20210420ICIP 1-4 to IPC.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone : [phone]
Fax: [phone]
petcr@richardsonandolea ry.com
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMINATION
OF 2O2O DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED
., ' ,' ,', zJ PF{ 3: 58
Attomeys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO.IPC-E.21.04
FIRST PRODUCTION REQUEST OF
THE TNDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
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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 ldaho Power (*ICIP") 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 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,
dreadi n g((Dm indspri ng.com.
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.
REOUEST FOR PRODUCTION NO. I
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 rosponses to informal as well as formal
requests and oral as well as written requests.
REOUEST FOR PRODUCTION NO. 2
The Company's 2020 Annual Demand-Side Management Report, Supplement l, Cost
Effectiveness, page 4 states; "Because of this timing, updated DSM alternate costs based on the
2017 IRP were used.for 202 I progrdm planning and will be used to evaluate the 2021 cost
elfectiveness."
a. Does this mean that all the *2021cost-effectiveness" for DSM expenditures will
be evaluated using the Company's cost data that are at least four years old?
b. Have the costs incurrcd by Idaho Power for electrical energy and demand changed
over the past four years? If the answer is in the affirmative please identifr the
extents of such changes explain fully which powcr cost changes have occurred
over this time period.
c. Does the Company believe that the cost-effectiveness of some of their DSM and
DR programs would be different with current power cost estimates? If the answer
is yes please explain fully.
REOUEST FOR PRODUCTION NO.3
In Idaho Power's April 8, 2021 IRPAC meeting the Company indicated that there may be
some significant changes in Idaho Power's forecast of near-term system reliability
(https://docs.idahopower.com/pclfs/AboutUs/PlanninBForFuture/irp/2021/ValmySpecialStudyUpda
First Production Request of the Industrial Customers of Idaho Power
IPC-E-21-04
Page 2
teIRPAC.pdf), Slide l8 of the presentation indicates the'Reliability Hurdle' could be as much as
787 MW in2023 and 862 MW in 2025. Given the magnitude of the Company's identified capacity
deficit inherent in its *Reliability Hurdles" - when will the Company be using this data to design
its demand side management prcgram? Please explain fully whether it would be prudent for the
Company to use this data to design energy and capacity programs for use in its most current DSM
activities.
REOUEST FOR PRODUCTION NO. 4
On page 8 of Company witness Pawel Goralski Direct Testimony states;
Three programs had significant increases in savings in 2020 as compared. to
2019: The Commercial & Industial ("C&1") Program Custom Projects option
experienced a 33 percent increase due to the completion of several large long-
term projects.
Does Idaho Power anticipate any continued increases of this magnitude in the Commercial &
Industrial ("C&f) large custom long-term projects for 2021 or 2022? Please explain fully.
DATED this 20th day of April,zD2l
PLLC
By
J
RICHARDSON ADAMS, PLLC, attorneys for
The Industrial Customers of Idaho Power
First Production Request of the Industrial Customers of [daho Power
IPC-E-21-04
Page 3
CERTIFICATE OF SERVICE
I hereby certifi that on this 20th day of Aprilz0zl copies of the foregoing First
Production Request of the Industrial Customers of Idaho Power were delivered electronically to:
Lisa Nordstom
Regulatory Dockets
Idatrc Power Company
I nordstrom@ idahopower.com
[e-mail]
Jan Noriyuki
Idatro Public Utilities Commission
ian.noriyuki@puc. idaho. gov
Edwad Jewell
Idatro Public Utilities Commission
edward jewell@f uc. idaho. gov
Connie Aschenbrenner
Idaho Power Company
caschenbrenner(A idahopower. com
Adam Lowney
McDowell Rackner Gibson PC
[e-mail]
First Production Request of the Industrial Customers of ldaho Power
IPC-E-21-04
Page 4
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