20231130Staff 7-12 to IPC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION Û$
PO BOX 83720
BOISE,IDAHO 83720-0074 c:
[phone]
IDAHO BAR NO.10221
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for 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 )SECOND 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 throughits 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
THURSDAY,DECEMBER 21,2023.
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
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY l NOVEMBER 30,2023
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.7:Please describe the maximum possible advanced notice participants
can receive under the advance notification option.Please describe how the Company will
determine this lead time when evaluating potential participants.
REQUESTNO.8:Please describe what additional risks the advance notification
presents in terms of the reliabilityof the associated load reduction.Please describe what options
the Company would consider as part of its case-by-case evaluation to mitigate these risks.
REQUESTNO.9:Please explain if the Company considered a different incentive
structure for the proposed advanced notification option.If so,please provide the details and
documentation.
REQUESTNO.10:Please explain any other criteria and metrics the Company will
consider when evaluating potential advance notification option participants.
REQUESTNO.11:For each participant listed in Attachment 1 to the Company's
response to Staff Production Request No.1,please provide the nominated and actual load
reduction for each event called in the 2022 demand response season.
REQUESTNO.12:The data provided in response to Production Request No.1
suggests that the majority of participants do not adjust their nominations on a weekly basis.
Please explain how the Company encourages participants to activelymanage their nomination
and load reduction performance.
DATED at Boise,Idaho,this 1 0 day of November 2023.
Adam Triplett
Deputy Attorney General
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 30,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF NOVEMBER 2023,
SERVED THE FOREGOING SECOND 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]
Ida Elmasian
CERTIFICATE OF SERVICE