20140411ICL 1-3 to IPC.pdf

Benjamin Otto (ISB No.8292)
710 N 6th Street
Boise,ID 83701
Ph:[phone] x 12
Fax:[phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY’S APPLICATION FOR
APPROVAL OF ITS AGREEMENT
WITH ENERNOC,INC.,TO
IMPLEMENT AND OPERATE A )
VOLUNTARY COMMERCIAL )
DEMAND RESPONSE PROGRAM )
RE C;
I P 1:35
D Ct J
CASE NO.IPC-E-14-02
THE IDAHO CONSERVATION
LEAGUE’S
FIRST PRODUCTION REQUEST TO
IDAHO POWER
COMES NOW the Idaho Conservation League,with the following production requests.
Along with the answer to each question,please provide any supporting documents,workpapers,
calculations,or information sources Idaho Power relies upon to support its answer.As required
by IDAPA 3 1.01.01.228.02,please indicate the witness who can answer question regarding the
response and who will sponsor the response at any hearing.If any responses include Excel
spreadsheets or other electronic files,please provide them with all formulas intact and activated.
As allowed by IDAPA 31.01.01.228.01,if the volume of any response indicates it would be more
feasible to do so ICL agrees to the Company depositing the response in an electronic depository.
This production request is ongoing.Accordingly,we respectfully ask Idaho Power to
provide additional documents and information that may supplement any initial responses.
REQUEST NO 1:Please provide responses to any discovery requests Idaho Power has received
from any other party in this docket.
REQUEST NO 2:Please provide the confidential explanation of the Third Amendment.
IPC-E-14-02 1 April 11,2014
ICL 1s production request to IPC
REQUEST NO 3:Please provide the Third Amendment in its entirety.The Idaho Conservation
League cannot profit from any information in this amendment as we do not provide demand
response programs nor are we eligible to participate in the FlexPeak program.However,ICL
needs the full Third Amendment to assess Idaho Power’s assertion this document aligns with the
Settlement Agreement approved in Case No.IPC-E-13-14.
DATED the 11t1 day of April 2014.
Benjamin I.Otto
Idaho Conservation League
IPC-E-14-02 2 April 11,2014
ICL 1st production request to IPC
CERTIFICATE OF SERVICE
I hereby certify that on this 11th day of April 2014 I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE,
TO IDAHO POWER to the following via the method of service noted:
First Class Mail:
Jean Jewel!
Commission Secretary (Original and three copies provided)
Idaho Public Utilities Commission
427 W.Washington St.
Boise,ID 83702-5983
Electronic Mail Only:
Idaho Power
Julia A.Hilton
Tami White
Regulatory Dockets
Idaho Power Company
P.O.Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
[e-mail]
ICIP
Peter I.Richardson
Gregory M.Adams
Richardson &O’Leary,PLLC
515 N.27th Street
Boise,ID 83702
[e-mail]
[e-mail]
Dr.Don Reading
6070 Hill Road
________________
Boise,Idaho 83703 Benjamin J.Otto
[e-mail]
IPC-E-14-02 3 April 11,2014
ICL 1st production request to IPC