20130314Staff 1-4 to IPC.pdf

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WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 3283
2013IIA:R 14 j4 3: 52
lOAHO rL hi UT1LITE3 COMiS.SRJ
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 THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL )
OF ITS AGREEMENT WITH ENERNOC TO )
IMPLEMENT AND OPERATE A VOLUNTARY)
COMMERCIAL DEMAND RESPONSE )
PROGRAM. )
)
)
CASE NO. IPC-E-13-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
MONDAY, MARCH 25, 2013.
This Production Request is to be considered as continuing, and Idaho Power Company 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 documents produced.
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 who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 MARCH 14, 2013
REQUEST NO. 1: Under what conditions will the Company pay EnerNoc an energy
payment?
REQUEST NO. 2: What scenario(s) will the Company dispatch FlexPeak in 2013 under
the proposed amendment?
REQUEST NO. 3: What scenario(s) will the Company dispatch FlexPeak in 2013 under
the current contract?
REQUEST NO. 4: Given the Company's answers to Request Nos. 2 and 3, what is the
Company's anticipated cost for the Flex Peak Program for 2013? Please delineate by customer
incentive, labor/administrative, other expense, and purchased services.
DATED at Boise, Idaho, this A4 0ilay of March 2013.
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Nikki Karpavich
i:umisc:prodreq/ipce 13.4wsnk prod req I
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 MARCH 14, 2013
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF MARCH 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF, IN CASE NO. IPC-E-13-04, BY E-MAILING AND MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: [e-mail]
[e-mail]
TAMI WHITE
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: [e-mail]
SEC TARY
CERTIFICATE OF SERVICE