20200928ICIP 9-12 to IPC.pdf

Peter J. Richardson tSB # 3195
Grcgory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,ldaho 83702
Telephone: [phone] I
neter{Drichardsonadanr s.com
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Attorneys for the Industrial Customers of ldaho Power
BETORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
REVISE THE ENERGY EFFICIENCY
RIDER, TARIFF 9I.
CASE NO.IPC.E-20.33
SECOND PRODUCTION REQUEST
OF THE INDUSTRIAL 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 Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considcrcd 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:
(2OB) 342- 1700; Fax: (208) 384- l5 I I ; [e-mail]
For each item, please indicate the narne of the person(s) preparing the answers, along
SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER -- IPC-E-20-33
I
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REOUEST FOR PROpUCTION NO. 9:
On page 4 of the Application states;
Notably, participation in the Company's Commercial and industrial Custom
Proiect option has increased, with the Company achieving the same kkYh savings
level in the six months ending June 2020, as Jbr all of 2019.
For the last three years please provide a list of the dollar amount of payments to each
Commercial and/or Industrial Custom Project (without customer specific identifying
information, if possible) and the assumed energy saving for each Custom Project.
REQUEST FOR PROpUCTT0N N0. t0:
What is the assumed level of annual Utility Costs for the Custom Projects used in the
forecasts of annual for DSM year 2020 and the low and high forecast for DSM year
2A2t',l
REOUEST FOR PRODUCTION NO. I I:
ln Case IPC-E-2O-15 Company witness Goralskistates:
Changes to the cost-eflbctiveness test for energ/ efJiciency will be carried out
over the 2020 program year to synchronize with the Company's annual planning
cycle. The company is in the process of implementing the (/cr as the primary
perspective as it moves into the 2021 IRP planning cycle. [Goralski, Direct
Testimony, IPC-E-20-15, at p. l6.l
In Response #8 to the Industrial Customers First Production Request to Company stated;
For the 2020 DSM progrom year, cosr-effectiveness reparting will be based on
the DSM avoided costs from the 2017 IRP. Because the 20tg IRP was not
aclonwledged before the Company started preparing the 2021 program year in
SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-20-33
PAGE 2
August 2020, Idaho Power will use the 2017 DSM avoided costs to calculate 2021
pr o gram year cos t- elfec tiven es s.
Does this mean Company witness Goralki's statement in his Direct Testimony is no
longer valid? If so, will it be withdrawn? Does this also mean the avoided costs used for
the UTC cost effeteness tests for the 2020 and 2021 DSM progr.rm years will based on
estimates of avoided costs that will be three and four years old?
REOUEST FOR PRODUCTION NO. 12:
ln response to ICIP Request for Production No. 8, the Company states that, "Idaho Power
uses the DSM avoided costs, discount rate, and escalation rate from the most recently
acknowledged IRP at the time the assumptions were frozen to calculate the cost-effective
ratios." On what authority does the company rely for the use of the most recent acknowledged
IRP for calculating cost-effective rations, please provide copies and citations?
DATED this 29th day of September,2020
J.ISB #319s
Industrial Customers of ldaho Power
SECOND PRODUCTION REQUEST OF THE TNDUSTRIAL CUSTOMERS OF IDAHO
POWER
rPC-E-20-33
PAGE 3
CERTIF'ICATE OF SERVICE
I HEREBY CERTIFY that on the 29e of September 2O2A,a true and correct copy of the
within and foregoing SECOND PRODUCTION REQUEST oF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER in Docket No. IPC-E-20-33 was
served, pursuant to Commission Order No. 34781, exclusively via electronic mail to:
Idaho Public Utilities Commission
Jan Nuriyuki, Secretary
Ed Jewell, Deputy Attorney General
ian.nu riyuki (Af uc. idaho. eov
Edwardjewel l@uuc. idgho. qov
Idaho Power Company
lnordstrom@ idahopower.com
dockets@ i dahoDower.corn
caschenbrenner(rlidahopower.com
By:
Peter
Attorney for the Industrial Customers of Idaho Power
SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER
IPC-E-20-33
PAGE 4