20241023IPC to Staff 1-6.pdf

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RECEIVED
Wednesday, October 23,2024
MEGAN GOICOECHEA ALLEN IDAHO PUBLIC
Corporate Counsel UTILITIES COMMISSION
mgoicoecheaallenC�idahopower.com
October 23, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-24-39
Idaho Power Company's Tariff Advice In Compliance with Order No. 36042
Related to Changes to Schedule 79; Tariff Advice No. IPC-E-TAE-24-03
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-referenced matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Enclosure
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

LISA D. NORDSTROM (ISB No. 5733)
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]
Inordstrom(a�idahopower.com
mgoicoecheaallen(a)idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S TARIFF ADVICE IN ) CASE NO. IPC-E-24-39
COMPLIANCE WITH ORDER NO. 36042 )
RELATED TO CHANGES TO SCHEDULE ) IDAHO POWER COMPANY'S
79; TARIFF ADVICE NO. IPC-TAE-24-03 ) RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER
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 October 9, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 1

REQUEST FOR PRODUCTION NO. 1: Please provide the initial estimate for the
following: (1) the number of eligible homes; (2) the number of homes that have
participated to date; (3) number of opt outs to date; (4) remaining pool of homes eligible;
and (5) the total spend for the current reweatherization program.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
1. The initial number of eligible homes for re-weatherization was estimated to be
around 1,000. To arrive at the initial estimate, the Company compiled a list of
homes that had been weatherized in the prior 14 years that had not received the
HVAC measure, and also gathered information from Community Action
Partnership Association of Idaho and Community Action Partnership ("CAP")
agencies. In 3-year increments, starting with homes that had been weatherized
between 12-14 years prior with no HVAC upgrades, Idaho Power filtered out
inactive accounts from the original list and sent that list to the CAP agencies for
review. The CAP agencies then further filtered the lists by removing homes that
had received HVAC upgrades from other funding sources and/or homes that were
no longer eligible due to occupancy and income changes or that they were unable
to contact.
2. To date, 39 homes have been re-weatherized —30 in 2023 and nine so far in 2024.
3. Of the customers contacted for re-weatherization, no known customers have opted
out to receiving the upgrades, although some may not have responded. The CAP
agencies actively manage the lists and do not supply the response rates to Idaho
Power.
4. Idaho Power does not maintain a list of eligible homes. As explained in the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 2

response to subpart 1, the initial estimation of 1,000 homes was an estimate based
on best information at the time. The Company is aware the CAP agencies have
reached out to most of the customers eligible for re-weatherization HVAC
upgrades from the original lists (minus those that were filtered out due to the
reasons listed above) and that re-weatherization has been completed for the
eligible homes that responded.
5. To date, $476,211 has been spent on re-weatherization projects ($358,306 in 2023
and $117,905 so far in 2024).
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program and Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 3

REQUEST FOR PRODUCTION NO. 2: Please provide an estimate for the
number of homes eligible for proposed expansion, the total spend, and delivery timeline
for the expanded HVAC reweatherization option. Please separate the estimated pool by
homes that were eligible under the previous eligibility requirements and homes eligible
under only the proposed expanded option.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Idaho Power has not
calculated an estimate of the number of homes that will be eligible for the "expanded"
option, however the list would include the original list of homes available for HVAC
upgrades that did not receive water heaters during the first re-weatherization. While
HVAC installments increased around 2015, the installation of water heaters did not. The
pool for electric water heaters should be higher than what would be eligible for the HVAC
upgrades alone. For example, in 2011 there were 37 active accounts that had not
originally received HVAC upgrades through the State Weatherization Assistance
Program ("WAP"). Of those 37, 25 did not receive water heaters at initial weatherization
and could be candidates for new water heaters.
Idaho Power does not have a projected spend for these upgrades but as with the
original re-weatherization proposal, it would be an amount not to exceed the remaining
carryover funds. As with the HVAC re-weatherization, it is expected the funds would be
available through the end of 2025, at which time stakeholders, including Commission
Staff, would reconvene to determine if there is still a need or desire to continue with the
pilot.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program and Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER -4

REQUEST FOR PRODUCTION NO. 3: Please describe the risk of CAP agencies
transferring funds before there has been an opportunity to spend them in the allocated
region.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The CAP agencies would
only transfer funds they do not intend to use. The incentive to transfer funds to a CAP
agency that may be able to weatherize additional homes would be to serve low
income/special needs people regardless of the CAP agency's regional service area.
Weatherization Managers at the CAP agencies update their production schedules
throughout the year and would know where they stand on spending their budget for the
year. At this point, they could propose the transfer of funds early in the fourth quarter of
each year with the purpose of providing enough time for the receiving CAP agency to
coordinate services before year end. The Idaho Department of Health and Welfare and
Weatherization Managers meet quarterly and could share progress on their production
schedules and estimate any need for potential Weatherization Assistance for Qualified
Customers ("WAQC") funds transfers throughout the year. The Idaho State WAP allows
funds to be repositioned where they can be fully utilized if needed. The option to move
funds provides the flexibility to address the demand for services where they are needed.
In light of the above-described process, the Company believes the potential risk of funds
being transferred where they otherwise could have been spent in the allocated region is
mitigated.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program and Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 5

REQUEST FOR PRODUCTION NO. 4: Please describe the metrics the Company
will use to monitor the average annual cost per dwelling relative to the annual DOE
average job cap.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The annual average cost
per home is calculated by dividing the number of homes by the production costs of those
homes, thereby excluding administrative costs in the average. These costs are provided
by the CAP agencies on each invoice, along with a current annual average, so the
Company has ongoing visibility into the calculated average annual cost per dwelling.
Going forward, this average would be monitored against the annual Department of Energy
("DOE") average job cap.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program and Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 6

REQUEST FOR PRODUCTION NO. 5: Please explain what options and other
actions the Company could consider in the event that the average annual cost per
dwelling deviates significantly from the annual DOE average job cap.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Total spending,
production costs, number of homes weatherized, and annual running averages are
communicated between Idaho Power and CAP agency Weatherization Managers
throughout the year. Each invoice submitted for payment has space to report the year-to-
date average job cost. Weatherization Managers plan their production throughout the
year and can schedule higher cost jobs with lower cost jobs to decrease or increase their
running average. They are also able to increase or decrease leveraging percentages
between different funding sources and WAQC funds per job.
The planned average can deviate from the actual average at the end of the year
as some scheduled jobs may not ultimately be weatherized for several reasons. Some
examples include: (1) a homeowner may relocate before they come to the top of the
waiting list, (2) a household may change their income status or number of members in
the household while on the waiting list and no longer qualify, (3) some homeowners
participate in other programs to receive weatherization measures, or (4) a homeowner
may no longer have an active account with Idaho Power. These unplanned changes have
the potential to result in deviations between the annual average as compared to the
allowed cap. While there is no recourse the Company would take in the event of the cap
being exceeded, Idaho Power and the CAP agencies work and communicate throughout
the year to mitigate this risk.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 7

The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program and Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 8

REQUEST FOR PRODUCTION NO. 6: Please provide a current list of specific
electrical upgrades allowed within the proposed expansion to the reweatherization
offering. Please explain if and how the Company might consider additional electrical
upgrade options that are not currently included.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The expanded offering
will allow for electrical upgrades necessary to complete HVAC and water heater
replacements, which could include main electrical service panel upgrades, new HVAC
equipment wiring, water heaters, water heating equipment wiring, or other ancillary
equipment deemed necessary to complete the installation of the new HVAC or water
heater system. The Company is not proposing to consider additional electrical upgrades
outside of what is required to support HVAC and water heater upgrades, as described
above.
The response to this Request is sponsored by Billie McWinn, Energy Efficiency
Program and Customer Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 9

Respectfully submitted this 23rd day of October 2024.
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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 TO IDAHO POWER - 10

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23rd day of October 2024, 1 served a true and
correct copy of Idaho Power Company's Response to the First Production Request of the
Commission Staff to Idaho Power upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff Hand Delivered
Dayn Hardie U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email [e-mail]
PO Box 83720
Boise, ID 83720-0074
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 11