20140414IPC to Staff 1-3.pdf

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An IDACoRP Company
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JULIAA. HILTON
Corporate Gounsel
ih i [e-mail]
April 1 1,2014
VIA HAND DELIVERY
Jean D. Jewel!, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-02
Third Amendment to Demand Response Agreement with EnerNOC, lnc. -
ldaho Power Company's Response to the First Production Request of the
Commission Staff
Dear Ms. Jewe!!:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the First Production Request of the Commission Staff to
ldaho Power Company.
Also enclosed in a separate envelope are an original and three (3) copies of ldaho
Power Company's Confidential Response to the First Production Request of the
Commission Staff to Idaho Power Company. Please handle the confidential information in
accordance with the Protective Agreement executed in this matter.
JAH:csb
Enclosures
Julia A. Hilton
122 1 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
JULIA A. HILTON (lSB No. 7740)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ih i lton@ida hopower. com
I no rd strom@ida hopower. co m
Attorneys for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION FOR APPROVAL
OF THIRD AMENDMENT TO lTS
AGREEMENT WITH ENERNOC, INC. -
DEMAND RESPONSE PROGRAM
i,; 5?
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-14-02
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/' or "CompEtry"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated March 28,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide the estimated FlexPeak expense for the 2014
program year and please explain how the total expense was calculated.
RESPONSE TO REQUEST NO. 1: The response to this Request is confidential
and proprietary to EnerNOC, Inc.'s ("EnerNOC") business model and will be provided
separately to those parties that have signed the Protective Agreement in this matter.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
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-13-2'1.
RESPONSE TO REQUEST NO. 2: ldaho Power expects a FlexPeak demand
reduction capacity of between 30 and 35 megawatts in 2014. ln Case No. IPC-E-13-21,
Idaho Power did not define the amount of demand reduction capacity that would be
provided by the FlexPeak Management program. When Case No. IPC-E-13-21 was
filed, ldaho Power had not successfully negotiated nor signed a contract with EnerNOC
forthe 2014 season. ln response to Staff's Production Request No. 4 in Case No. IPC-
E-13-21, ldaho Power stated:
ldaho Power does not have a forecast of the total amount of
demand reduction from this program for 2014. However, the
Company believes that it is a reasonable assumption that it
can satisfy the deficit of 30 MW in 20'14 as shown in the
Company's Application on Table 2 with its existing demand
response programs if necessary.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
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.
RESPONSE TO REQUEST NO. 3: The contract separated the delivery period
into two segments to accommodate the reduction in available demand reduction
capacity from three months to two months. Prior to the amendment, the demand
reduction capacity was available between June 1 and August 31. As part of
Amendment No. 3, the 2014 season reduced the program availability to between June
15 and August 15, in accordance with the Settlement Agreement and Order No. 32923
in Case No. IPC-E-13-14. The resulting pricing change is to divide the annual cost per
kilowatt equally between two billing periods instead of the three billing periods, as was
done previously. Beyond the dates of availability, no programmatic changes apply to
these segments.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 11th day of April 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
IA A. HILTON
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of April 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Weldon B. Stutzman
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customerc of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, Idaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OFTHE COMMISSION STAFFTO IDAHO POWERCOMPANY.5