20081014IPC to Staff 110-125.pdf

BARTON L. KLINE
Lead Counsel
e:lDA.~POR(g
An IDACORP Company
October 10,2008
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 Second Supplemental Response to the Sixth Production Request of the
Commission Staff, Idaho Power Company's Response to the Fourth Production Request of
the Industrial Customers, Idaho Power Company's Response to Community Action
Partnership Association of Idaho's First Production Requests, and Idaho Power Company's
Response to the Seventh Production Request of the Commission Staff.
In addition, also enclosed are CDs containing the Company's responses to
production requests in which electronic/excel fies were requested and also for ease of
production 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.ve~/!L
Barton L. Kline
Lead Counsel for Idaho Power Company
BLK:csb
Enclosures P.O. Box 70 (83707)
12~1 W. Idaho St.
Boise, ID 83702
RECEIVED
1088 OCT I 0 PM 5: 04
IDAHO PUBLICUTIliTIES COMMISSION
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: [phone]
Facsimile: [phone]
bkline(âidahopower.com
Inordstrom(âidahopower.com
dwalker(âidahopower.com
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
RESPONSE TO THE SEVENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to the Seventh Production Request of the Commission Staff to Idaho Power
Company dated September 26, 2008, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
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).
RESPONSE TO REQUEST NO. 110: Please see enclosed CD. Since this data
is confidential, Idaho Power is providing this information only to parties that have
executed the Protective Agreement.
The response to this Request was prepared by Mike Polito, Risk Analyst, Idaho
Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 111: Please provide copies of the educational materials used or
given to Idaho participants of the Residential Educational Initiative program.
RESPONSE TO REQUEST NO. 111: In response to Staffs production Request
No. 21, the Company provided electronic copies of several education materials given to
customers as part of the Residential Educational Initiative program. Included were:
Summer Energy Savings Tips (English)
Summer Energy Savings Tips (Spanish)
Winter Energy Savings Tips (English)
Winter Energy Savings Tips (Spanish)
30 Simple Things You Can Do to Save Energy
2008 Energy Effciency Guide
Practical Ways to Manage Your Electricity Bil
Included on the enclosed CD are materials that have been produced or updated
since Response No. 21 was provided, as well as "Simple Ways to Save Energy, Mini
Home Audit," which was not included in response to Request No. 21.
Summer Energy Savings Tips (English - updated version)
Fall 2008 Energy Effciency & Green Living Series - book marks
Fall 2008 Energy Effciency & Green Living Series - library series brochure
Fall 2008 Energy Effciency & Green Living Series - poster
Simple Ways to Save Energy - Mini Home Audit
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
Also include in this response are hard copies of "30 Simple Things You Can Do
to Save Energy," which is an updated version of the electronic copy provided in
response to Staffs production Request No. 21.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWERCOMPANY - 4
REQUEST NO. 112: What changes, if any, were made to the Residential
Educational Initiative program for 2008?
RESPONSE TO REQUEST NO. 112: As stated in an e-mail dated September
29, 2008, to Lynn Anderson at the IPUC (email attached with this response) and as a
follow-up to Staff Request No. 22:
In 2007 an Idaho Power Employee who started the
Residential Education Initiative was in a cross-training
position with our department until late October when she
was hired for another position outside our department. The
Program Specialist, Residential Education was a new
position in 2008 and was not filled until June of 2008
therefore a plan was never developed.
Because the Residential Education Program Specialist position was filled in mid-
year and the program is new, no significant changes have been made to this program in
2008. The Company is currently assessing the Residential Education Initiative ("REI")
program, and designing program plans for 2009.
In 2008, as part of the REI program and National Energy Awareness Month, the
Fall Energy Effciency and Green Living Series is currently being conducted at the Boise
Public Library. This program was offered in 2007, but has been modified and updated
for 2008.
Also as part of the 2008 REI program, a new energy effciency presentation for
school-age children (grades 4-6) wil begin later this year and wil be presented by the
Community Education Representatives in their respective geographic areas.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 113: Why is the Energy House Calls program only offered to
Idaho residential customers who live in manufactured homes?
RESPONSE TO REQUEST NO. 113: The Energy House Calls C'EHC") program
is a legacy program that began in 2003, and was originally designed and implemented
by the Bonnevile Power Administration C'BPA"), and funded under the Conservation
Rate Credit ("CRC") program. As such, all of the program design, estimated energy
savings, and program administration was estimated based on the fact that it was offered
to manufactured homes. Approximately 80 percent of all manufactured homes have
ducts that are unsealed or improperly sealed.
In mid-2007, when the CRC program was discontinued, Idaho Power began
funding the EHC program through the Idaho Energy Effciency Rider, Schedule 91.
Idaho Power wil continue to fund the EHC program, as long as the Company believes
that the market saturation level is such that there are significant numbers of qualified
homes in its service area that can benefit from this program, and for which cost-effective
energy savings can be realized.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO. 114: In the future, wil the Energy House Calls program be
offered to all Idaho residential customers? If not, why not?
RESPONSE TO REQUEST NO. 114: Idaho Power has no plans to offer Energy
House Calls program to all residential customers. This program was designed by the
Bonnevile Power Administration specifically for manufactured homes (see response to
Staffs Request No. 113). Idaho Power is currently conducting an evaluation of this
program to determine its cost-effectiveness and ongoing viability. As part of this
analysis, the Company is evaluating savings estimates for this program and attempting
to identify weatherization measures that may be applicable to other house types.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO. 115: Please provide copies of all demand-side management
(DSM, e.g. energy effciency, 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 Effciency Allance.
RESPONSE TO REQUEST NO. 115: In 2003, Idaho Power produced a formal
business plan for Demand-Side Management titled "Demand-Side Management at
Idaho Power - A Business Plan 2003-2005." An electronic copy is provided on the
enclosed CD. Because of limited availability, a hard copy of the attachment is available
upon request at Idaho Power Company's corporate offces. Please contact Doug Jones
at 388-2615 or Camila Victoria at 388-5821 to arrange a time to review the requested
materiaL.
Since 2005, Idaho Power has used a multi-dimensional approach to DSM
business planning. This method incorporates DSM potential studies, long-term
forecasting including IRP planning, annual strategic planning, annual budget planning,
consultation with the Energy Effciency Advisor Group ("EEAG") and other stakeholders,
and governance by the Energy Effciency Guiding CounciL.
Long-term DSM potential studies are conducted by third-part consultants for
Idaho Power. The results of these studies are utilized in the IRP planning process to
initially screen programs for cost-effectiveness and evaluate them on a like basis to
supply side resources. Through the budgetary process, the leadership in the Customer
Relations and Energy Effciency group conducts annual planning, incorporating the
results of the IRP planning. The EEAG is comprised of twelve members, including
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
representatives from the residential, industrial, commercial, and irrigation sectors, as
well as representatives for the elderly, low income, environmental organizations, state
agencies and public utility commissions. All new programs and all major program
changes are presented to the EEAG prior to implementation. The input from the EEAG
is used to design and modify programs prior to implementation. Detailed financial
information is presented to the EEAG to enable the members to advise the Company on
these issues. The minutes from all EEAG meetings are attached to the response to
Staffs Request No. 92. Depending on the program, Idaho Power may consult with
other stakeholders such as the Idaho Irrigation Pumpers Association during the
planning process. The Idaho Power Energy Effciency Guiding Council is comprised of
Company senior management and representatives from the Customer Relations and
Energy Effciency Department. DSM programs, initiatives, and expenses are presented
to the Energy Effciency Guiding Council for input and management approval. The
Company believes that this dynamic planning process is a much more effective and
efficient process than producing static multi-year business plans that cannot take into
account annual changes in markets, customer impact, technology, and other rapidly
changing aspects of demand-side management programs and initiatives.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
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.
RESPONSE TO REQUEST NO. 116: The promotional brochure used by Rebate
Advantage was provided as part of Idaho Power's response to Staffs production
Request No. 21.
Idaho Power has had very little written correspondence with its contractors,
mobile home manufacturers, dealerships, and/or salespersons in 2007 and 2008. In
2007 and 2008, Idaho Power sent letters to various salespeople notifying them that their
applications have not been accepted. The Company sent four letters to salespeople
because the home was not an Energy StarCl; three letters because the home sold was
not electrically heated; and four letters because the home was not located in Idaho
Power service territory. Samples of these letters with the customer's names redacted
are included on the enclosed CD.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10
REQUEST NO. 117: Please provide copies of complaints and inquiries to Idaho
Power in 2007 and 2008 regarding the Rebate Advantage program.
RESPONSE TO REQUEST NO. 117: Idaho Power does not have any record
of complaints regarding the Rebate Advantage program in 2007 and 2008. The
Company does not track inquiries, per se. Most inquiries are made by telephone, and
these inquiries are not documented, they are acknowledged and the customer is
provided whatever information is needed. If Commission Staff considers applications
for an incentive(s) an inquiry, the Company received 123 applications in 2007 and
approximately 79 year-to-date in 2008. A copy of the application form is included on the
enclosed CD.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST NO. 118: Please provide copies of all correspondence between
Idaho Power and its contractors in 2007 and 2008 regarding the AlC Cool Credit
program.
RESPONSE TO REQUEST NO. 118: The AlC Cool Credit has an extremely
large volume of correspondence with its contractors for 2007 and 2008. The Company
exchanges thousands of e-mails annually with its contractors (over 4,000 to date in
2008). These reports include weekly reports, information pertaining to specific
customers, and equipment updates. Much of this correspondence contains customer
specific information, making it diffcult to redact and provide as part of this request. As a
general business policy, Idaho Power does not maintain comprehensive archives of all
correspondence. If Staff has specific questions which may be answered by the
contents of such discussion notes, letters, and memorandums, these wil be made
available upon request. Please contact Doug Jones at 388-2615 or Camila Victoria at
388-5821 to arrange a time to review the requested materiaL.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST NO. 119: Please provide copies of complaints and inquiries to Idaho
Power or its contractors in 2007 and 2008 regarding the AlC Cool Credit program.
RESPONSE TO REQUEST NO. 119: On the enclosed CD are two files
containing customer complaints and/or inquiries. One contains scanned complaints
received in paper form with the customer information redacted. The other is a table
produced from a query of Idaho Power's Customer Information System with customer
information redacted. This response does not contain an exhaustive list of complaints
and/or inquiries for the AlC Cool Credit program. Idaho Power has contracted with a
third part to install cycling switches and supply call center support for the program.
Annually, the Company and its contractor receive a large volume of customer contacts
concerning the AlC Cool Credit program. These contacts can be received in many
ways. Customers can contact Idaho Power's customer service center, the third-part
contractots call center, Company or contractor staff by phone or e-mail, Company staff
at events (home shows, etc.), or apply to participate in the program. Not all of these
contacts are tracked and some have no tracking mechanism. In 2007, the inquiries that
resulted in program participation accounted for approximately 8,323 new participants
and in 2008 the AlC Cool Credit program has added about 8,300 new participants.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
REQUEST NO. 120: Please provide copies of all correspondence between
Idaho Power and its contractors in 2007 and 2008 regarding the Energy StarCl Homes
Northwest program.
RESPONSE TO REQUEST NO. 120: Through the Energy StarCl Homes
Northwest program, Idaho Power has business relationships with approximately 146
builders, Home Performance Specialists C'HPS"), Idaho Offce of Energy Resources
C'OER"), Northwest Energy Effciency Allance ("NEEA"), and regional consultants.
Through these business relationships, this program has an extremely large quantity of
paper and electronic correspondence (hundreds of pieces annually). Much of this
correspondence contains customer specific information which would be diffcult to
redact. As a general business policy, Idaho Power does not maintain a comprehensive
archive of all correspondence. If Staff has specific questions which may be answered
by the contents of this correspondence, they wil be made available upon request.
Please contact Doug Jones at 388-2615 or Camila Victoria at 388-5821 to arrange a
time to review the requested materiaL.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
REQUEST NO. 121: Please provide copies of complaints and inquiries to Idaho
Power or its contractors in 2007 and 2008 regarding the Energy Starc Homes Northwest
program.
RESPONSE TO REQUEST NO. 121: In 2007 and 2008 yea r-to-d ate , the
Energy StarCl Homes Northwest program has had four complaints. Two of these were
received by phone and two bye-maiL. The e-mails were not saved after the issues were
resolved. All four complaints came from builders.
Two of these complaints were made to the Program Specialist, who manages the
program, but were directed towards the Idaho Offce of Energy Resources ("OER") and
were due to the OER inspector requiring a Quality Assurance ("QA") inspection on
homes that were already occupied. According to both builders, the inspector
approached both homes and told both sets of homeowners that he was required to
inspect their homes, inconveniencing the occupants for up to six hours. The QA
process should be completed immediately after construction and before anyone
occupies the homes. In both cases, the homeowners called their builders and
complained. The builders then appealed to Idaho Power for assistance. To attempt to
resolve this issue the Idaho Power Program Specialist contacted OER concerning the
complaint and OER responded that in the future they would make every effort to
complete the QA prior to occupancy.
The other two complaints were from builders complaining that they had not
received their incentives. Upon further research, it was found that the Home
Performance Specialist ("HPS") had failed to turn in the certification forms to the OER in
a timely manner. Idaho Power does not pay an incentive without the certification
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
paperwork, signed by OER staff. To resolve this issue, Company staff contacted the
HPS, informed him of the complaints, and encouraged him to submit his certification
forms in a timelier manner.
The Company receives inquiries about the Energy StarCl Homes Northwest
program in many ways. Customers can contact the customer service center, Company
staff by phone or e-mail, Company staff at events (home shows, etc.), Energy StarCl
builders directly, or apply to participate in the program. The Company does not track all
of these inquiries. The inquiries that come to fruition, other than for educational
purposes, are documented as incentives are paid. In 2007, Idaho Power incented 303
Energy StarCl Homes, and as of September 30, 2008 the Company has incented 165
Energy Starc Homes.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST NO. 122: Please specifically identify and quantify all Tariff Schedule
91 funds 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.
RESPONSE TO REQUEST NO. 122: Idaho Power has not used any Tariff
Schedule 91 funds for marketing expenses or direct administration expenses related to
promotion of renewable energy resources. The Company has used a de minimis
amount of annual staff time, funded by Tariff Schedule 91, since September 2006 for
supervision of the specialists directly working on Idaho Power's small scale renewable
programs and Green Power program.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
REQUEST NO. 123: Please specifically identify and quantify all Tariff Schedule
91 funds that have been used for personnel, administration and/or marketing expenses
related to promotion of Project Share for each year from 2002 through 2008.
RESPONSE TO REQUEST NO. 123: Idaho Power has not used any Tariff
Schedule 91 funds for marketing expenses or for direct administration expenses related
to Project Share. The Company has used a de minimis amount of annual staff time
funded by Tariff Schedule 91 since September 2006 for supervision of the Special
Needs Program Specialist.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -18
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 chart as of September 2008.
RESPONSE TO REQUEST NO. 124: Please see attached spreadsheet. This
spreadsheet contains the Position Title (A), Grade (B), Salary Min (C), Salary Max (D),
Total Comp Min (E), andTotal Comp Max (F).
Columns 0 - F in the spreadsheet represent the cash compensation range for
each position. Specifically, Column C and Column 0 represent the annual base salary
range for each respective position. For non-exempt positions (Grades 8, 14, 18), the
numbers shown are based upon 2080 hours worked per year and do not include any
potential overtime hours. Column E and Column F represent the total compensation
range, which is comprised of the annual base salary range plus a target incentive
payment of 6 percent of the annual salary. Idaho Power considers employee
information, such as provided within this request, to be confidential and is providing this
information only to parties who have executed the Protective agreement.
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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
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.
RESPONSE TO REQUEST NO. 125: Attached is a copy of Idaho Power's
response to Commission Staffs Request No. 15 in Case No. IPC-E-08-04, which is a
preliminary analysis of average monthly usage changes with regards to changes in
average house size and residential air conditioner penetration for both Ada and Canyon
counties.
See the analysis performed for the Fixed Cost Adjustment monthly report that
ilustrates the average monthly usage changes for Schedule 1 and Schedule 7
customers on the enclosed CD.
Idaho Power is unaware of any meeting notes or correspondence among
employees regarding Schedule 1 or Schedule 7 customer average monthly usage
changes. Attached is an e-mail correspondence from Spencer Sator from Esource in
regard to average residential use.
The response to this Request was prepared by under the direction of Theresa
Drake, Customer Relations and Energy Effciency Manager, and Michael Youngblood,
Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
DATED at Boise, Idaho, this 10th day of October 2008.
Mi~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 RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of October 2008 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH
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 Utilities 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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U.S. Mail
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FAX
-2 Email Weldon.stutzman(âpuc.idaho.gov
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U.S. Mail
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FAX
-2 Email Neil.price(apuc.idaho.gov
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-2 Email peter(arichardsonandoleary.com
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-2 Email dreading(amindspring.com
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-2 Email rcb(aracinelaw.net
elo(aracinelaw.net
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22
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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-2 Email tony(ayankel.net
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-2 Email mkurt(aBKLlawfrm.com
kboehm(aBKLlawfirm.com
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Email
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-2 Email khiggins(aenergystrat.com
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-2 Email cew(agivenspursley.com
mcc(agivenspursley.com
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-2 Email dennvtemp(ayahoo.com
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23
Department of Energy
Lot R. Cooke
Arthur Perry Bruder
Offce of the General Counsel
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
Routing Symbol GC-76
Dwight D. Etheridge
Exeter Associates, Inc.
5565 Sterrett Place, Suite 310
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Barton . Kline
IDAHO POWER COMPANY'S RESPONSETO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-08-10
IDAHO POWER COMPANY
RESPONSE TO STAFF'S
PRODUCTION REQUEST NO. 112
Page 1 of 4
Pengily, Pete
From: Spencer Sator (spencecsator~esource.comi
Sent: Monday, March 03, 2008 3:27 PM
To: Pengilly, Pete
Cc: Joan Gregerson
Subject: Idaho Power inquiry on residental energy consumption trends
Attachments: TIAX_Residential Office_2007.pdf; TV Sets_ACEEE_2006.pdf; TV Sets_Energy Star_2006.pdf; TV
Sets_NRDC_2005.pdf; ECOS_Residential Office_2006.pdf
An in If fr E SO
Your Inquiry
Here at Idaho Power we have noted that our residential usage has been gradually increasing since
2003, about 12,500/yr to almost 13,OOO/yr. i am looking for any research to explain this increase. We
keep hearing increased square footage of homes, more plug load, plasma TV, etc. but i have really
yet to see any studies/research to support such information.
Our Response
Hi Peter-
We are aware of no study that directly links size of homes or plug loads with higher energy
consumption. Although there certainly is some connection between these trends, the overall home
energy picture is far larger with many, many more variables.
Here are some of the main reasons why energy consumption is on the rise:
· Increasing house size
· Higher market penetration of air conditioning (even in cooler climates)
· Higher adoption of electric heat in new houses because of high gas prices
· Increasing occupants per household in new constructions
· Growth in energy draw of TV sets, entertainment equipment and peripherals
· Greater market penetration of large TVs, computers and entertainment equipment
. Warmer average summers
· Increased hours of TV viewing by Americans
· Growth in home offices and telecommuting
· Lack of energy standards for many new technologies, like plasma TVs and computer monitors
· Increasing urban heat sink effects
At the same time, you've got some forces that are acting to reduce energy demand:
. CFLs
· Increasing concerns about environment/global warming
· Increasing appliance standards
10/10/2008
Page 2 of 4
· Better utilty outreach programs
. LCDs replacing CRTs
. Greater insulation levels
· More efficient housing stock
· Efficiency upgrades in older homes
· Water conservation measures in homes with electric hot water
There are stil more factors that can act to both increase and decrease demand, depending on
individual circumstances:
· Changing profile of entertainment preferences (Le. watching movies on a computer or iPod
instead of a power-hungry home entertainment system, or vice-versa)
· Aging of the Baby Boomers and associated changes in energy consumption habits
. Trends in single family vIs multi-family construction
· Consumer preferences of gas stoves vIs electric vIs infrared over time
· More sophisticated lighting schemes and fixtures in homes
· Overall water usage trends in homes with electric hot water heat
· Urban renewal and revitalization efforts that may enhance efficiency options, but can lead to
lower number of occupants per dwellng
· Dining habits (at home vIs eating out)
· Strong economy causing more consumption and/or allowing households to spend extra
money on energy-conserving appliances
. Short- and middle-term weather trends
These are just a few of the many, many variables that make up the overall home energy picture. You
can see why there isn't a lot of research that directly relates home energy consumption with one or
two specific variables, like TV sets. There are literally dozens (if not hundreds) of factors that affect a
household's energy bils and different components apply for different households in different regions
in differing amounts.
That said, your observation that the trends in energy consumption are outweighing those of energy
conservation is a development occurring in much of the nation. This is also not new; there has been
steady growth in electricity consumption for 40 years virtually everyhere except California.
We do have many studies, reports and data tables on individual components of energy consumption
if you'd like more specific information. Here are a few factors:
Two important trends are air conditioning and home size, as demonstrated here:
y
Average finished area of new homes
( f¡ t)
New homes with central air conditioning
(~ )ear square ee lJ
1950 983 no data
1970 1500 34
! 1980 1740 63
1990 2080 76
2000 2321 85
2004 2349 90
l 2005 2434 89
10/10/2008
Page 3 of 4
With televisions, there are several trends that all lead to increased energy consumption, including the
fact that the average number of TV sets has gone up from 2.3 to 2.8 sets per house since 2000,
average set size has increased, higher penetration of new set types, increased hours of viewing for
the average American (a 12.5 percent jump from 1995-2005), proliferation of peripherals (set top
boxes, hi-fi speakers, etc.), and lack of Energy Star or other efficiency standards for new technology
types.
I'LL attach a couple reports to this email that discuss trends in TV energy consumption trends in
greater detail:
TV Sets_ACEEE_2006
TV Sets_Energy Star _2006
TV Sets_NRDC_2005
Also, the growth in telecommuting can have a significant impact. When you consider the fact that this
often requires an additional room in a house, plus plugloads from an extra computer, fax machine,
printer, lights and other accessories, you can see that even a rise of a few percent in the population
that works from home has the potential for a noticeable increase in energy draw across the
community. This is particularly in regions with high prevalence of electric heat, where the thermostat
might find itself with a higher setpoint than if the home were vacant during the day.
And perhaps the most important factor that you would want to analyze is local demographics. The
single largest driver of energy consumption in a home is usually the number of occupants per
household. With the tremendous population boom in many Western regions, many cities are seeing
influxes of larger, young families. This can significantly increase the "average" household
consumption. This is because the actual average household is changing. So comparing a 2.2-person
household from several years ago to a 2.7-person household today is a bit of an apples and oranges
affair.
I'LL also attach a few studies that analyze residential plugloads and use habits in great detaiL. They
include some historical data for certain technologies.
TIAX_Residential Office_2007
ECOS_Residential Office_2006
Finally, I'll mention one really good resource for data on a number of home electronics:
http://www.efficientproducts.org. It catalogs and compiles up-to-date studies on several home
technologies, including TVs and computers. And, if you should have additional questions on any
specific technology or trends, we're always happy to help you find good information.
Please let us know if you find this information useful, and feel free to contact me if I can be of further
assistance.
Regards,
Spencer Sator
Associate, Research
SpencecSator ~ esource .com
[phone]
www.esource.com/question - the fastest way to get your questions to our team
10/1012008
Page 4 of 4
Attachments
TIAX_Residential Office_2007
ECOS_Residential Office_2006
TV Sets_ACEEE_2006
TV Sets_Energy Star_2006
TV Sets_NRDC__2005
Inquiry Number: 00005560
Inquiry date: 2/29/2008
From: Peter Pengily
Organization: Idaho Power Company
(Ç 2008 E Source Companies LLC
10/1012008
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-08-10
IDAHO POWER COMPANY
RESPONSE TO STAFF'S
PRODUCTION REQUEST NO. 125
~ily, Pete
From:
Sent:
To:
Subject:
Lynn Anderson (Lynn.Anderson ~ puc.idaho.gov)
Monday, September 29,200810:51 PM
Pengily, Pete; Drake, Theresa
RE: IPC response to Staff P.R. 22
Pete, thanks for the follow-up.
Theresa, do you have time to chat about education for a few minutes after the EEAG
meeting?
From: Pengilly, Pete (mail to: PPengilly&idahopower. com)
Sent: Mon 9/29/2008 11:35 AM
To: Pengi 1 ly , Pete; Lynn Anderson
Cc: Daniel Klein; Randy Lobb; Kline, Bart; Weldon Stutzman; Drake, Theresa; Echeverria,
Diana; Becia, Celeste; Bearry, Christa
Subject: RE: IPC response to Staff P.R. 22
Lynn,
We do not have a 2008 marketing plan for the Residential Education Initiative. In 2007 an
Idaho Power Employee who started the Residential Education Initiative was in a cross-
training position with our department until late October when she was hired for another
posi tion outside our department. The Program Specialist, Residential Education was a new
position in 2008 and was not filled until June of 2008 therefore a plan was never
developed. Attached is the Energy Education Efficiency marketing plan for 2007.
Hope this helps.
Pete Pengilly
Idaho Power Company
208-388-2281
ppengi1 ly&idahopower . com
From: Pengilly, Pete
Sent: Thursday, Septemer 25, 2008 5:49 PM
To: i Lynn Anderson i
Cc: Daniel Klein; Randy Lobb; Kline, Bart; Weldon Stutzman; Drake, Theresa; Echeverria,
Diana; Becia, Celeste
Subject: RE: IPC response to Staff P.R. 22
Lynn,
Seems like an oversight on the Custom Efficiency Marketing Plan - here it is. I will have
to look into the Residential Education Initiative Marketing plan. I'm not sure we have one
because it is not really a program more of an initiative. Diana, our Marketing Strategist
is out of the office though next week, so it may take me a couple days to track down an
answer. I i 11 get back as soon as I can.
Pete Pengilly
Idaho Power Company
208-388-2281
ppengi1 ly&idahopower . com
1
From: Lynn Anderson (mail to: Lynn. AndersonØpuc . idaho. gov)
Sen t: Thursday, September 25, 2008 5: 32 PM
To: Pengilly, Pete
Cc: Daniel Klein; Randy Lobb; Kline, Bart; Weldon Stutzman
Subject: IPC response to Staff P.R. 22
Hi Pete,
I noticed that there was no marketing plan on the CD for Commercial/Industrial
Custom Efficiency (but there was a duplicate for Residential Heating and Cooling
Efficiency). So, assuming there is a 2008 marketing plan for Custom Efficiency, please e-
mail it to Daniel and me.
Also, while there is a marketing plan for Commercial Education Initiative on the
CD, there isn't one for the Residential Education Initiative. If there is one, please e-
mail that to us as well.
Thanks,
Lynn
334-0353
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