20240603Staff 33-42 to IPC.pdf

RECEIVED
Monday, June 3, 2024 12:58:10 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
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
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 )
PRUDENTLY INCURRED. ) THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Idaho Power Company("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY,JUNE 244 2024.
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.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JUNE 3, 2024

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.
REQUEST NO. 33: Please explain if the Company is considering increasing the
funding amounts for any CAP agencies.
REQUEST NO. 34: Please explain if the Company is considering any other changes to
the low-income weatherization programs to increase program performance.
REQUEST NO. 35: On Page 10 of the Application, the Company claims that they are
requesting only $3,449,976 in DSM labor to be collected through the Rider. This amount leaves
$175,313 of remaining labor costs that the Company is not charging to the Rider. Please explain
how the Company is paying for the extra $175,313. In the response, please specify if this
amount is being booked below the line/charged to shareholders, recovered through base rates,
or accounted for through other means.
REQUEST NO. 36: For promotional and marketing items in 2023, please answer the
following:
i. Please explain what marketing measures the Company claims energy efficiency
savings on;
ii. Please explain the source and basis the Company used to quantify these savings;
and
iii. Please send copies of all advertisements the Company paid for in 2023, including,
but not limited to, all Sponsorship Packages, and any radio or
magazine/newspaper advertisements.
REQUEST NO. 37: In the Residential New Construction Program PY2022 Evaluation
("Evaluation"), the evaluator describes how it verified that reported model output savings and
tracked savings matched. The Evaluation explains that tracking data for the program is
retrieved from the regional AXIS database, reviewed by Company staff, and entered into the
Company's database. Evaluation at 4. Please explain how kWh savings is calculated or
otherwise determined and input into the AXIS database.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 3, 2024

REQUEST NO. 38: Please provide an example data output from the AXIS system.
REQUEST NO. 39: Please provide a list detailing if and what amount(i.e., number of
months) of billing data is available for each Residential New Construction Rebate issued in
PY2022 at the time the Evaluation was initiated.
REQUEST NO. 40: Please explain if the Company has conducted any internal analysis
of the Residential New Construction Program using billing data from the
incentivized constructions. If yes, please provide analysis. If not, why not?
REQUEST NO. 41: Please provide a timeline for the PY2022 Evaluation showing start
date, important milestones, and end date.
REQUEST NO. 42: Please explain if the REM/Rate modeling documentation supporting
the Residential New Construction Program incentives provides details on what types of upgrades
are being selected to meet energy savings targets. If so, provide a breakdown of upgrade types
selected by participants for the 2022 and 2023 program years.
DATED at Boise, Idaho, this��ay of June 2024.
S
Adam Triplett
Deputy Attorney General
[:\Utility\UMISC\PRDREQ\IPC-E-24-11 PR#3.docx
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JUNE 3, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS� DAY OF JUKE 2024,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-11, 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: caschenbrenner(midahopower.com
m,[e-mail] [e-mail]
I nordstrom amidahopower.com
dockets nidahopower.com
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEYS OFF PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubble0mcityotboise.org
E-MAIL: eiewell(&cityotboise.org
boisecityattorney(cbcityofboise.org
F DIEGO RIVAS KEN ROBINETTE CEO
NW ENERGY COALITION SOUTH CENTRAL COMMUNITY
1101 8TH AVE ACTION PARTNERSHIP
HELENA MT 59601 550 WASINGTON ST SOUTH
E-MAIL: diego(cDnwenergy_org TWIN FALLS ID 83303
E-MAIL: ken(@sccap-id.org
MATTHEW NYKIEL BRAD HEUSINKVELD
IDAHO CONSERVATION LEAGUE IDAHO CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nykieingmail.com E-MAIL:
bheusinkveldaidahoconservation.ors
;'l',", I,�',
PATRICIA JORD N, SECRETARY
CERTIFICATE OF SERVICE