20130325ICIP 1-8 to IPC.pdf

Peter J. Richardson ISB # 3195
Greg Adams ISB # 7454
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
7fl:fAR25 AMII:55
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER IDAHO POWER ) CASE NO. IPC-E-13-04
COMPANY'S APPLICATION FOR )
APPROVAL OF ITS AGREEMENT WITH ) FIRST PRODUCTION REQUEST OF
ENERNOC TO IMPLEMENT AND ) THE INDUSTIAL CUSTOMERS OF
OPERATE A VOLUNTARY ) IDAHO POWER
COMMERCIAL DEMAND RESPONSE )
PROGRAM
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the 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.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; dreadingmindspring.com
I -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-13-04
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 hearing who can sponsor the answer
Some of the following requests may include disclosures deemed by Idaho Power to be
confidential. Idaho Power, along with all other parties to this case, are reminded that the
Industrial Customers of Idaho Power have entered into and filed with the Commission the
Protective Agreement in connection with this case IPC-E- 13-04.
REQUEST FOR PRODUCTION NO.!:
Please provide copies of Idaho Power's responses to discovery requests by all other
parties to this docket.
REQUEST FOR PRODUCTION NO. 2:
Page three of the Application states, "Over the program years between 2009 and 2012,
Idaho Power has called 8, 4, 14, and 4 events, respectively, for an average load reduction,
excluding the first two years of program ramp-up, of 38 megawatts ("MW"). Please provide for
each one of the events, the month, day, time period, megawatt and MWh reductions. Also please
provide the number of participants for each event.
REQUEST FOR PRODUCTION NO. 3:
Page three of the application states, "While participation had steadily grown between
2009 and 2011, participating sites declined between 2011 and 2012 from 108 to 102. The
weekly commitment in 2012 peaked in "August at 38.8 Mw; the average weekly MW rerductin
during the entire 2012 season was 34.5 MW." Please describe any know reasons for the decline
in the number of participants and committed MW.
REQUEST FOR PRODUCTION NO. 4:
4
Page three of the Application states, "If the contract with EnerNoc remains unchanged in
2 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-13-04
2013, achievable demand reduction is expected to increase and the overall program costs are
expected to increase as well." Given the decline in participation and committed MW between
2011 and 2012, please explain why the Company believes leaving the program unchanged will
result in an increase in both in 2013.
REQUEST FOR PRODUCTION NO. 5:
Page six of the Application states, "Idaho Power has also included a confidential
explanation of the Second Amendment to the Agreement as Attachment 2 to the Application.
This explanation will be provided upon request and execution of the Protective Agreement. The
confidential explanation will be provided in lieu of the Second Amendment to the Agreement to
interested parties that could profit from the specific financial and business model data contained
in the Second Amendment." Please provide the Agreement, the First Amendment to the
Agreement, the Second Amendment to the Agreement and Attachment 2, the confidential
explanation of the Second Amendment to the Agreement.
REQUEST FOR PRODUCTION NO. 6:
Please provide all FlexPeak Management Reports completed by the Company from the
program's inception to the present.
REQUEST FOR PRODUCTION NO. 7:
Page four of the Application indicates the agreement between Idaho Power and EnerNoc
expires in February of 2014. Does the Company expect to execute a new contract with EnerNoc
for the FlexPeak program? If so, at what level of participation, megawatts committed, dispatch
hours, and event days will the Company anticipate be included in the new contract? Please
explain fully.
3-FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - EPC-E-13-04
REQUEST FOR PRODUCTION NO. 8
According to Idaho Power's 2012 Demand-Side management Annual Report, at page
159, there are five participant sites and 11.6 MW annual savings for the FlexPeak program in
Oregon. Does the Company anticipate asking the Oregon Commission also for a curtailment of
the FlexPeak program in Oregon? Please explain why or why not.
DATED this 25th day of March, 2013.
RICHARDSON & O'LEARY PLLC
By:
Peter J. Richardson, ISB #3195
Attorneys THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
4-FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER- IPC-E-13-04
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that on the 25th day of March, 2013, 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 X Hand Delivery
Commission Secretary U.S. Mail, postage pre-paid
Idaho Public Utilities Commission Facsimile
472 W. Washington (83702) Electronic Mail
P0 Box 83720
Boise, ID 83720-0074
Lisa Nordstrom X Hand Delivery
Idaho Power Company U.S. Mail, postage pre-paid
P0 Box 70 - Facsimile
Boise, Idaho 83707-0070 X Electronic Mail
[e-mail]
Weldon Stutzman X Hand Delivery
Idaho Public Utilities Commission U.S. Mail, postage pre-paid
472 West Washington Street - Facsimile
Boise, Idaho 8372 X Electronic Mail
Weldon.stutzman(idaho.puc.gov
Nina Curtis
Administrative Assistant
5-FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-13-04