20140418IPC to ICL 1-3.pdf

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An IDACORP Company
JULIAA. HILTON
Corporate Counsel
[e-mail]
April 18,2014
VIA HAND DELIVERY
Jean D. Jewel!, $ecretary
ldaho Public Utilities Commission
47 2 W esl 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 ldaho Conservation League's First
Production Request
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's Response to the ldaho Conservation League's First Production Request
to ldaho Power.
JAH:csb
Enclosures
Sincerely,
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
JULIA A. HILTON (!SB No. 7740)
LISA D. NORDSTROM (lSB No. 573s)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ihilton @ ida hopower. com
lnordstrom @ida hopower. co m
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF TDAHO POWER )
CoMPANY'S PETITION FOR APPROVAL ) CASE NO. tpC-E-14-02
OF THIRD AMENDMENT TO ITS )
AGREEMENT WITH ENERNOC, tNC. - ) IDAHO POWER COMpANy',S
DEMAND RESPONSE PROGRAM ) RESPONSE TO THE IDAHO
) CONSERVATION LEAGUE'S
) FrRST PRODUCTTON REQUEST
) TO IDAHO POWER
)
COMES NOW, ldaho Power Company ("ldaho Powe/'), and in response to the
ldaho Conservation League's First Production Request to ldaho Power dated April 11,
2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 1
REQUEST NO. 1: Please provide responses to any discovery requests ldaho
Power has received from any other party in this docket.
RESPONSE TO REQUEST NO. 1: ln the regular course of business, ldaho
Power will provide copies of its responses to discovery requests to the ldaho
Conservation League ("lCL") in this proceeding. To date, ldaho Power has only
responded to the ldaho Public Utilities Commission Staff's ("Staff') First Production
Request. A copy of ldaho Powe/s response to Staff's Request was previously provided
to lCL.
The response to this Request is sponsored by Christa Bearry, Legal
Administrative Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUESTTO IDAHO POWER- 2
REQUEST NO. 2: Please provide the confidential explanation of the Third
Amendment.
RESPONSE TO REQUEST NO. 2: The confidential explanation of the third
amendment was previously provided to lCL.
The response to this Request is sponsored by Christa Bearry, Legal
Administrative Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 3
REQUEST NO. 3: Please provide the Third Amendment in its entirety. The
ldaho 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
FIexPeak program. However, lCL needs the full Third Amendment to assess ldaho
Powe/s assertion this document aligns with the Settlement Agreement approved in
Case No. IPC-E-13-14.
RESPONSE TO REQUEST NO. 3: The confidential third amendment was
previously provided to lCL.
The response to this Request is sponsored by Christa Bearry, Legal
Administrative Assistant, ldaho Power Company.
DATED at Boise, ldaho, this 18th day of April 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST TO IDAHO POWER.4
IA A. T'{ILTON
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of April 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST TO IDAHO POWER
upon the following named parties by the method indicated below, and addressed to the
following:
Gommission Staff
Weldon B. Stutzman
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Industrial Gustomerc of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 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 IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUESTTO IDAHO POWER- 5