20080827Staff to IPC 16-24.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECEtVED
1808 AUG 21 . PM 3: 22
IDAHO PUBL\Ç ON
UTiliTIES COMM t;81 . i
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE TO ITS )
CUSTOMERS IN THE STATE OF IDAHO. )
)
)
)
CASE NO. IPC-E-08-10
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, SEPTEMBER 17,2008.
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 AUGUST 27,2008
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference ID AP A 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents 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 identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO. 16: Please provide names and job titles with descriptions of duties for
all employee positions in Idaho Power's Customer Relations and Energy Efficiency (CR&EE)
Deparment.
REQUEST NO. 17: Please provide resumes of all employees of the Energy Efficiency
Division of the CR&EE Deparment. (Personal information such as home addresses and
telephone numbers may be redacted).
REQUEST NO. 18: Please provide customer participation numbers for 2008 year to
date for each of Idaho Power's energy efficiency and demand response programs.
REQUEST NO. 19: Please provide an estimate for the number of different customers
by customer class who have paricipated in one or more of Idaho Power's energy efficiency
programs from 2003 through 2008 to date.
REQUEST NO. 20: Please provide a detailed description of the "Home Weatherization
Pilot", including but not limited to its budget, fuding sources, administration, evaluation, cost-
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 AUGUST 27,2008
effectiveness, participation selection criteria and method, expected pilot paricipation, and how it
differs from low-income weatherization.
REQUEST NO. 21: Please provide a copy of all the customer communications
materials curently used by Idaho Power to promote customer paricipation in its energy
efficiency and demand response programs.
REQUEST NO. 22: Please provide a copy ofIdaho Power's marketing plan for its
energy efficiency and demand response programs. Please provide a description and schedule for
TV, newspaper, radio advertising, bil inserts, direct mailers, etc. used to promote these
programs. Does Idaho power taget high energy users and directly contact them to offer an audit
to see how energy usage can be reduced? If not, why not?
REQUEST NO. 23: Please provide a list of all Schedule 7 customers who have been
moved to another schedule (e.g. Schedule 9) since January 2005. Provide the dates of the
transfer, as well as the monthly usage for each customer.
REQUEST NO. 24: Please provide any analysis the Company has done to adjust usage
for the Small Commercial class as a result of moving customers to a different schedule.
DATED at Boise, Idaho, this:l? %y of August 2008.
ø~
Neil Price
Deputy Attorney General
..
Technical Staff: Daniel Klein/16 - 22
Bryan Lanspery/23 - 24
i:umisc:prodreq/ipce08. i Owsnpdkbl prod req2
SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 AUGUST 27, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF AUGUST 2008,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-10, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
DONOV AN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bkline(fidahopower.com
Inordstrom(fidahopower .com
dwalker(fidahopower.com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(frichardsonandoleary.com
RANDALL C BUDGE
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(fracinelaw.net
elo(fracinelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurz(fBKLlawfirm.com
kboehm(fBKLlawfirm.com
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
JOHN R GALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale(iidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(imindspring.com
ANTHONY Y ANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E-MAIL: yanel(iattbi.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(ienergystrat.com
LOTH COOKE
ARTHUR PERRY BRUDER
UNITED STATE DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: lot.cooke(ihq.doe.gov
arhur. bruder(fhq .doe. gov
CERTIFICATE OF SERVICE
DWIGHT ETHERIDGE
EXETER ASSOCIATES INC
5565 STERRTT PLACE, SUITE 310
COLUMBIA MD 21044
E-MAIL: detheridge(fexeterassociates.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
1500 LIBERTY STREET SE, SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(iexcite.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(igivenspursley.com
KEN MILLER
CLEAN ENERGY PROGRA DIRECTOR
SNAKE RIVER ALLIANCE
POBOX 1731
BOISE ID 83701
E-MAIL: kmiler(isnakeriverallance.org
,9J~,v~_SECRETARY
CERTIFICATE OF SERVICE