20140328Staff 1-3 to IPC.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 3283
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF COMMERCIAL
DEMAND RESPONSE PROGRAM. IDAHO
POWER COMPANY'S PETITION FOR
APPROVAL OF THIRD AMENDMENT TO
AGREEMENT WITH ENERNOC, LNC.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-8.I4-02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Weldon B. Stutzman, Deputy Attomey General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
FRTDAY, APRIL 11,2014.
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.
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 MARCH 28,2014
REQUEST NO. 1: Please provide the estimated FlexPeak expense for the 2014 program
year and please explain how the total expense was calculated.
REQUEST NO.2: Please provide the expected FlexPeak demand reduction capacity for
2014 and how that capacity compared with the FlexPeak capacity included in IPC-E-13-21.
REQUEST NO.3: Regarding Amendment No. 3, please describe why the contract
separated the delivery period into two segments and if any pricing and/or programmatic changes,
beyond those specified in the amendment, apply to the segments.
DATED at Boise, Idaho, thkT€W^yof March 2014.
Weldon B. Stutzman
Deputy Attomey General
Technical Staff: Nikki Karpavich 1-3
i:umisc:prodreq/ipce l4.2wsnkde prod req I
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY MARCH 28,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF MARCH 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-14-02, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
CBearr.v@ idahopower. com
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE