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
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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
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RECEIVED
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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
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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
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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
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..
Barton L. Kline
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SIXTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8