20200827ICIP 1-8 to IPC.pdf

Peter J. Richardson ISB # 3195
Greg Adams ISB # 7454
RICHARDSON ADAMS, PLLC
5 l5 N. 27th Street
Boise, ldaho $7A2
pC_!Clr.,,{ Ji c harclso naclant s. co n l
';l';li {i I'I i: ll ll t",.i:r) t i] il.t ;i1 J t"(.rl i
IN THE MATTER OF THE
APPLICATTON OF IDAHO POWER
FOR AUTHORITY TO REVISE THE
ENERGY EFFICIENCY RIDER, TARIFF
SCHEDULE 9I.
t.r;:r:;=i?tr*
:ij:iil;iLiG e? PH fu: l+,{
: -:,'.j';'.i ;: LjiSLiij
' r, :i- r Ti :;;:, **&ifo.it*$+S+i
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
CASE NO.IPC.E.2O.33
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the [ndustrial Customers of [daho Power ("lCIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("ldaho
Power" or the "Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplemental responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide onc 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, tdaho 83703,
.!rq,,i :* ,{!_ir_i t.pfli -. , r11.
For each item, please indicate the name of the person(s) preparing the answer(s), along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
First Production Request of the lndustrial Customers of Idaho Power
rPC-E-20-33
Page I
REQUEST FOR PRODUCTTON NO. l:
Please provide copies of all of the company's responses to data requests from the IPUC
Staff (or any other party) in this matter. Please include responses to informal as well as formal
requests and oral as well as written requests.
REQUEST FOR PRODUCTTON NO.2:
Please provide minutes (including copies of all hand-out materials) from the EEAG
meetings referenced in paragraph I I of the Company's application.
REQUEST FOR PRODUCTTON NO.3:
Please provide all internal workpapers and other documents that the company has relied
upon or created to support its requested increase in the EE rider.
R-EQUEST FOR PRODUCTION NO.4:
Please document when the Company first became aware of the need for an increase in the
Energy Efficiency rider and explain in narrative form what steps the company has taken to avoid
the need for such an increase.
REQUEST FOR PRODUCTION NO 5:
lt appears from the table at page 2 of the Company's application that the Energy
Efficiency Rider over cotlected from the ratepayers in the years 2014,2015,2A16,2017 ,2018
(assumed) and 2019. Please explain and document why that trend of overcollections has been
reversed to the tune of requiring an increase in the rider from2.75oh to 3.10%.
REQUEST FOR PRODUCTTON NO.6
Reference the table on page 2 of the Application. For each row with a Rider percentage
associated with a case number please provide:
First Production Request of the Industrial Customers of ldaho Power
rPC-E-20-33
Page 2
A) The annual Rider revenue collected at that percentage level.
B) The annual expenditures corresponding 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.
REQUEST FOR PRODUCTION NO. 7
Page 3 of the Application states, "At the end of July 202A,the Rider balancing account
had an under-collected balance of approximatety $9.1 million and, without adjustment, the Rider
balancing account is estimated to have an under-collected balance of approximately $ l7 million
at the end of2021 based on a low energy efficiency savings case ("low-case") forecast scenario,
and'$22.7 million under-collected under a high energy efficiency savings case ('high-case',)
forecast scenario." Please provide all results, workpapers in electronic format with functioning
formulae, input and output data with sources, and detail all assumptions for the current under-
collection and forecasted under-collection at the end of 2021 . Please provide this for both the
"low-case" and "high case".
REQUEST FOR PRODUCTION NO.8
Page 4 of the Application statcs the Company's long-term forecast will be able ro update
two key inputs; (l) the incorporation of "UTC" cost-effectiveness screening, and (2) the 2021
IRP over the next several months. In Case IPC-E-20-15 Company witness Goralski states,
Changes to the cost-elfectiveness test for energy efficiency will bc carricd out over the
2020 program year to synchronize with the company's annual-planning cycle. The
Company is in the process of implementing the UCT as the primary perspective as it
moves into the 2021 IRP planning cycle. [Goralski, Direct Testimony, tpc]-E-20- 15, at
p.t6.l
First Production Request of the Industrial customers of ldaho power
rPC-E-20-33
Page 3
Will the Company use the Alternative Costs developed/synchronized in the "UTC" cost-
effectiveness test calculations from the yet-to-be-finalized 2019 tRP or the not-yet-developed
2020 IRP in determining EE cost effectiveness? Please explain fully.
Dated this 27th day of August 2020
RICHARDSON ADAMS, PLLC
BY
Peter Richardson, ISB # 3195
Attorneys for the lndustrial Customers
of ldaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 27th of August 202O,a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER in DocKet No. IPC.E.2O.33 WAS
served, pursuant to Commission Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Nuriyuki, Secretary
1 rn nunyrrki-,!.1),r' id4fro glrv
[:ri'r llri lcir i:l I 1i. puc.idaho.uov
ldaho Power Company
l":rq rd..i_trs m(tr, i d a ho po w er. c o rn
docketsr-1t, idilhrlli,s '! ir i,ron i
,.t.,! ilij tl l) t'; r l l' d1 .. i, idaho;'ower conr
By
Peter
Attorney for the Industrial Customers of ldaho Power
First Production Request of the Industrial Customers of ldaho Power
IPC-E-20-33
Page 4