to the application. REQUEST FOR PRODUCTION NO.4 The Company's Demand-Side Management 2010 Anua Report states there were 30,803 paricipants in the A/C Cool Credit program in 2010 (page 20). On page 23 the DSM Anual Report it states: The 2011 program target is to reach 40,000 tota paricipants. Once the taget is achieved, the company will continue A/C Cool Credit marketing and promotion to determine if satuation has been achieved or if it is possible to increase parcipation. As Smar Meters are installed in those areas where the paging signal is unavailable, the A/C Cool Credit program will be able to expand. Page 3 - FIRST PRODUCTION REQUEST OF THE INDUSTRI CUSTOMERS OF IDAHO POWER-IPC-E-II-05 The curent demand reduction is 39.0 MW. With the 30% increase in paricipants expected in 2011, does the Company expect an equal 30% increase in MW demand reduction (11.7 MW)? What is the expected increase in paricipants and demand reduction for the areas where paging signals are not available? REQUEST FOR PRODUCTION NO.5 Exhibit 1, page 1 of Darlene Nemnch's Direct Testimony shows the Irigation Peak Rewards Program rider expenditues for 2010 of $13,096,946. In Order No. 32200, IPC-E-I0-46, March 9,2011, the Commission approved significant changes to the Irigation Peak Rewards Program. Wht changes in the expenditues for ths program does the Company expect to the changes approved by the Commission? Does the Company expect any MW changes do to the program changes? REQUEST FOR PRODUCTION NO.6 The Company's 2010 Demand-Side Management Anual Report, page 102 discussing the Irrigation Peak Rewards Program states; Idaho Power will continue to educate customers on the program, though workshops and agricultue shows, though may have to limit paricipation levels to near curent levels, based on the overall need for demand response as a resource to meet futue loads. (a) Does this mean Idaho Power plans to limit expansion of their Demand Response Programs beyond their curent levels? (b) If so, please explain why the Company would limit Demand Response Programs when it is showing Peak-Hours deficits beginnng in 2015 as displayed on slide 43 presented at the November 18,2010, Integrated Resource Plan Advisory 20 Council (IRPAC) meeting. (c) Has the Company compared the costs of increased the DSR to the costs of a new peaking plant to meet the projected demand referred to in (b)? REQUEST FOR PRODUCTION NO.7 Reference the Idao Power IRPAC Meeting Slide Presentation on Nov. 18,2010, at slide 22. (a) Please provide all data regarding "operational tagets" for individual DSM programs used in the 2011 IR process. Please organize the data by DSM program. (b) Please provide all data regarding "demand response targets" for individua DSM programs used in the 2011 IRP process. Please organize the data by DSM program. Page 4 - FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-II-05 REQUEST FOR PRODUCTION NO.8 Does Idaho Power use the "demand response targets" or the "operational targets" when analyzing cost effectiveness in the 2010 DSM Report? Please provide supporting evidence of the demand reduction (MW) or energy use reduction (kWh or MWh) for each DSM program. Than you for your prompt attention to this First Request for Production. Sincerely yours,~ ory Adams RICHARDSON & O'LEARY, PLLC Page 5 - FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF IDAHO POWER- IPC-E-I1-05 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 5th day of May, 2011, a tre and correct copy of the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIL CUSTOMERS OF IDAHO POWER IN CASE NO.IPC-E-II-05 was served in the maner shown to: Ms. Jean Jewell Commssion Seceta Idao Public Utilities Commssion POBox 83720 Boise, ID 83720-0074 X Hand Delivery _ U.S. Mail, postage pre-paid Facsimile Electronic Mail Lisa D Nordstrom Jason B Wiliams Idaho Power Company POBox 70 Boise, Idao 83707-0070 lnordstrom~idahopower..com jwiliams($idaopower.com _ Hand Delivery X U.S. Mail, postage pre-paid Facsimile Electronic Mail Darlene Nemich Greg Said Idaho Power Company POBox 70 Boise, Idaho 83707-0070 dnentich~idahopower.com gsaid~idaopower.com _ Hand Delivery X U.S. Mail, postae pre-paid Facsimile Electronic Mail