20240503IPC to Staff Response to First PR.pdf

IDAW
ORNPOWER.
An IDACORP Company
RECEIVED
2024 May 3, 2:15PM
MEGAN GOICOECHEAALLEN IDAHO PUBLIC
Corporate Counsel UTILITIES COMMISSION
mgoicoecheaallen(D_idahopower.com
May 3, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-24-11
In the Matter of the Application of Idaho Power Company for a Determination
of 2023 Demand-Side Management Expenses as Prudently Incurred
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Response to the First
Production Request of the Commission Staff in the above-entitled matter.
The confidential attachments will be sent in a separate email to the parties who sign
the Protective Agreement.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Megan Goicoechea Allen
MGA:cd
Enclosures
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
CASE NO. IPC-E-24-11
Idaho Power Company's Application for a Determination of 2023 Demand-Side
Management Expenses as Prudently Incurred
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachment No(s). 4 and 6 to Idaho Power Company's Response to the
First Production Request of the Commission Staff, dated May 3, 2024, may contain
information that Idaho Power Company and a third party claims is a confidential trade
secrets and business records of a private enterprise required by law to be submitted to
or inspected by a public agency as described in Idaho Code § 74-101 , et seq., and/or §
48-801, et seq. As such, it is protected from public disclosure and exempt from public
inspection, examination, or copying.
DATED this Friday, May 3, 2024,
Akr T i
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Megan Goicoechea Allen
Counsel for Idaho Power Company

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaal len(o-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-24-11
DETERMINATION OF 2023 DEMAND-SIDE )
MANAGEMENT EXPENSES AS ) IDAHO POWER COMPANY'S
PRUDENTLY INCURRED. ) RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated April 12, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1

STAFF REQUEST FOR PRODUCTION NO. 1: Please provide the monthly
interest calculations for the balance in the Demand Side Management ("DSM") tariff rider
account for 2023.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 1:
Please see the attachment provided for this response.
The response to this Request is sponsored by Robert Everett, Finance Team
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2

STAFF REQUEST FOR PRODUCTION NO. 2: Please provide the DSM tariff rider
revenue by month and by customer class for 2023.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 2:
The table below contains the 2023 Idaho Power Energy Efficiency Rider funding
by rate class:
2023
Rate Class Tariff Schedule Rider Funding
Residential 01, 03, 05, 06 $ 16,438,416
Commercial 07, 08, 09 $ 8,845,599
Industrial 19, 26, 29, 30, 32 $ 5,146,818
Irrigation 24 $ 4,098,757
Lighting 15, 40, 41, 42 $ 146,410
Total $ 34,675,999
The response to this Request is sponsored by Robert Everett, Finance Team
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3

STAFF REQUEST FOR PRODUCTION NO. 3: Please provide the cost-
effectiveness workpapers and calculations for each energy efficiency and demand
response program in 2023 in Excel format, with all formulas intact.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 3:
Please see the attachment provided for this response.
In preparing the workpapers for this response, Idaho Power discovered an error in
the formula used to calculate the $29.93 per kW year for the A/C Cool Credit demand
response program that is displayed on page 33 of Thompson's Direct Testimony, page
34 of the Annual Report, and page 13 of Supplement 1 to the Company's Demand-Side
Management 2023 Report. The total expenses in 2023 for the A/C Cool Credit program
were $1 ,987,623 and would have remained the same had the program been fully used
for the maximum 60 hours. However, the program incentives were inadvertently omitted
from the formula used in the calculation. As a result, the updated program cost is
calculated to be $44.53 per kW year opposed to the $29.93 per kW year initially reported.
This also results in an updated total demand response portfolio value of $41.97 per kW
year compared to the $40.80 per kW year initially reported, which is still under the 2023
demand response avoided cost threshold of $84.57 per kW year and therefore remains
cost-effective. The Commercial & Industrial Flex Peak and Irrigation Peak Rewards
Program's dollar per kW year values were not impacted by the formula error.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF -4

STAFF REQUEST FOR PRODUCTION NO. 4: Please provide a listing of all legal
and consulting fees, including, but not limited to Evaluation, Measurement and
Verification ("EM&V"), charged to the Idaho DSM tariff rider during 2023.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 4:
Please see the Confidential attachment provided for this response.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program & Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5

STAFF REQUEST FOR PRODUCTION NO. 5: Please provide the amount of labor
expense charged to the DSM tariff rider for 2023. Please also include the number of Full
Time Equivalents funded by the rider. Please also provide the general wage adjustment
percentage for non-union personnel approved by the Compensation Committee of the
Board of Directors for each year.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 5:
The table below contains the 2023 Idaho Power Demand-Side Management labor
expense, full-time equivalent employees, and general wage adjustment percentage:
Year Idaho Rider Labor Expense FTEs General Wage Adjustment
2023 $3,449,976 24.07 6%
The response to this Request is sponsored by Robert Everett, Finance Team
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6

STAFF REQUEST FOR PRODUCTION NO. 6: Please provide a current
organizational chart by title and name showing all Idaho Power and contract employees
who charge time to the DSM rider. Please include complete job descriptions, required
qualifications, salary ranges, bonus opportunities, and total compensation ranges,
including benefits, for all employees identified in this request.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 6:
Please see the Confidential Attachments 1 and 2 provided for this response.
The response to this Request is sponsored by April Powell, Total Rewards
Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7

STAFF REQUEST FOR PRODUCTION NO. 7: Please provide copies of all
internal audit reports referencing any of the Company's DSM expenses and processes
for 2023. If an audit was completed and no reports were issued, please provide the date
and scope of the audit and all internal auditor workpapers.
RESPONSE TO STAFFS REQUEST FOR PRODUCTION NO. 7:
Audit Services performs audits of internal controls related to the Company's DSM
expenses and processes on a rotational basis as part of complying with Sarbanes-Oxley
("SOX") requirements. The related SOX process is Regulatory DSM Liability ("RDSU).
The RDSL process was not subject to audit in 2023.
The response to this Request is sponsored by Sonse Sutezzo, Audit Manager,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8

STAFF REQUEST FOR PRODUCTION NO. 8: Please provide a list of market
transformation and marketing activities offered in 2023 by the Northwest Energy
Efficiency Alliance ("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; and
b. Please provide a financial comparison of those activities. If applicable,
please identify how much the Company was reimbursed from NEEA for
those marketing activities.
RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 8:
The Company did not opt out of any market transformation or marketing activities
offered by NEEA in 2023.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program and Customer Analysis Leader, Idaho Power Company.
Respectfully submitted this V day of May 2024.
Awrx T I'
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MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this V day of May 2024, 1 served a true and correct
copy of the within and foregoing Idaho Power Company's Response to the First
Production Request of the Commission Staff upon the following named parties by the
method indicated below, and addressed to the following:
Adam Triplett Hand Delivered
Deputy Attorneys General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
P.O. Box 83720 FAX
Boise, ID 83720-0074 X Email
adam.triplett(a),puc.idaho.gov
a4lw
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10