20170615IPC to ICIP 1-6.pdf

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An loAcoRP company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
June 15,2017
VIA HAND DELIVERY
,:".-l
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
ii:
Re Case No. IPC-E-17-03
2016 Demand-Side Management Expenses - ldaho Power Company's
Response to the First Production Request of the Industrial Customers of
ldaho Power
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an origina! and three (3) copies of
Idaho Power Company's Response to the First Production Request of the lndustrial
Customers of ldaho Power.
Also enclosed are four (4) copies of non-confidential disks containing information
responsive to Staffs production requests.
Very truly yours,
O-"fu,/(/(
Lisa D. Nordstrom
LDN:kkt
Enclosures
PO. 8ox 70 (83707)
1221 W. ldaho 5t.
Boise, lD 83702
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
,( ti
lnordstro .com
Attomey for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2016 DEMAND-
SI DE MANAGEMENT EXPENDITURES
AS PRUDENTLY INCURRED
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CASE NO. |PC-E-17-03
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compatry"), and in
response to the First Production Request of the Industrial Customers of ldaho Power
dated May 26,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUGTION NO. 1: Please provide all of the Company's
discovery responses to all other parties that have provided and any future discovery
responses the Company will provide in this docket.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: ldaho Powe/s
responses to the ldaho Public Utilities Commission Staffs First and Second Production
Requests were provided to the lndustrial Customerc of ldaho Power on Apri! 27, 2017,
and June 9, 2017, respectively. As a matter of cource, copies of ldaho Powe/s
responses to all parties' discovery requests in this case will be provided to the lndustrial
Customerc of ldaho Power.
The response to this Request is sponsored by Kimberly Towell, Executive
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 Aschenbrenne/s
Direct Testimony;
A. Table 1;2016 DSM Programs by Sector . . . ., page 4,
B. Table 2; lncrementalAnnual Energy Efficiency 2002-2016, page 6,
C. Table 3; Peak Demand Reduction Capacity 2004-2016, page 8,
D. Table 4; Annual lncremental Energy Efficiency ....2002-2016, page 9,
E. Table 5; Annual Cumulative Energy Efficiency ....2002-2016, page 10,
F. Table 6; ldaho Energy Efficiency Rider (Jan-Dec-2016), page 14.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: PIease seE thE
spreadsheet provided on the enclosed CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho 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;'2016 ldaho DSM Expenses and Adjustment for
Prudence filing', attached to Connie Aschenbrenne/s Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see the
spreadsheet provided on the enclosed CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, 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;'2016 program sector summary and energy
usage/savings/demand reduction', found on page 10 of the Demand-Side Management
2016 Annual Report.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: PIease see the
spreadsheet provided on the enclosed CD. The data sources that support Table 2 are
primarily stored in a relationship database management system that is accessed
through reporting processes, SQL queries, and analytical software such as SAS@ or
other programming languages as needed for reporting and data extraction specific to
the table criteria.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 5: Please provide in electronic format the
spreadsheets used to create Table 6; 'Cost-effectiveness summary by program', found
on page 27 of the Demand-Side Management 2016 Annual Report.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the
attachment provided in the Company's response to Staffs Request No. 5.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST FOR PRODUCTION NO. 6: On page 8 of the Demand-Side
Management 2016 Annual Report it states,
Also in 2016, the new Twin Falls Operation Center was
constructed to replace the 1951-built center used to house
the operations staff. The design incorporates energy-efficient
lighting, heating and cooling, daylight harvesting, and a
rooftop solar affay.
Please provide the details for the rooftop solar affay installed on the new
Twin Falls Operation Center. Please include the size, type of panels, cost to
install, etc.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The roof top solar
installed at the Company's Twin Fa!!s Operations Center is a S0-kilowatt system utilizing
a series of 320 Watt photovoltaic panels supported by one inverter. The costs
associated with the rooftop solar anay are not included in the Company's request for a
prudency determination in this docket and are therefore outside the scope.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 15h day of June 2017.
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15s day of June 2017 I served a true and
conect 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:
Gommission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 8372O-OOT 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Gomm unity Action Partnership
Association of Idaho
Brad M. Purdy
Attomey at Law
2019 North 17h Street
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Perching Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 4r'-107
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Executive Assistant
IDAHO POWER COMPANYS RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER.g