20220401Staff 1-6 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
DETERMINATION OF 2O2I DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURREI)
CASE NO.IPC.E.22.08
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,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
FRTDAY, APRrL 22,2022.
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 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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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APRIL 1,2022
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 energy efficiency and demand response program in202l in Excel format, with all
formulas intact.
REQUEST NO. 2: Please provide the revenue (excluding interest) by class and tariff
schedule for the DSM tariff rider in202l.
REQUEST NO.3: Please provide the calculation of the interest accrued to the DSM
tariff rider account.
REQUEST NO. 4: Please provide a list of market transformation and marketing
activities offered by NEEA that the Company has opted out of for all or part of its service
territory.
a. For those activities, please provide a side-by-side comparison of NEEA marketing
activities and those conducted by the Company.
b. Please provide a financial comparison of those activities. If applicable, please
identiff how much the Company was reimbursed from NEEA for those marketing
activities.
REQUEST NO. 5: For each date during 2021that 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. 6: Please provide the Company's DSM labor expense and DSM full-
time equivalent employees charged to the tariff rider for 2020 and202l.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 1,2022
DATED at Boise, Idaho, this -1DUu, of April 2022.
Riley
Deputy
irumiscprodreq/ipce22.8mlc prod rcq I
FIRST PRODUCTION REQUEST
TO IDAHO POWER
General
3 APRIL 1,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISt DAY OF APRIL 2022, SERVED
THE FOREGOING FrRST PRODUCTION REQUEST OF TIIE COMIITSSION STAFF
TO IDAHO POWER COMPATIY, IN CASE NO. IPC-E-22-08, By E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : [e-mail]
dockets@idahopower. com
CONNIE ASCHENBRENNER
ZACK THOMPSON
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL : [e-mail]
ahompson@idahopower. com
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CERTIFICATE OF SERVICE