20140116Staff 1-8 to IPC.pdf

KRISTINE A. SASSER .,. , -
DEPUTY ATTORNEY GENERAL 4:,:. I . :, i .:, .'' ?-: i 0
IDAHO PUBLIC UTILITIES COMMISSION J ]
PO BOX 83720
BOISE, IDAHO 83720-0074 : :
(208) 334-03s7
BAR NO. 6618
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 IDAHO POWER
COMPANY'S APPLICATION FOR APPROVAL ) CASE NO. IPC-E-13-21
OF ITS CAPACITY DEFICIENCY PERIOD TO BE )
UTILIZED IN THE COMPANY'S SAR
METHODOLOGY.
) FIRST PRODUCTION
) REQUEST OF THE) coMMrssroN srAFF To
) IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information on or before THURSDAY, FEBRUARY 612014.
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.
Please provide answers to each question and any supporting workpapers that provide detail or
are the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person preparing
the document, and the name, location and phone number of the record holder and, if different, the
witness who can sponsor the answer at hearing. Reference IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JANUARY 16,2014
REQUEST NO. 1: Please provide all documentation supporting Idaho Power's assertion that
it will acquire approximately the same amount of demand response in2014 as in2012 given that the
terms of the 2013 settlement adopted by the Commission in Order No. 32923 l) reduce fixed
incentive payments to participants, 2) mandate at least three intemrptions each season, 3) limit
recruitment of residential and commercial/industrial customers, and 4) preclude new irrigation
participation.
REQUEST NO.2: Please provide the current number of A/C Cool Credit participants, the
amount of demand reduction expected from each participant, the expected realization rate, source of
the realization rate, and the total amount of demand response expected to be realized from this
program in2014.
REQUEST NO.3: Please provide the annual attrition rate for A/C Cool Credit participants
in 2010, 2011,2012, and 2013.
REQUEST NO. 4: Please provide the current number of FlexPeak participants (sites) which
are under contract for the 2014 season, the total amount of commercial/industrial demand response
under contract for the 2014 season, the expected realization rate, source of the realization rate, and the
total amount of demand response expected tobe realized from this program in2014.
REQUEST NO. 5: Does Idaho Power plan to contract with EnerNoc or another third-party
aggregator to provide commercial/industrial demand response in2014? If so, please explain the
status of the contract negotiations. If not, please explain in detail how Idaho Power plans to acquire
the amount of commercial/industrial demand response expected to be realizedin20l4.
REQUEST NO. 6: Please provide the current number of Irrigation Peak Rewards
participants (service points) under contract for the 2014 program season, the total amount of irrigation
demand response under contract for the 2014 season, the expected realization rate, source of the
realization rate, and the total amount of demand response expected to be realized from this program
in20l4.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JANUARY 16,2014
REQUEST NO. 7: If the amount of inigation demand response currently under contract is
different from the amount Idaho Power expects to have for the 2014 season, please explain how Idaho
Power plans to acquire the amount of irrigation demand response expected to be realizedin2}l4.
REQUEST NO. 8: Does Idaho Power believe that the terms of the Commission approved
2013 settlement (Order No. 32923), which reduces incentive payment amounts and increases
intemrption, will over time reduce the participation rates and reliability of its irrigation demand
response program? Please explain why or why not.
Dated at Boise,Idaho, this l(PAu1of January 2014.
Technical Staff: Stacey Donohue
i:umisc:prodreq/ipce 13.2 lksrsd prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JANUARY
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY oF JANUARY 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
coMMrssloN STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-l3-
2I, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707
E-MAIL: [e-mail]
dockets@idahopower. com
PETER J zuCHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
gre g@ richardsonandoleary. com
RANDY ALLPHIN
TESS PARK
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707
E-Mail: [e-mail]
[e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE