20231025Staff 1-6 to IPC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 MMiâSLON
[phone]
IDAHO BAR NO.10221
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)CASE NO.IPC-E-23-24
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )MODIFICATIONS TO THE COMPANY'S )FIRST PRODUCTION
COMMERCIAL &INDUSTRIAL DEMAND )REQUESTOF THE
RESPONSE PROGRAM,SCHEDULE 82 )COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,NOVEMBER 15,2023.
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 identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY l OCTOBER 25,2023
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.
REQUESTNO.1:For the 2022 program year,please provide a blinded list of Flex
Peak customers detailing the nominated kW for each week of the season,maximum potential
incentive payment,actual payment,their hypothetical compensation under the Company's
proposed incentive structure,and their hypothetical compensation under the Energy Efficiency
AdvisoryGroup ("EEAG")suggested per event basis.
REQUESTNO.2:Please describe any Company surveys or customer communications
with Flex Peak customers leading to the development of this proposal.
REQUESTNO.3:Please provide an estimate of the expected changes to participation
under the proposed incentive structure.
REQUESTNO.4:Please explain any functional differences between the current
incentive adjustment waiver and the proposed performance waiver.
REQUESTNO.5:Please provide a count of participants that can nominate 3 MW or
more of load reduction.
a.Of these participants,how many does the Company expect to nominate all their
load with the proposed advance notification?
b.Please explain how the Company reached this estimation.
REQUESTNO.6:Please explain if the Company considered any incentive structures
other than the proposed structure or the per event structure proposed in the EEAG.
a.For any potential structures,please explain why they were ultimatelynot
proposed by the Company.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 OCTOBER 25,2023
DATED at Boise,Idaho,this day of October 2023.
Adam Triplett
Deputy AttorneyGeneral
i:umisc:prodreq/IPC-E-23-24 PR#l
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 OCTOBER 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF OCTOBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-
24,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]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE