20190225ICIP 1-6 to IPC.pdf

Peter J. Richardson ISB # 3 195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
gre g@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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lii;i f [ri i S Pi'i 3: 33
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
REVISE THE ENERGY EFFICIENCY
RIDER, TARIFF 91.
CASE NO. IPC-E-I9.06
FIRST PRODUCTION REQUEST OF
THE TNDUSTRIAL CUSTOMERS OF
IDAHO POWER
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Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The lndustrial Customers of Idaho Power ("ICIP") 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 additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy 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
[phone]; Fax: (208) 384-l5l l; [e-mail]
For each item, please indicate the name of the person(s) preparing the answers, along
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with the job title of such person(s) and the witness at hearing who can sponsor the answer
REOUEST FOR PRODUCTION NO. 1
Please provide all discovery responses related to this docket, whether'formal' or
informal and all exchanges of information along with workpapers and attachments
provided IPUC Staff and/or other entities, whether or not they are aParty
REOUEST FOR PRODUCTION NO. 2
Reference the table on page 2 of the Application. For each row with case
numbers please provide:
A) The annual Rider revenue collected at that percentage level.
B) The annual expenditures coresponding to the time period referenced in
"A."
C) The beginning and ending balance in the Rider Account for each time
period.
D) The amount of Rider funds transferred to, or from, the PCA.
REOUEST FOR PRODUCTION NO. 3
On page 3 of the Application is a reference to "recently completed forecast Rider
balances for 2019 through 2021 ..." Please provide all results, workpapers in electronic
format with functioning formulae, input and output data with sources, and detail all
assumptions.
REQUEST FOR PRODUCTION NO. 4
For each year,2002 through 2017 , please identify, and provide copies of, the
source (including dates) of the data used to measure the cost/benefit analysis for each
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-19-06
PAGE 2
program.
REQUES
Attachment 2 to the Application notes that the Northwest Energy Efficiency
Alliance ("NEEA") contract with Idaho Power ends in June 2020. What is the current
level of payment to NEEA? What is the expected level of payment to NEEA assuming
the contract is renewedin2020? Please explain how ldaho Power's funding of NEEA is
determined to be cost effective, or not. Is it anticipated that the reasons for the reduction
in the EE Rider will also impact in any way the cost effectiveness evaluation of Idaho
Power's participation in NEEA, please explain?
REOUEST FOR PRODUCTION NO. 6
Attachment I (confidential) to the Application indicates that the cost of the
Company's conservation programs (both incentives and expenses) supported by the Rider
are expected to decrease by a stated sum between 2002 and 2017 .
A) Please explain in detail the reason for this expected decrease in expenditures.
B) Does the Company also expect to achieve different levels of kW and/or kWh
savings as a result of these lower expenditures? Please detail expected changes.
C) Does the Company plan to eliminate any specific programs as a result of the
reduced expenditures? Please identify each such program and explain the reason for its
elimination. Please also identifu any reductions in existing programs that will result from
the reduced expenditures and explain the reason for the planned reductions.
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-19-06
PAGE 3
DATED this 25th day of February 2019
Richardson Adams, PLLC
Peter J.
lndustrial Customers of ldaho Power
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-19-06
PAGE 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of February 2019, a true and correct copy of the
foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in Docket No. IPC-E-19-06 was served electronically and U.S. Mail to:
Diane Hanian (Hand Delivered)
Commission Secretary
Idaho Public Utilities Commission
472 W est Washington Street
Boise, Idaho 83702
diane.holt@puc. idahq. sov
Connie Aschenbrenner
Idaho Power Company
l22l West Idaho Street
Boise, Idaho 83702
caschenbrenner@idahopower. com
Karl T. Klein
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, Idaho 83702
[e-mail]. gov
Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
lnordstrom@idahopower. som
dockets@idahopower. com
Benjamin Otto
Idaho Conservation League
710 N 6th Street
Boise, tdaho 83702
botto@idahoconservation. ors
Kandi Walters
Administrative Assistant
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-19-06
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