20080926Staff to IPC 110-125.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 3283
RECE.\VEO
iøSEl i& l~ 3: 41
\OI\r\O i8J~\~S\ON
\ji\\.rnES
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
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
SEVENTH 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
FRIDAY, OCTOBER 10,2008.
SEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 SEPTEMBER 26, 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 IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementar 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 files on CD with formulas activated.
REQUEST NO. 110: Please provide electric and natural gas forward prices for 2009
contract months as reported daily for all settlement dates beginning August 25, 2008, through as
recent as possible for each of the trading hubs for which Idaho power regularly trades or considers
in its analysis. Please provide the data in an electronic Excel format with formulas activated.
(This request is for an update to the data already provided in response to Staff Request No.4).
REQUEST NO. 111: Please provide copies of the educational materials used or given to
Idaho paricipants of the Residential Educational Initiative program.
REQUEST NO. 112: What changes, if any, were made to the Residential Educational
Initiative program for 2008?
REQUEST NO. 113: Why is the Energy House Calls program only offered to Idaho
residential customers who live in manufactured homes?
REQUEST NO. 114: In the futue, wil the Energy House Calls program be offered to all
Idaho residential customers? If not, why not?
SEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 SEPTEMBER 26, 2008
REQUEST NO. 115: Please provide copies of all demand-side management (DSM, e.g.
energy efficiency, conservation or demand response) business plans prepared by or for Idaho
Power from 2002 through 2008.
Note: Use of the word "contractors" in Request Nos. 116 - 121 is intended to include
subcontractors and the Northwest Energy Efficiency Allance.
REQUEST NO. 116: Please provide copies of all correspondence between Idaho Power
or its contractors and mobile home manufacturers, dealerships and/or salespersons in 2007 and
2008 regarding the Rebate Advantage program.
REQUEST NO. 117: Please provide copies of complaints and inquiries to Idaho Power
in 2007 and 2008 regarding the Rebate Advantage program.
REQUEST NO. 118: Please provide copies of all correspondence between Idao Power
and its contractors in 2007 and 2008 regarding the A/C Cool Credit program.
REQUEST NO. 119: Please provide copies of complaints and inquiries to Idaho Power
or its contractors in 2007 and 2008 regarding the A/C Cool Credit program.
REQUEST NO. 120: Please provide copies of all correspondence between Idaho Power
and its contractors in 2007 and 2008 regarding the Energy Star~ Homes Northwest program.
REQUEST NO. 121: Please provide copies of complaints and inquiries to Idaho Power
or its contractors in 2007 and 2008 regarding the Energy Star~ Homes Northwest program.
REQUEST NO. 122: Please specifically identify and quantify all Tariff Schedule 91
fuds that have been used for personnel, administration and/or marketing expenses related to
promotion of renewable energy resources for each year from 2002 through 2008.
SEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 SEPTEMBER 26, 2008
REQUEST NO. 123: Please specifically identify and quantify all Tariff Schedule 91
fuds that have been used for personnel, administration and/or marketing expenses related to
promotion of Project Share for each year from 2002 through 2008.
REQUEST NO. 124: Please provide the salary range and total compensation range for
each employee position listed on the Customer Relations and Energy Effciency organization
char as of September 2008.
REQUEST NO. 125: Please provide any Idaho Power analyses, meeting notes or
correspondence among employees or contractors in 2007 and 2008 regarding Schedule 1 or
Schedule 7 customer average monthly usage changes.
DATED at Boise, Idaho, this .ib ~ay of September 2008.-
IJJ!~
Neil Price
Deputy Attorney General
Technical Staff: Rick Sterling/11 0
Daniel Klein & Curis Thaden 111 - 114
Lynn Anderson & Donn English 115 - 125
i:umisc:prodreq/ipce08. i Owsnprpsdkctlade prod req7
SEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 SEPTEMBER 26, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DATE 26TH OF SEPTEMBER
2008, SERVED THE FOREGOING SEVENTH 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(Ðidahopower.com
lnordstrom(Ðidahopower .com
dwalker(Ðidahopower.com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(Ðrichardsonandoleary.com
RANDALL C BUDGE
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(Ðracinelaw.net
elo(Ðracinelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurz(ÐBKLlawfirm.com
kboehm(ÐBKLlawfirm.com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(ÐhotmaiL.com
JOHNRGALE
VP-REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale(Ðidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: .dreading(Ðmindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: yanel(Ðattbi.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(Ðenergystrat.com
LOTH COOKE
ARTHUR PERRY BRUDER
UNITED STATE DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: lot.cooke(Ðhq.doe.gov
arhur. bruder(Ðhq .doe. gov
CERTIFICATE OF SERVICE
DWIGHT ETHERIDGE
EXETER ASSOCIATES INC
5565 STERRTT PLACE, SUITE 310
COLUMBIA MD 21044
E-MAIL: detheridge(qexeterassociates.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
1500 LIBERTY STREET SE, SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(qexcite.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(qgivenspursley.com
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmiler(qsnakeriveralliance.org
~~.~SECRETARY
CERTIFICATE OF SERVICE