20161109Staff 35 to IPC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
I ECEI JED
::GI G !!0\1 -9 P 1 2: 21
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR DEFERRAL )
AND RECOVERY COSTS ASSOCIATED WITH )
PARTICIPATION IN AN ENERGY )
IMBALANCE MARKET )
)
) ___________________ )
CASE NO. IPC-E-16-19
THIRD PRODUCTION .
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, request that Idaho Power Company (Company;
Idaho Power) provide the following documents and information as soon as possible, by
WEDNESDAY, NOVEMBER 30, 2016.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Responses pursuant to Commission Rules of
Procedure must include the name and phone number of the person preparing the document, and
the name, location and phone number of the record holder and if different the witness who can
sponsor the answer at hearing if need be. ID APA 31.01.01 .228.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 1 NOVEMBER 9, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 35: Please explain how the Company's participation in the EIM could
directly and indirectly impact demand response program operations, participation, costs and
benefits. Furthermore, please explain how participation in the EIM could require modifications
to the implementation guidelines set forth in the Demand Response Programs Settlement
Agreement (Case No. IPC-E-13-14).
Dated at Boise, Idaho, this 1,-t-;:-day of November 2016.
Technical Staff: Matt Elam/35
i:umisc:prodreq/ipce l 6. I 9bkme prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER
r arpen
Deputy Attorney General
2 NOVEMBER 9, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9THDAY OF NOVEMBER 2016,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-16-19,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]
[e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
223 N 6TH ST STE 317
PO BOX 1731
BOISE ID 83701
E-mail: [e-mail]
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83 702
E-mail: [e-mail]
SECR~~-
CERTIFICATE OF SERVICE