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Home My WebLink About20100810Staff 6-23 to IPC.pdfNEIL PRICE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 ISB NO. 6864 oi:r:r: ¡~"\L~~,..., ll ZO\ß AUG to PM 4: 01 IDAHC; lillITI¡r: Sv ¡ ~ .'. z ... 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 IDAHO POWER ) COMPANY'S APPLICATION FOR AN ORDER ) DESIGNATING THE ENERGY EFFICIENCY ) RIDER FUNDS SPENT BY THE COMPANY ) DURING 2008-2009 AS PRUDENTLY)INCURRD EXPENSES. ) ) ) CASE NO. IPC-E-I0-09 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilties Commission, by and through its attorney of record, Neil Price, 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 24, 2010. 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 IDAP A 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 wil augment the documents produced. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 AUGUST 10,2010 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 preparing the documents. Please identify the name, job title, location and telephone number of the record holder. Please provide all Excel and electronic files on CD with formulas activated. REQUEST NO.6: Please provide copies of Idaho Power's last two Demand Side Management (DSM) business plans? REQUEST NO.7: Please provide total Idaho Power personnel-related expenses for the Company's DSM efforts in 2008 and in 2009. REQUEST NO.8: Please provide total Idaho Power office-related expenses for the Company's DSM efforts in 2008 and in 2009. REQUEST NO.9: Please provide total Idaho Power travel-related program expenses for the Company's DSM efforts in 2008 and in 2009. REQUEST NO. 10: Please provide total Idaho Power employee training expenses for the Company's DSM efforts in 2008 and in 2009. REQUEST NO. 11: Please provide the following: a) A current organization char showing all Idaho Power employees, by title and by name, for whom at least 5% of their total Idaho Power compensation is paid with energy efficiency tariff rider funds or who spend at least 5% of their work hours on DSM. b) Complete job descriptions, required qualifications, salary ranges, bonus opportunities, and total compensation ranges, including benefits, for all employees identified above. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 AUGUST 10,2010 REQUEST NO. 12: Please provide the following: a) The organization char in effect on July 1,2009, showing all Idaho Power employees, by title and by name, for whom at least 5% of their total Idaho Power compensation was being paid with energy efficiency tariff rider fuds or who were spending at least 5% of their work hours on DSM. b) Complete job descriptions, required qualifications, salar ranges, bonus opportunities, and total compensation ranges, including benefits, in effect on July 1,2009, for all employees identified above. REQUEST NO. 13: Please identify the person or persons who ultimately decide whether or not Idaho Power wil implement new DSM programs or add new measures to existing programs after Idaho Power has determined such programs or measures will likely be cost- effective. REQUEST NO. 14: Table 2 on page 8 ofIdaho Power's 2009 DSM Anual Report lists, by customer sector, DSM direct expenses, energy and peak load savings, and energy sales. Please provide for those same customer sectors total revenues, base rate revenues, and DSM taiff rider revenues collected for 2008 and for 2009. REQUEST NO. 15: Please provide a matrix showing Idaho Power's expenditures in 2008 and in 2009 for post-implementation DSM program evaluations of impacts, processes, market effects and cost-effectiveness. REQUEST NO. 16: Forthe AC Cool Credit program, please provide Idaho Power's complete criteria used for selecting customers to whom marketing materials are mailed. REQUEST NO. 17: Please provide a detailed description of all changes made to all lighting measures' cost-effectiveness assumptions and calculations in consideration of federal standards changes. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 AUGUST 10,2010 REQUEST NO. 18: Regarding Idaho power's Residential Energy Effciency Lighting program, please provide the following: a) Idaho Power's most recent evaluation of this program. b) An explanation for why no future evaluations are planed through 2012. REQUEST NO. 19: In Case No. IPC-E-09-09, Staff Production Request Nos. 1-5 requested information about Idaho Power's Irrigation Efficiency Rewards Program. In recognition ofIdaho Power's August 4,2009 responses to those five questions, does Idaho Power have additional information or other significant changes to its prior answers relative to the program's continuation in 2008 and 2009? The requests are as follows: a) IPC-E-09-09 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? b) IPC-E-09-09 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? c) IPC-E-09-09 REQUEST NO.3: At the top of page 6 of the Irrigation Efficiency Rewards program description included in Attachment 1, Energy Efficiency Rider Expense Documentation, is the statement that" ...it is expected that Program paricipation wil likely be more constant going forward as many systems that were previously improved become eligible to paricipate in the Program again." a) Is repetitive participation in this program considered an aspect of program success? Please explain. b) Has Idaho Power investigated market transformation for irrigation efficiency? d) IPC-E-09-09 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, summarizing data, and calculating cost-effectiveness based on assumed savings? SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 AUGUST 10,2010 If so, please provide such evaluation(s) and explain why the information was not previously provided. e) IPC-E-09-09 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 suffcient for the Commission to assess prudency of this program's $5.1 milion cost from 2003 through 20077 Please explain. REQUEST NO. 20: Pages 57 and 133 contain tables showing that Weatherization Assistance for Qualified Customers is cost-effective from both the total resource and utilty cost perspectives. a) How has Idaho Power verified both the pre-weatherization and post-weatherization conditions of the weatherized homes? b) Has Idaho Power completed any biling analyses or any other type of impact evaluation of this program? c) What are Idaho Power's plans for future verification of pre- and post- weatherization conditions and program evaluations? REQUEST NO. 21: In Idaho Power's Evaluation Plan shown on page 14 of Supplement 2 of the 2009 DSM Annual Report, future process evaluations are listed for the Residential Energy Education Initiative. Please explain why similar evaluations are not listed for the Commercial Education Initiative. REQUEST NO. 22: Please provide copies of all written internal correspondence or meeting notes in 2008,2009 and 2010 regarding Idaho Power' decision to sign its agreement with the Northwest Energy Effciency Allance (NEEA) for NEEA's current funding cycle. REQUEST NO. 23: Please provide all internal and external correspondence with NEEA or its contractors regarding Idaho Power's decision to provide an additional $160,OÒO to NEEA for the Consumer Electronics Initiative. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 AUGUST 10,2010 DATED at Boise, Idaho, this ¡OtP day of August 2010. Technical Staff: Lynn Anderson i:umisc:prodreq/ipcelO.9npla prod req2.doc SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 6 AUGUST 10,2010 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF AUGUST 2010, SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-IO-09, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: LISA D NORDSTROM DONOV AN E WALKER IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: lnordstrom(iidahopower.com dwalker(iidahopower.com BENJAMIN J OTTO ID CONSERVATION LEAGUE PO BOX 844 BOISE ID 83702 E-MAIL: botto(fidahoconservation.org ANTHONY YANKEL 29814 LAK ROAD BAY VILLAGE OH 44140 E-MAIL: tony(fyanel.net DR DON READING 6070 HILL ROAD BOISE ID 83703 E-MAIL: dreading(imindspring.com DARLENE NEMNICH GREG SAID IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: dnemnich(fidahopower.com gsaid(iidahopower .com ERIC L OLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204 E-MAIL: elo(fracinelaw.net PETER J RICHARDSON GREGORY MADAMS RICHARDSON & O'LEARY PO BOX 7218 BOISE ID 83702 E-MAIL: peter(frichardsonandolear.com greg(frichardsonandolear.com ~ò~~ CERTIFICATE OF SERVICE