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HomeMy WebLinkAbout20081009IPC to Staff 90, 92.pdfesIDA~POR~ An IDACORP Company BARTON L. KLINE Lead Counsel October 9, 2008 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-08-10 General Rate Case Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies each of Idaho Power Company's Supplemental Response to the Sixth Production Request of the Commission Staff. In addition, also enclosed are four copies of a CD containing the Company's response to production in which electronic files have been provided because of the voluminous nature of the information. Upon receipt of this filing, I would appreciate it if you would return a stamped copy of this letter for my file in the enclosed stamped, self-addressed envelope.velfr!/~ Barton L. Kline Lead Counsel for Idaho Power Company BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, 10 83702 BARTON L. KLINE, ISB #1526 LISA D. NORDSTROM, ISB #5733 DONOVAN E. WALKER, ISB #5921 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 Facsimile: (208) 388-6936 bkline(ëidahopower.com Inordstrom(ëidahopower.com dwalker(âidahopower.com RECEIVED 200ft OCT -9 PM 12: 46 A'IO ..1;1:'\ !l':\0. ", ti.." t"~, L"'-~1.l (~r'~lr\~J UTILITIES COd,:rh).)IL ,'i Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 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. ) ) CASE NO. IPC-E-08-10 ) ) ) ) ) ) IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in supplemental response to the Sixth Production Request of the Commission Staff to Idaho Power Company dated September 19, 2008, herewith submits the following information: IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO. 90: For each Idaho-funded demand-side management (DSM) program included in Appendix 4 of Idaho Power's Demand-Side Management 2007 Annual Report, please provide the pre-implementation estimated evaluation budget, the amount spent on evaluations through 2007, and the amount spent for evaluations in 2008 to-date. SUPPLEMENTAL RESPONSE TO REQUEST NO. 90: When developing demand-side management programs, Idaho Power incorporates evaluations of each program into the planning process. In the planning and cost-effectiveness phase of program design, Idaho Power allocates approximately five percent of a program's annual budget for evaluation purposes. Idaho Power program evaluations are planned on a multi-year basis and are reviewed on a year-by-year basis. A program's evaluation plan can change depending on the maturity of the program, program offerings, code changes, technological changes, reporting requirements, and regional evaluation efforts. Idaho Power considers many factors when planning to conduct evaluations internally or externally, including the availability of primary or secondary data. When suffcient primary data is available, Idaho Power may choose to conduct an internal evaluation. If a large amount of secondary data is required or if extensive measurement and verification equipment is needed, Idaho Power typically hires a consultant to conduct these evaluations. Consultants are also utilized by Idaho Power if specific subject matter expertise is required for an evaluation. Additionally, Idaho Power contracts with third-part consultants to confirm or estimate energy savings or peak demand reduction associated with DSM programs that have been evaluated internally. IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 If a regional evaluation is planned by an organization such as the Northwest Energy Effciency Allance, Idaho Power often provides input to the evaluation process and seeks to ensure that a statistically valid sample is represented within Idaho Powets service territory. In some cases, Idaho Power funds an oversample to gather suffcient data for reliable estimates of program performance in its service territory. Idaho Power also utilizes regional databases, including the Northwest Power and Conservation Council Regional Technical Forum, for estimated values such as energy savings and costs associated with end-use measures as sources of secondary data. For internal evaluation projects, Idaho Powets costs are generally limited to the labor and overhead expenses associated with a full-time evaluator. However, internal costs include items such as survey tools that are a one-time cost to the Company, but provide functionality to several programs. Other costs Idaho Power incurs for evaluation purposes include purchasing equipment, such as data loggers, used to collect information to assess program performance. Costs to hire third-part consultants vary considerably based on items such as the type of data required, use of field personnel, type of reporting needed, and equipment required for an evaluation. For a complete list of the costs spent on evaluation work through 2008 to-date, please see the Excel spreadsheet named '2003-2008 Evaluation Study List.xls' previously provided in Idaho Power's response to Request No. 91. The response to this Request was prepared under the direction of Theresa Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO. 92: Please describe how post-implementation evaluations have been used by Idaho Power to improve its DSMprograms and/or to improve its overall resource planning. Include supporting discussion notes, letters and memorandums, all whether on paper or electronically distributed. SUPPLEMENTAL RESPONSE TO REQUEST NO. 92: Many of Idaho Power's energy effciency and demand response programs were developed using assumptions and estimated energy savings and costs from a variety of resources. These resources include, but are not limited to: Northwest Power and Conservation Council, the Regional Technical Forum, the Northwest Energy Effciency Allance, E-Source, the Database on Energy-Effciency Resources, the Energy Trust of Oregon and regional utilities. Idaho Power uses the results from post-implementation evaluations and studies to verify program impacts, modify program assumptions, or change program structures, as warranted by the study. If it becomes necessary to make a program change, based on results of a post-implementation study, Idaho Power reviews the program during the Integrated Resource Plan ("IRP") development process and vets these changes through the Energy Effciency Advisory Group ("EEAG"). Idaho Power uses the IRP process for developing and changing energy effciency and demand response program offerings. For a complete description of how DSM programs are screened in the IRP process, please see Appendix D-Technical Appendix of the 2006 I RP, located at http://w.idahopower.com/energycenter/irp/2006/2006IRPFinal.htm. Idaho Pòwer communicates results of post-implementation studies and subsequent program changes through a variety of venues, including the Demand Side Management Annual Report, workshops, trainings, and other stakeholder meetings. IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 These avenues for communicating program impacts allow Idaho Power to gather feedback from impacted stakeholders for changing or improving programs if it is determined to be necessary. Idaho Power also presents changes or modifications to existing programs during EEAG meetings. The EEAG is an advisory council that provides customer and public interest guidance on energy effciency program design and implementation strategies. This group has proven to be a valuable resource to Idaho Power for disseminating post-implementation information (minutes for EEAG meetings are provided on the enclosed CD). As a general business policy, Idaho Power does not maintain archives of all discussion notes, letters and memorandums. If Staff has specific questions which would allow the Company to make a reasonably focused search to identify relevant discussion notes, letters, and memorandums, the Company could make this specific information available. The response to this Request wàs prepared under the direction of Theresa Drake, Customer Relations and Energy Effciency Manager, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 9th day of October 2008. ~-BARTON L. KLINE Attorney for Idaho Power Company LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of October 2008 I served a true and correct copy of IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Weldon B. Stutzman Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Neil Price Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Dr. Don Reading Ben Johnson Associates 6070 Hil Road Boise, Idaho 83703 Idaho Irrigation Pumpers Association, Inc. Randall C. Budge Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 201 East Center Pocatello, Idaho 83204-1391 i. Hand Delivered U.S. Mail _ Overnight Mail FAX i. Email Weldon.stutzman(âpuc.idaho.gov i. Hand Delivered U.S. Mail _ Overnight Mail FAX i. Email Neil.price(ëpuc.idaho.gov Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email peter(ërichardsonandolearv.com Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email dreading(ëmindspring.com Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email rcb(ëracinelaw.net elo(ëracinelaw. net IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Kroger Co. I Fred Meyer and Smiths Michael L. Kurt Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 The Kroger Co. Attn: Corporate Energy Manager (G09) 1014 Vine Street Cincinnati, Ohio 45202 Kevin Higgins Energy Strategies, LLC Parkside Towers 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Micron Technology Conley Ward Michael C. Creamer GIVENS PURSLEY, LLP 601 West Bannock Street P.O. Box 2720 Boise, Idaho 83701-2720 Dennis E. Peseau, Ph.D. Utility Resources, Inc. 1500 Libert Street SE, Suite 250 Salem, Oregon 97302 Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email tony(ëyankel.net Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email mkurt(âBKLlawfirm.com kboehm(ëBKLlawfrm.com Hand Delivered i. U.S. Mail _ Overnight Mail FAX Email Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email khiggins(ëenergystrat.com Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email cew(ëgivenspursley.com mcc(ëgivenspursley.com Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email dennvtemp(âyahoo.com IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 Departent of Energy Lot R. Cooke Arthur Perry Bruder Ofce of the General Counsel United States Departent of Energy 1000 Independence Avenue SW Washington, DC 20585 Routing Symbol GC-76 Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Place, Suite 310 Columbia, MD 21044 Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail i. Overnight Mail FAX i. Email Lot.Cooke(âhg.doe.gov Arthur. Bruder(ëhg .doe.gov Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email detheridge(âexeterassociates.com Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email bmpurdy(âhotmail.com Hand Delivered i. U.S. Mail _ Overnight Mail FAX i. Email kmiler(snakeriverallance.org .. Barton L. Kline IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8