20230928Staff 26-29 to IPC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
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 )CASE NO.IPC-E-23-10
COMPANY'S APPLICATION FOR A )DETERMINATION OF 2022 DEMAND-SIDE )FOURTH PRODUCTION
MANAGEMENT EXPENSES AS )REQUESTOF THE
PRUDENTLY INCURRED )COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,OCTOBER 19,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 1 SEPTEMBER 28,2023
RECEIVED
2023 September 28 1:41 PM
IDAHO PUBLIC
UTILITIES COMMISSION
REQUESTNO.26:In its May 2022 Energy Efficiency AdvisoryGroup meeting,the
Company provided an overview of a planned Online Marketplace.Please provide an update on
the status of any associated expenses and provide an estimated timeline of the marketplace
model.Please also provide any associated expenses from 2022 for this project.
REQUESTNO.27:In its Response to Production Request No.21,the Company
indicated that it has requested responses to recommendation Nos.1,2,4,5,6,8,and 9.Please
explain why recommendationNos.3 and 7 were not included in the Company's request.
REQUESTNO.28:In its Response to Production Request No.21,the Company states
that it has worked with Northwest Energy Efficiency Alliance "(NEEA")"on an alternate
method for quantifyingcode savings.Please describe the alternate method.
REQUESTNO.29:In its Response to Production Request No.23,NEEA describes an
assessment of its state energy code evaluation methods to be conducted in 2024.Please provide
a scope of work,a timeline,and completion date for the assessment.
DATED at Boise,Idaho,this day of September 2023.
Michael Duval
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.10csjjt prod req 4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBER 28,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OF SEPTEMBER 2023,
SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-10,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA D NORDSTROM ZACK THOMPSON
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
dockets idaho ower.com
ED JEWELL WIL GEHL
DEPUTY CITY ATTORNEY ENERGY PROGRAM MGR
BOISE CITY ATTORNEY'S OFFICE BOISE CITY DEPT PUBLIC WORKS
150 N CAPITOL BLVD.150 N CAPITOL BLVD.
PO BOX 500 PO BOX 500
BOISE ID 83701-0500 BOISE ID 83701-0500
E-MAIL:[e-mail] E-MAIL:wgehl citvofboise.org
ejewell citvofboise.org
dearly cityofboise.org
SECRETARY
CERTIFICATE OF SERVICE