20130626ICL 1-3 to IPC.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone]xt2
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLTCATION OF rDAHO POWER )
COMPANY FOR A DETERMINTION )
OF 2OI2 DEMAND-SIDE ) FIRST PRODUCTION REQUEST OF
MANAGEMENT EXPENDITURES AS ) THE IDAHO CONSERVATION
PRUDENTLY INCURRED LEAGUE
The Idaho Conservation League (ICL) requests the following information. Please provide
any supporting documents, workpapers, calculations, or information sources that support any
answer. As required by IDAPA 31.01.01.228.02, please indicate the witness who can answer
questions regarding the response and who may sponsor the response at any potential hearing. If
any responses include Excel spreadsheets or other electronic files, please provide them with all
formulas intact and activated. This production request is ongoing. Accordingly, we ask Rocky
Mountain Power to provide additional documents and information that may supplement any
initial responses.
Request No 1: Please provide a copy of all production requests submitted in this case by other
parties, along with any responses by Idaho Power.
Request No 2: Please provide a hard copy of the 2013 Demand Side Management Potential Study
including any appendices.
Request No 3: Please compare, by DSM program, the level of energy efficiency achieved by Idaho
Power in2012 against the level of cost effective potential and the achievable potential identified
in the 2009 DSM Potential Study. Along with quantiffng the gap, please provide a qualitative
description of the factors underlying any gap.
Respectfully submitted this 26'h day of |une 2013,
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CASE NO. IPC-E-13-08
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Benjamin J. Otto
Idaho Conservation League
[PC-E-13-08
ICL First Production Request
Jlune 26,2013
CERTIFICATE OF SERVICE
I hereby certifr that on this 26 th day of June 2013,I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST to the following persons via the method of
service noted:
Hand delivery:
)ean )ewell
Commission Secretary (Original and 3 copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Julia a. Hilton
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
dockets@idahopower. com
Darlene Nemnich
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
ttatum@idahopower. com
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Befrjamin I. Otto
rPC-E-13-08
ICL First Production Request
June26,2013