20090714Staff 1-16 to IPC.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
RECEiVED
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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 A
PRUDENCY DETERMINATION OF
ENERGY EFFICIENCY RIDER FUNDS
SPENT IN 2002-2007
)
) CASE NO. IPC-E-09-09
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilties Commission, by and though 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
TUESDAY, AUGUST 4, 2009.
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 supplementa responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 JULY 14,2009
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 preparng the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Has Idaho Power calculated the benefit/cost ratio of its Irrigation
Efficiency Rewards program from the perspective of program paricipants? If so, please provide
such calculations and data sources. If not, why not?
REQUEST NO.2: Of the 2,127 irrigation efficiency program projects completed from
2003 through 2007, how many does Idaho Power estimate would have been completed in the
absence ofIPC's program?
REQUEST NO.3: At the top of page 6 of the Irrigation Efficiency Rewards program
description included in Attchment 1, Energy Efficiency Rider Expense Documentation, is the
statement that "...it is expected that Program paricipation will likely be more constant going
forward as many systems that were previously improved become eligible to paricipate in the
Program again."
a) Is repetitive paricipation in this program considered an aspect of program success?
Please explain.
b) Has Idaho Power investigated market transformation for irrgation effciency?
REQUEST NO.4: Has any post-implementation evaluation (impact, process, or market
effects) of Idaho Power's 2003-2007 Irrigation Effciency Rewards program been completed
beyond reviewing payments, sumarzing data, and calculating cost-effectiveness based on
assumed savings? If so, please provide such evaluation(s) and explain why the information was
not previously provided.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JULY 14,2009
REQUEST NO.5: Idaho Power states that it "plans to conduct biling analyses of
paricipants in the Irrigation Effciency Rewards program" and pursue "exploration of
opportunities to parner with other regional organizations to conduct an updated impact evaluation
of the Program." Is it Idaho Power's position that these assertions are sufficient for the
Commission to assess prudency of this program's $5.1 milion cost from 2003 through 2007?
Please explain.
REQUEST NO.6: At the bottom of page 5 of the ENERGY STAR Lighting Program
description included in Attchment 1, Energy Efficiency Rider Expense Documentation, is the
statement that "A copy of this study was made available in Response No. 91 in IPUC Case No.
IPC-E-08-10." The study referenced was contracted with KEMA in 2006 for a consumer lighting
surey anØ it was not included on the list of studies provided by Idaho Power in its Response to
Productioh Request 91. Please identify where in IPC's Response to Production Request 91 the
i
results of this surey exist.
I
¡
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!lQUEST NO.7: At the bottom of page 6 of the Building Efficiency program
descriptioh included in Attachment 1, Energy Efficiency Rider Expense Documentation, it is
¡stated tha~ evaluation results for four of 14 measures in this program will be available in 2009.
Please deJcribe how the evaluator or Idaho Power wil adjust the program's benefit/cost
iicalculatio:ts to reflect estimates of projects that would have been completed in the absence of the
I
program? I
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RtQUEST NO.8: Given that there is not yet an evaluation of any measure for any year
!
of the Bui~ding Efficiency program available for Commission review and that the evaluation
!
results expected later this year wil include only four of 14 measures in this program, on what
I
basis doe~ Idaho Power believe the Commission should find that Idaho Power's expenses of$l.3
milion fr~m 2004 through 2007 were reasonable and prudent?
I
¡
RtQUEST NO.9: What is the process by which IPC's manager of the Easy Upgrades
!
program crmmunicates concerns about measure lives or savings with IPC's manager of energy
effciency I evaluation?
IFIRST Pi~.oDUCTION REQUEST TOIDAHO POWER COMPANY 3 JULY 14,2009
REQUEST NO. 10: Has Idaho Power calculated the benefit/cost ratio of its Easy
Upgrades program from the paricipant perspective? If so, please provide such calculations and
data sources. If not, why not?
REQUEST NO. 11: Given that Idaho Power's first formal post-implementation
evaluation of the Easy Upgrade Program is not planed until 2010, on what basis does Idaho
Power believe the Commission should find that Idaho Power's expenses of$0.7 millon from
2006 through 2007 were reasonable and prudent?
REQUEST NO. 12: At the top of page 5 of the A/C Cool Credit program description
included in Attchment 1, Energy Efficiency Rider Expense Documentation, is the statement that
"The A/C Cool Credit continues to perform as expected by the Company." Please explain how
this statement aligns with paricipation growth rates that have been significantly and consistently
below the Company's targeted/expected growth rates?
REQUEST NO. 13: The "Program Analysis and Validation" and "Program Evaluation"
sections of the A/C Cool Credit program description included in Attachment 1 and the three
Sumit Blue evaluations (provided in IPC's Response to Production Request 91 in IPC-E-08-1O)
describe how the program's peak load savings were calculated and verified and offer some
insights into quality assurance and customer satisfaction. However, Idaho Power has not
provided for Commission review any overall program evaluation (marketing and process, in
addition to impact) that might explain: 1) why paricipation in the program consistently lags the
Company's targets; 2) why invitations to paricipate are not more efficiently and more effectively
targeted; 3) how the several program glitches were allowed to occur. Given the above, combined
with the program's current lack of cost-effectiveness, on what basis does Idaho Power believe the
Commission should find that Idaho Power's expenses of $2.4 millon from 2003 through 2007
were reasonable and prudent?
REQUEST NO. 14: The "Program Cost Effectiveness" section of the Heating and
Cooling Efficiency program description included in Attchment 1, Energy Efficiency Rider
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 JULY 14,2009
Expense Documentation, explains that the program's lack of cost-effectiveness in 2006 and 2007
was due to starup costs that remained unexpectedly high and paricipation that was lower than
expected. With program changes Idaho Power said it expected cost-effectiveness will be
achieved in 2009. Please explain the basis for the Commission to find that Idaho Power's
expenses of $0.5 milion from 2006 through 2007 were reasonable and prudent?
REQUEST NO. 15: The table on page 2 of the Building Operator Training program
description included in Attchment 1, Energy Efficiency Rider Expense Documentation, includes
benefit/cost (B/C) ratios of 8.31 from the utilty perspective and 8.08 from the total resource cost
perspective for this program's operation in 2003 and 2004. Under the "Program Development"
heading, Idaho Power stated that this training program was terminated due to its resources being
needed to develop the Custom Effciency and Building Efficiency programs. IPC's 2008 DSM
Report shows these latter two programs having much lower purorted B/C ratios than shown for
the defuct Building Operator Training program. Please explain how it was prudent to end a more
cost-effective program in order to use that program's resources for less cost-effective programs.
REQUEST NO. 16: In the last paragraph of the first page (Page 11) of the Cost-
Effectiveness description included in Attchment 1, Energy Efficiency Rider Expense
Documentation, Idaho Power states that it relies on the Electric Power Research Institute End Use
Technical Assessment Guide (TAG) and the California Standard Practice Manual to assess the
cost-effectiveness of its DSM programs. Both of these cost-effectiveness guides state that the
benefits of energy efficiency programs should be expressed as "net benefits," i.e. excluding
energy efficiency benefits that would have occurred in the absence of programs. Please list each
ofIdaho Power's programs with an indication of whether the benefit/cost ratio is calculated using
net benefits or gross benefits. For those programs in which net benefits were used, provide a brief
description of how net benefits were estimated. For those programs in which net benefits were
not used, explain why not.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 JULY 14, 2009
DATED at Boise, Idaho, this \~ay of July 2009.
if-L~
Weldon Stutzman
Deputy Attorney General
Technical Staff: Lynn Anderson
i:umisc:prodreqlipce09.9wsla prod reqI
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 6 JULY 14,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF JULY 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-09-09, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom(fidahopower.com
bkline(fidahopower .com
DARLENE NEMNICH
JOHNRGALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dnemnich(fidahopower.com
rgale(fidahopower .com
Jo~SECRETA y ~
CERTIFICATE OF SERVICE