20150210ICIP 1-10 to IPC.pdf

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Peter J. Richardson (lSB No. 3195)
Greg Adams (ISB 7454)
Richardson Adams, PLLC
515 N. 27ft Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
greg@ richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY' S APPLICATION FOR
APPROVAL OF NEW TARIFF
SCFIEDULE 82, A COMMERCIAL AND
INDUSTRIAL DEMAND RESPONSE
PROGRAM (FLEX PEAK PROGRAM).
CASE NO. IPC-E-I5-03
FIRST PRODUCTION REQUEST OF
THE TNDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idaho Power ("lCIP") by and through their
attomey of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementary responses additionaldocuments that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physicalcopy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at 6070 Hill Road, Boise, Idaho 83703, Tel:
ICIP First Production Requesst - IPC-E- I 5-03
(208) 3 42-1700; Fax : [phone] I ; [e-mail]
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 at hearing who can sponsor the answer.
If some of the following requests include disclosures deemed by Idaho Power to be
confidential, the ICIP will enter into Idaho Power's standard confidentiality agreement.
REOUEST FOR PRODUCTION NO. I
What is the target amount of MW for participation in the Flex Peak Program? When is
that target expected to be reached?
REOUEST FO PRODUCTION NO.2
The proposed Schedule 82's Availability section provides: "The Company shall have the
right to accept Participants at its sole discretion based on criteriq the Company considers
necessary." It goes on to identifu some of the criteria it may include (total Program capacity,
Facility Site location or amount of capacity at a particular location). Please provide a complete
list of the criteria that will be used in evaluating a potential Participant's acceptance into the Flex
Peak Program.
REOUEST FOR PRODUCTION NO.3
Please provide a copy of the Program Application.
REOUEST FOR PRODUCTION NO. 4
The Company's Application at page 3 provides: "ldaho Power considers demand
response a committed resource and 390 MW (including the C&l program) of demand response
will be included in each portfolio that is analyzed as part of the 2015 Integrated Resource
Planning Process. " Mr. Nesbitt, at page 9 of his direct testimony is asked about the risk of
actual load reduction differing from nominated levels. [n response he states: *lnitially the
ICIP First Production Request- IPC-E-15-03
Company plans to mitigate the uncertainty by including most, but not all of the total Nominated
kW into its forecast of available demqnd response resources. " Please reconcile the two
statements and also identify the amount of Nominated kW that will be removed from its load
forecasts by year and kW level.
REOUEST FOR PROpUCTION NO. s
Initially the Flex Peak Program had a target of 50 MW. It was subsequently reduced to
between 20 and 35 MW. What will the target for this program be going forward?
REOUEST FOR PRODUCTION NO. 6
The Company's Application at page 4 provides: "The Company solicited stakeholder
preferences and support from its Energt Efficiency Advisory Group ('EEAG) on Friday,
January 9, 2015, for either renewing the contract with the third-party administrator or having
the Company administer the program. As described more fully in Ms. ll/hite's testimony, the
majority of EEAG members appeared to be cautiously supportive of an ldaho Power-managed
progrqm; however, one EEAG member expressed a neutral position and another EEAG member
recommended the Company retain EnerNOC, lnc. as the third-party manager of the Program."
Please provide the minutes and presentation material of the EEAG webinar on January 9,2015.
REOUEST FOR PRODUCTION NO. 7
Mr. Nesbitt's Direct Testimony at page 5 provides: "ln anticipation of possibly
administering the program internally, the Company informally surveyed 25 customers that
recently participated in the third-party managed FlexPeak Management program and asked
them how they might respond to a change in the way the progrom wos designed and managed.
The responses generally indicated those customers would likely participate even if the program
changed and they were not provided with the same monitoring and coaching services that
ICIP First Production Request - IPC-E-15-03
EnerNOC provided. " Please provide all documents relating to this survey including questions,
responses, noteso reports, and internal emails that the Company has pertaining to the survey.
REOUEST FOR PRODUCTION NO. 8
Mr. Nesbitt's Direct Testimony at page 8 provides: "Additionally, an ldaho Power-
managed program may provide an opportunityfor smaller customers to participate -- those who
may not have been accepted under a third-party aggregator model. " Please provide the customer
size restriction used by EnerNOC and any proposed size limit that will be used by Idaho Power.
How many additional kW does the Company assume will be available for the internally-
managed program?
REOUEST FOR PRODUCTION NO. 9
Please provide copies of all material provided to the Commission Staff regarding the
Company's application that were provided other than through formal discovery, both prior to,
and after, the filing of the Application.
REOUEST FOR PRODUCTION NO. TO
Please provide discovery responses provided to all other parties in this Docket.
DATED this l0th day of February 2015.
Richardson Adams,PLLC
r.
Peter J. Richardson
Industrial Customers of Idaho Power
ICIP First Production Request - IPC-E-15-03
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Oth day of February, 2015, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER, in Docket No. IPC-E-15-03 was
served as indicated below to:
Ms. Jean Jewell X- Hand Delivery
Commission Secretary _ U.S. Mail, postage pre-paid
Idaho Public Utilities Commission _ Facsimile
P O Box 83720 X Electronic Mail
Boise lD 83720-0074
Lisa D. Nordstrom X Hand Delivery
Idaho Power Company _ U.S. Mail, postage pre-paid
1221 West Idaho Street _ Facsimile
Boise,Idaho 83707-0070 X Electronic Mail
lnordstrom@ idahopower. com
[e-mail]
Tami White
Quentin Nesbitt _X Hand Deliver
Idaho Power Company _U.S. Mail, postage pre-paid
1221 West Idatro Street _Facsimile
Boise,Idaho 83702 X Electronic Mail
twhite@ idahopower. com
qnessbitt@ idahopower. com
Q,, ir\y',$,,
Nina Curtis
Administrative Assistant
ICIP First Production Request - IPC-E-I543