20131007Staff 1-6 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BARNO.5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
IN THE MATTER OF IDAHO POWER
COMPANY'S 2OI3 INTEGRATED RESOURCE
PLAN.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E.13.15
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Company; IPC) provide the following documents and information as soon as possible, by
MONDAY, OCTOBER 28, 2013.
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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identiff the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY OCTOBER 7,2013
REQUEST NO. l: Please provide any analyses conducted by the Company to quantify
how mandatory time-of-use rates for Schedule 19 customers impact class demand and energy
use. If the Company has not conducted any analysis, please explain why.
REQUEST NO.2: Please explain how a mandatory time-of-use rate for Schedule 19
customers has changed the methodology of forecasting peak load for the industrial class within
the Integrated Resource Plan (IRP).
REQUEST NO.3: What contingency analysis has the Company performed to enable it
to meet its load obligations if Boardman to Hemingway is delayed?
REQUEST NO. 4: Does the Company's portfolio analysis include any sections of the
Gateway West project? Why or why not?
REQUEST NO. 5: The Company forecasts energy savings of 69 aMW for 2013 -2017
due to its current demand-side management (DSM) portfolio (IRP, p. 43), and 38 aMW from
new energy efficiency savings by 2017 (p.44). Specifically, how does the Company plan to
obtain these savings? What new measures, programs and marketing efforts will the Company
implement to achieve these savings?
REQUEST NO. 6: The l0-year Action Plan does not discuss energy efficiency as a
resource. Please explain why.
DATED at Boise, Idaho, this 4
-fL- day of October 2013.
/L/ // t-.-.--
Karl T. Klein
Deputy Attorney General
Technical Staff: Bryan Lanspery/l-4
Nikki Karpavich/5-6
i:umisc:prodreq/ipcel3.l5kkblnk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 OCTOBER 7,2013
I HEREBY CERTIFY THAT I
SERVED THE FOREGOING F'IRST
COMMISSION STAFF TO IDAHO
IPC-E-I3-15, BY MAILING A COPY
FOLLOWNG:
LISA D NORDSTROM
JENNIFER REINHARDT
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
EMAIL: [e-mail]
i reinhardt@ idahopower.com
dockets@ idahopower.com
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
EMAIL: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS
5I5 N 27TH ST
BOISE ID 836I6
EMAIL: oeter(Erichardsonadams.com
THOMAS H NELSON
ATTORNEY AT LAW
PO BOX 1211
WELCHES OR 97068
Email: [e-mail]
CERTIFICATE OF SERVICE
HAVE THIS 7TH DAY OF OCTOBER 2013,
PRODUCTION REQUEST OF THE
POWER COMPANY, IN CASE NO.
THEREOF, POSTAGE PREPAID, TO THE
GREGORY W SAID
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
EMAIL: [e-mail]
ttatum@ i dahopower. com
BENJAMTN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
EMAIL : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
NANCY ESTEB PhD
PO BOX 490
CARLSBORG WA 98324
Email: [e-mail]
CERTIFICATE OF SERVICE