20160509IPC to ICIP 1-4.pdf

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i?,fiCTIVED
2015 f.tAY -9 Pl,l h: l7
LISA D. NORDSTROM
Lead Counsel
May 9, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Case No. IPC-E-16-03
2015 Demand-Side Management Expenses - Idaho Power Company's
Response to the First Production Request of the Industrial Customers of
ldaho Power
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the lndustrial
Customers of ldaho Power.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to the lndustrial Customers of ldaho Power's production requests.
Very truly yours,
An IDACORP Companv
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Lisa D. Nordstrom -
LDN:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom @ id a hopower. com
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2015 DEMAND-
SIDE MANAGEMENT EXPENDITURES
AS PRUDENTLY INCURRED
REC EI VED
i$16 ffiAY -9 PH tr; I 7
il.l ,.,;-; r''LI i-rLlUr;' l.il'l i:S C0iih{lSSlON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. |PC-E-16-03
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of the lndustria! Customers of ldaho Power
dated April 19,2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE ]NDUSTR]AL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 1: Please provide all of the Company's
responses to discovery from all other parties (whether formal or informal) and all future
discovery responses the Company provides in this docket.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: To date, Idaho Power
has not provided any responses to discovery in this case. As a matter of course, copies
of ldaho Power's responses to all parties' discovery requests in this case will be
provided to the lndustrial Customers of ldaho Power.
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 2: Please provide in electronic format the
spreadsheets used to create the following table's included in Connie Aschenbrenner's
Direct Testimony;
A. Table 1;2015 DSM Programs by Sector. . . ., page 4,
B. Table 2; IncrementalAnnual Energy Efficiency 2002-2015, page 6,
C. Table 3; Peak Demand Reduction Capacity 2004-2015, page 7,
D. Table 7; ldaho Energy Efficiency Rider (Jan-Dec-2015), page 16.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see the Excel
file provided on the enclosed CD.
The response to this Request is sponsored by Connie Aschenbrenner, Senior
Regulatory Analyst, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 3: Please provide in electronic format the
spreadsheets used to create Exhibit 1;'2015 ldaho DSM Expenses and Adjustment for
Prudence filing', attached to Connie Aschenbrenner's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see the Exce!
file provided on the enclosed CD.
The response to this Request is sponsored by Connie Aschenbrenner, Senior
Regulatory Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 4: Please provide in electronic format the
spreadsheets used to create Table 2;'2015 program sector summary and energy
usage/savings/demand reduction', found on page 11 of the Demand-Side Management
2015 Annual Report.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the Excel
files provided on the enclosed CD. Attachment 1 is Appendix 3 from the Demand-Side
Management 2015 Annual Report and Attachment 2 is Table 2 in Excel format.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, tdaho, this gth day of May 2016.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
Attorney for ldaho Power Company
CERTIFICATE OF SERVIGE
I HEREBY CERTIFY that on the 9th day of May 2016 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Brandon Karpen
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conseryation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
lndustrial Customerc of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
X Hand Delivered
U.S. Mai!
X U.S. Mail
_Overnight Mail
FAXX Email pete r@ richa rdsonada ms. com
q req@ richardsonadams. com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6