20150310Staff 1-10 to IPC.pdf

KARL T. KLErN ii i: { i: i i'' ' : ' l
DEPUTY ATTORNEY GENERAL ?flI{ }+ s r ",IDAHO PUBLIC UTILITIES COMMISSION .-;;: iiAli IU FI{ 2: B6
PO BOX 83720 i ," ,.
BOISE, IDAHO 83720-0074 il';'lli; 'i jt ,-;, .i. .,i.:.:i,..t:i
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER )
coMPANy'S APPLICATION FOR APPROVAL ) CASE NO. IPC-E-15-03
oF NEW TARTFF SCHEDULES2, A )
COMMERCIAL AND INDUSTRIAL DEMAND- ) rrnsr pRODUCTION
RESPONSE PROGRAM (FLEX PEAK ) nreUEST oF THEPROGRAM). ) COVTMISSION STAFF TO
) IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Company) provide the following documents and information as soon as possible, by
TUESDAY, MARCH 31, 2015.
This Production Request is to be considered as continuing, and the 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identiff the name, job title, location and telephone
number of the record holder.
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 1 MARCH 10, 2015
REQUEST NO. 1: Please provide a detailed cost comparison between EnerNOC's Flex
Peak Management program and the Company's Flex Peak Program showing how the Company
expects to save $600,000 - $900,000 annually by managing the commercial and industrial (CIP)
demand-response program itself. Please indicate if this cost savings comes from reduced
incentive payments to participants, elimination of coaching expense, removal of participant
monitoring equipment, or from some other category. Please provide a detailed explanation of all
cost differences.
REQUEST NO.2: Without hiring additional staff, how does the Company plan to
ensure that participant attrition rates do not cause the Flex Peak program to fall under 35MW?
As part of the response, please explain how the Company will train new participants to provide
accurate and reliable demand reduction under the revised program.
REQUEST NO. 3: In response to the Industrial Customers of Idaho Power's (ICIP's)
Production No. 7, the Company states that 9 out of 25 Flex Peak participants surveyed
commented on the need for and usage of EnerNOC's technology/software for real time data.
Please explain how the Company will assure that customers can continue to participate
effectively without the EnerNOC technology software?
REQUEST NO. 4: Page 5 of Mr. Nesbitt's testimony states that there are: "several
small differences" in the services provided by EnerNOC compared to what the Company will
provide. Please identify and explain these differences.
REQUEST NO. 5: Page 3 of Mr. Nesbitt's testimony reads: "The Program will be
promoted to past C&I demand response program participants...." Does this mean that the
Company will not market the program to customers who have not previously participated? If so,
how does the Company plan to attract new participants to the program if the previous
participants are not sufficient to meet the 35 MW target? Please fully explain.
REQUEST NO. 6: Page 12 of Ms. White's testimony reads: "Idaho Power compared
the [RFP] proposals received to a Company-operated program that served as a benchmark."
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY MARCH 10,2015
Please provide the two proposals and the documents describing the Company-operated program
that served as a benchmark. All three sets of documents should include detailed operational and
cost information.
REQUEST NO. 7: Did the Company consider whether smaller participants (eligible
under the Flex Peak program) would be able to provide accurate and reliable demand reduction
without the "coaching services" that EnerNOC previously provided? See Nesbitt,page 5. Please
explain why or why not.
REQUEST NO. 8: Did the Company ask any potential smaller customers (eligible
under the Flex Peak program) if they would be likely to participate in the program without
equipment that allows them to monitor their load reduction, or access to a website where they
can view their real-time load data? Please explain why or why not.
REQUEST NO. 9: Please provide specific examples detailing the Company's
opportunities to use the Flex Peak program to "cross-market energy efficiency programs." See
Nesbit, page7.
REQUEST NO. 10: Page 8 of Mr. Nesbitt's testimony says that under the Flex Peak
Management program, EnerNOC assumed the risk ("downward financial adjustment") for under-
performance by participants. Mr. Nesbitt further explains that this risk shifts to participants in
the Company-managed Flex Peak program. In response to ICIP Production No. 7, the Company
appears to say that it did not ask past participants in the Flex Peak'Management program if this
change would affect their future participation in the Flex Peak program. Please explain why the
Company did not ask past participants this question. Did the Company ask this question of
potential, smaller participants that are eligible under the Flex Peak program? Please explain why
or why not.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY MARCH IO,2OT5
DATED at Boise, Idaho, this t * day of March 2015.
vl /L
Karl T. Klein
Deputy Attorney General
Technical Staff: Ty Hardin/l-4
Stacey Donohue/S-I0
i:umisc:prodrcq/ipce I 5.3kksdth prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 MARCH IO,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1OTH DAY OF MARCH 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF' THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC.E-15-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail: [e-mail]
dockets@ idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail : oeter@.richardsonadams.com
sre sfarichardsonadams. com
TAMI WHITE
QUENTIN NESBITT
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
qnesbitt@ idahopower. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : [e-mail]
CERTIFICATE OF SERVICE