20200327Staff 1-5 to IPC.pdf

FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 MARCH 27, 2020
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917

Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorneys for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
DETERMINATIN OF 2019 DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
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CASE NO. IPC-E-20-15

FIRST 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,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than FRIDAY,
APRIL 10, 2020.
This Production Request is to be considered as continuing, and Idaho Power 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
RECEIVED
2020 March 27,AM9:44
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 27, 2020
the person preparing the documents. Please also identify 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 spreadsheets and electronic files on CD with formulas intact and enabled.

REQUEST NO. 1: Please provide the cost-effectiveness workpapers and calculations
for each DSM program in 2019 in Excel format, with all formulas intact.

REQUEST NO. 2: Please provide the revenue received (excluding interest) by class and
tariff schedule for the DSM tariff rider in 2019.

REQUEST NO. 3: Please provide the calculation of the interest accrued to the DSM
tariff rider account.

REQUEST NO. 4: For each date during 2019 that demand response programs were
used, please provide the date, the amount of load reduction (by program), the system peak, and
the daily load curves.

REQUEST NO. 5: Please provide the Company's DSM labor expense and DSM full-
time equivalent employees charged to the tariff rider for 2018 and 2019.

DATED at Boise, Idaho, this 27th day of March 2020.

_________________________________
Dayn Hardie
Deputy Attorney General

i:umisc:prodreq/ipce20.15dhbl prod req 1
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF MARCH 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-15, BY E-MAILING A COPY
THEREOF, TO THE FOLLOWING:

LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]

CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]

/s/ Reyna Quintero __
SECRETARY