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Home My WebLink About20081017IPC to Staff 116, 122-23, 124.pdf'-IDA~PORCI BARTON L. KLINE Leacl Counsel IDAHO P UTILITIES COMMiS An IDACORP Company October 17, 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 of Idaho Power Company's Second Supplemental Response to the Seventh Production Request of the Commission Staff. 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(jiiU ~Barton L. Kline Lead Counsel for Idaho Power Company BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, 10 83702 e 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((idahopower.com InordstromCâidahopower.com dwalkerCâidahopower.com Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 e RECEIVED zons OCT , 7 AM II: l 5 UT IDAHO PLlBL CIUTIES COMM $SlON BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MA TIER 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 SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), and in supplemental 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 SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 e e SUPPLEMENTAL REQUEST NO. 116: Thank you for the 10/15, 5:03 p.m., Supplemental Response to Staffs P.R. #116. Among those 11 confidential letters written between 917/07 and 9/15/08, none were to Clayton Industries, Clayton Manufactured Homes, Jim Rettinger, Oakwood Homes, Jason Wilson, or Golden West Homes. Does Idaho Power have any record of any correspondence with, or regarding, any of those people or businesses? SUPPLEMENTAL RESPONSE TO REQUEST NO. 116: Idaho Power has no record of correspondence with the companies listed. It should be noted that Idaho Power does not consider program applications, which were received by some of the companies listed, to be correspondence. 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 SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 e e SUPPLEMENTAL REQUESTS NOS. 122 & 123: IPC's responses to P.R.'s 122 and 123 deny using DSM tariff rider funds, except for de minimis staff time, for either renewable energy resources or Project Share. Please define "de minimis" and explain why printed material about wind power and project share were included in IPC's response to P.R. _? (darn if i can say exactly which one at the moment) Are any of Project's Share's costs included in IPC's accounts for low-income weatherization (aka weatherization for qualified customers)? When was the "Renewable Energy Specialist" originally included in the "Customer Relations & Energy Effciency" unit? Given that a "Renewable Energy Specialist" is listed under the "Energy Effciency Program Leadet' on the Customer Relations & Energy Effciency organization chart provided in IPC's responses to P.R. 16, please estimate the percentage of time that that Program Leader, the Clerk ", the Customer Relations & Energy Effciency Manager, the Dept. Specialist and anyone else in the Customer Relations & Energy Effciency unit spend on renewable energy issues and projects. SUPPLEMENTAL RESPONSE TO REQUESTS NOS. 122 & 123: The Merriam Webster online dictionary defines de minimis as "lacking significance or importance" or "so minor as to merit disregard." In Response to what Idaho Power assumes to be Staffs Request No. 21, Idaho Power supplied copies of all the customer communications materials currently used by Idaho Power's Customer Relations and Energy Efficiency department's programs. This department administers Idaho Power's energy effciency and demand response programs. IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 e e None of Project's Share's costs are included in IPC's accounts for Weatherization for Qualified Customers program. The Renewable Energy Specialist has been in the Customer Relations and Energy Effciency (formerly the Customer Relations and Research) group since its inception in 2004. The Renewable Energy Specialist has been employed by Idaho Power for over 26 years. This position was formerly an Energy Services Program Specialist 11. Prior to September 2006, this position was supervised by a leader who was notfunded under rate Schedule 91. The Energy Effciency Program Leader dedicates less than one percent of their time supervising the Renewable Energy Specialist. The Clerk II does not spend any time on renewable energy issues or projects. The Customer Relations & Energy Effciency Manager and the Departmental Specialist do spend time on renewable energy issues and projects but they do not separately record their time related to these projects as it is part of their normal business activities and they are not funded under rate Schedule 91. Several other individuals in the Customer Relations and Energy Effciency department spend time on renewable energy issues and projects but they do not separately record their time ,associated with these activities as it is part of their normal business activities and they are not funded under rate Schedule 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 SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 e e SUPPLEMENTAL REQUEST NO. 124: I apologize for not clarifying that ''total compensation" as used in P.R. 124 was intended to mean the sum of salary, bonus, insurances, social security, retirements, etc. In other words, all benefits that employees receive for their work and for which Idaho 'Power incurs a cost. Please amend IPC's , response accordingly. SUPPLEMENTAL RESPONSE TO REQUEST NO. 124: Column C (Salary Min) and Column D (Salary Max) in the attached spreadsheet represent the annual base salary range for each respective position. For non-exempt positions, the numbers shown are based upon 2080 hours worked per year and do not include any potential overtime hours. Column E (Total Comp Min) and Column F (Total Comp Max) represent the total compensation range, which is comprised of the annual base salary range plus the following items: 1) A target incentive payment of 6 percent of the annual salary. This is not guaranteed compensation. (**For the S1, the target Short Term Incentive ("STI") is 10 percent and the target Long Term Incentive ("LTI") is 10 percent, for a total of 20 percent of the annual salary.) 2) A pension benefit amount of 5.69 percent of the annual salary. There is a 5-year cliff vesting for the pension plan, but this figure is included for each position assuming each employee wil reach 5 years with the Company. 3) Payroll taxes equal to 8.4 percent of the annual salary. 4) Health benefits equal to 10.4 percent of the annual salary. 5) Payments for Worker's Compensation Insurance equal to 0.71 percent of the annual salary. IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 e e 6) Under the Employee Savings Plan Contribution, the Company wil match up to 3.52 percent of the annual salary if the employee elects to participate. All percentages shown are averages. With the exception of the incentive payment, the figures shown may be slightly higher or lower depending upon each individual person. For example, the amount contributed for health benefits wil vary from one employee to the next based upon the number of eligible dependents. 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. DATED at Boise, Idaho, this 17th day of October 2008. ßRL 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 SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 e e CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 1 ¡th day of October 2008 I served a true and correct copy of IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL 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 Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 .- Hand Delivered U.S. Mail _ Overnight Mail FAX .- Email Weldon.stutzman(âpuc.idaho.gov Neil Price Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 .- Hand Delivered U.S. Mail _ Overnight Mail FAX .- Email Neil.price((puc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email peter((richardsonandoleary.com Dr. Don Reading Ben Johnson Associates 6070 Hil Road Boise, Idaho 83703 Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email dreading(âmindspring.com 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 Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email rcb((racinelaw.net eloßYracinelaw.net IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 e 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 e Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email tonyCâyankel.net Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email mkurtßYBKLlawfirm.com kboehmCâBKLlawfirm.com Hand Delivered .- U.S. Mail _ Overnight Mail FAX Email Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email khigginsCâenergystrat.com Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email cewCâgivenspursley.com mccCâgivenspursley.com Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email dennvtempCâyahoo.com IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 e e 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 Columbia, MD 21044 Hand Delivered U.S. Mail .- Overnight Mail FAX .- Email Lot.CookeCâhg.doe.gov Arthur. BruderCâhg.doe.gov Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email detheridgeCâexeterassociates.com Community Action Partnership Association Of Idaho Brad M. Purdy Attomey at Law 2019 North 1 ¡th Street Boise, Idaho 83702 Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email bmpurdyCâhotmail.com Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered .- U.S. Mail _ Overnight Mail FAX .- Email kmilerCâsnakeriverallance.org Qii~ Barton L. Kline IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9