20100831IPC to Staff 6-23.pdf

esIDA~POR(I
An IDACORP Company
LISA D. NORDSTROM , .i\W(t DLead Counsel ¡PhI gJ ~r,iA
Inordstromcmidahopower.com üTUJ11Eo v w ,"
August 31,2010
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-10-09
IN THE MA ITER OF IDAHO POWER COMPANY'S APPLICATION FOR
AN ORDER DESIGNA TlNG THE ENERGY EFFICIENCY RIDER FUNDS
SPENT BY THE COMPANY DURING 2008-2009 AS PRUDENTLY
INCURRED EXPENSES
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the Second Production Request of the Commission Staff to
Idaho Power Company in the above matter.
'"
Very truly yours,
;f~iC.n~
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom(aidahopower.com
dwalker(aidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
RECEiVED
zina AUG 31 PM l.:40
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 INCURRED EXPENSES.
)
) CASE NO. IPC-E-10-09
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE SECOND
) 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 Second Production Request of the Commission Staff to Idaho Power
Company dated August 10, 2010, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO.6: Please provide copies of Idaho Powets last two Demand
Side Management (DSM) business plans?
RESPONSE TO REQUEST NO.6: The only document that Idaho Power has
produced entitled "Business Plan" was published in 2003. Idaho Power produced a
formal business plan for Demand-Side Management ("DSM") titled Demand-Side
Management at Idaho Power - A Business Plan 2003-2005. An electronic copy of the
aforementioned document is provided on the enclosed CD. Because of limited
availability, a hard copy of the attachment is available for review upon request in Idaho
Power's discovery room.
Idaho Power currently uses a multi-faceted approach to planning. This method
incorporates DSM potential studies, long-term forecasting, including integrated resource
planning, annual strategic planning, annual budget planning, consultation with the
Energy Effciency Advisor Group ("EEAG") and other stakeholders, and governance by
the Energy Efficiency Guiding Council.
The EEAG is comprised of thirteen members, including representatives from the
residential, industrial, commercial, and irrigation sectors, as well as representatives for
the elderly, low income, environmental organizations, state agencies, and public utilty
commissions. Current members of the EEAG include the following individuals:
Energy Effciency Advisory Group
Catherine Chertudi - City of Boise, Public Works Department
Celeste Becia - Idaho Power Company
Don Sturtevant - Simplot
Ken Robinette - South Central Community Action Partnership
Kent Hanway - CSHQA
Linnea Wittekind - Oregon Public Utilty Commission
Lynn Anderson - Idaho Public Utilties Commission
Lynn Young - AARP
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
Mike Youngblood - Idaho Power Company
Nancy Hirsh - Northwest Energy Coalition
Sid Erwin - Idaho Irrigation Pumpers Association
Sue Siefert - Idaho Office of Energy Resources
Tom Eckman - Northwest Power & Conservation Council
The Idaho Power Energy Efficiency Guiding Council is comprised of Company
senior management and representatives from the Customer Relations and Energy
Efficiency Department. Current members of the DSM Executive Guiding Council
include the following individuals:
DSM Executive Guiding Council
Darrel Anderson - Executive Vice President of Administration & CFO
Dan Minor - Executive Vice President of Operations
Ric Gale - Senior Vice President of Corporate Responsibilty
Lisa Grow - Senior Vice President of Power Supply
Warren Kline - Vice President of Customer Operations
Vern Porter - Vice President of Engineering & Operations
Greg Said - General Manager Regulatory Affairs
Theresa Drake - Manager Customer Relations and Energy Efficiency
Celeste Becia - Energy Efficiency Program Leader, Residential
Todd Schultz - Energy Efficiency Program Leader, Commercial/Industrial!
Irrigation
Pete Pengily - Customer Research & Analysis Leader
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO.7: Please provide total Idaho Power personnel-related expenses
for the Company's DSM efforts in 2008 and in 2009.
RESPONSE TO REQUEST NO.7: Idaho Power assumes that the "personnel-
related expenses for the Company's DSM efforts in 2008 and 2009," refers to labor
related expenses. Under its standard bookkeeping process, the Company assigns each
accounting transaction to a detailed cost element ("DCE"). In 2008, Idaho Powets labor
related Idaho Energy Efficiency Rider ("Ridet') expenses were $1,965,698 of
$18,880,276 total Idaho Rider expenses and in 2009 Idaho Power's labor related Idaho
Rider expenses were $2,293,136 of $31 ,821 ,464 total Idaho Rider expenses.
Idaho Power has provided a spreadsheet on the enclosed CD which provides
information reflecting DSM expenses incurred to the Idaho Rider and Idaho Powets
Operations and Maintenance ("O&M"). Totals for these two accounts reconcile with
Appendix 2 of Idaho Powets Demand-Side Management 2008 and 2009 Annual
Reports. Expenses incurred to the Oregon Energy Efficiency Rider ("Oregon Ridet')
and Bonnevile Power Administration ("BPA") are excluded from the information
provided. The spreadsheet included on the enclosed CD contains four tabs. The
Request #07 tab shows labor related expenses (DCEs 100-199) for 2008 and 2009.
The Cost Element Definitions tab defines Idaho Powets DCEs. The 2009 By DCE and
2008 By DCE tabs show all Idaho Rider expenses and Idaho Power O&M DSM related
expenses that were charged to work orders.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO.8: Please provide total Idaho Power office-related expenses for
the Company's DSM efforts in 2008 and in 2009.
RESPONSE TO REQUEST NO.8: Idaho Power assumes that the "offce-
related expenses for the Company's DSM efforts in 2008 and 2009," refers to DCEs 551
and 559. These expenses include offce supplies for the programs and DSM personnel.
Idaho Power assigns each accounting transaction to a DCE. In 2008, Idaho Power's
offce related Idaho Rider expenses were $7,914 of $18,880,276 total Idaho Rider
expenses and in 2009 Idaho Powets office related Idaho Rider expenses were $6,072
of $31 ,821 ,464 total Idaho Rider expenses.
Idaho Power has provided a spreadsheet on the enclosed CD which provides
information reflecting DSM expenses incurred to the Idaho Rider and Idaho Powets
O&M. Totals for these two accounts reconcile with Appendix 2 of Idaho Powets
Demand-Side Management 2008 and 2009 Annual Reports. Expenses incurred to the
Oregon Rider and BPA are excluded from the information provided. The spreadsheet
included on the enclosed CD contains four tabs. The Request #08 tab shows office
related expenses (DCEs 551 and 559) for 2008 and 2009 by Idaho Rider and Idaho
Power O&M. The Cost Element Definitions tab defines Idaho Powets DCEs. The 2009
By DCE and 2008 By DCE tabs show all Idaho Rider expenses and Idaho Power O&M
DSM related expenses that are charged to work orders.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO.9: Please provide total Idaho Power travel-related program
expenses for the Company's DSM efforts in 2008 and in 2009.
RESPONSE TO REQUEST NO.9: Idaho Power assumes that the "travel-
related expenses for the Company's DSM efforts in 2008 and 2009," refers to DCEs
521-534 and 539. Idaho Power assigns each accounting transaction to a DCE. In
2008, Idaho Powets travel related Idaho Rider expenses were $103,964 of
$18,880,276 total Idaho Rider expenses and in 2009 Idaho Powets travel related Idaho
Rider expenses were $93,609 of $31 ,821 ,464 total Idaho Rider expenses.
The expenses assigned to the travel related DCEs contain charges that are for
travel within Idaho Powets service territory (DCEs 521-5~4 and 539), such as mileage
expenses incurred by the Program Specialist and Customer Representatives when
making contractor, customer, or trade ally visits for the purpose of promoting energy
efficiency programs. These DCEs also contain travel to training events, conferences,
and workshops for or conducted by the DSM staff. For instance, some meal expenses
that are included are not travel related but include food provided for contractors or trade
alles during training (DCEs 532 and 539).
Idaho Power has provided a spreadsheet on the enclosed CD which provides
information reflecting DSM expenses incurred to the Idaho Rider and Idaho Powets
O&M. Totals for these two accounts reconcile with Appendix 2 of Idaho Powets
Demand-Side Management 2008 and 2009 Annual Reports. Expenses incurred to the
Oregon Rider and BPA are excluded from the information provided. The spreadsheet
included on the enclosed CD contains four tabs. The Request #09 tab shows travel
related expenses (DCEs 521-534 and 539) for 2008 and 2009 by Idaho Rider and Idaho
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
Power O&M. The Cost Element Definitions tab defines Idaho Powets DCEs. The 2009
By DCE and 2008 By DCE tabs show all Idaho Rider expenses and Idaho Power O&M
DSM related expenses that are charged to work orders.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO. 10: Please provide total Idaho Power employee training
expenses for the Company's DSM efforts in 2008 and in 2009.
RESPONSE TO REQUEST NO. 10: In this Response, Idaho Power has
provided the expenses associated with Personal Memberships and Registrations, DCE
535, for 2008 and 2009. This DCE contains expenses that may not be training related,
such as memberships to professional organizations. Additionally, this DCE would not
capture training in which there was no registration fee. Idaho Powets accounting
system does not differentiate travel related expenses specifically related to training.
The Company assigns each accounting transaction to a DCE. Any travel related
expenses associated with training are contained in the Company's Response to Staffs
Production Request NO.9. In 2008, Idaho Powets Idaho Rider 2008 training related
expenses, as defined above, were $29,203 of $18,880,276 total Idaho Rider expenses
and in 2009 Idaho Powets training related Idaho Rider expenses were $12,120 of
$31,821,464 total Idaho Rider expenses.
Idaho Power has provided a spreadsheet on the enclosed CD which provides
information reflecting DSM expenses incurred to the Idaho Rider and Idaho Power's
O&M. Totals for these two accounts reconcile with Appendix 2 of Idaho Power's
Demand-Side Management 2008 and 2009 Annual Reports. Expenses incurred to the
Oregon Rider and BPA are excluded from the information provided. The spreadsheet
included on the enclosed CD contains four tabs. The Request #10 tab shows training
related expenses (DCE 535) for 2008 and 2009 by Idaho Rider and Idaho Power O&M.
The Cost Element Definitions tab defines Idaho Powets DCEs. The 2009 By DCE and
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
2008 By DCE tabs show all Idaho Rider expenses and Idaho Power O&M DSM related
expenses that are charged to work orders.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST NO. 11: Please provide the following:
a) A current organization chart 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.
RESPONSE TO REQUEST NO. 11:
a) Included on the enclosed CD is a copy of Idaho Powets current
organizational chart for all employees in the Customer Relations and Energy Efficiency
department and all employees who charge time to the Idaho Rider. An exact analysis of
employees who spend at least 5 percent of their work hours on DSM has not been
conducted. Many non-Rider funded employees support the Company's energy
efficiency efforts. Consequently, an exact accounting of who spends at least 5 percent
of their work hours on DSM would be difficult and time consuming. Examples of the
positions which spend considerable time on DSM are:Major Customer
Representatives, Legal staff, Regulatory staff, Corporate Publishing, Printers, Regional
Managers, Customer Service Representatives, Regional Customer Relation Managers,
and others.
Employee names have been redacted from the organizational chart provided.
Idaho Power considers personnel information confidential and as such, this information
is available for Staff to audit at Idaho Powets headquarters upon signing a protective
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10
agreement. Please contact Doug Jones at 388-2615 or Camila Victoria at 388-5821 to
arrange an on-site audit.
(b) The enclosed CD contains work files for all employees in the Customer
Relations and Energy Effciency department and all employees who charge time to the
Idaho Rider. These work files contain job descriptions for Idaho Power staff. Many
Idaho Power employees who do not charge to the Rider spend at least 5 percent of their
work hours on DSM; however, an exact analysis has not been completed to account for
all of these employees (see the Company's Response to Staffs Production Request No.
11(a)). Idaho Power considers salary information confidential and as such, this
information is available for Staff to audit at Idaho Power's headquarters upon signing a
protective agreement. Please contact Doug Jones at 388-2615 or Camila Victoria at
388-5821 to arrange an on-site audit.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST NO. 12: Please provide the following:
a) The organization chart 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 funds or who were
spending 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, in effect on July 1,
2009, for all employees identified above.
RESPONSE TO REQUEST NO. 12:
a) Provided on the enclosed CD is a copy of Idaho Powets July 1, 2009,
organizational chart for all employees in the Customer Relations and Energy Efficiency
department and all employees who charge time to the Idaho Rider. Many Idaho Power
employees who do not charge to the Rider spend at least 5 percent of their work hours
on DSM; however, an exact analysis has not been completed to account for all of these
employees. Many Idaho Power staff who are not Rider funded support the Company's
energy effciency efforts. Consequently, an exact accounting of who spends at least 5
percent of their work hours on DSM would be difficult and time consuming. Examples of
the positions which spend considerable time on DSM are: Major Customer
Representatives, Legal staff, Regulatory staff, Corporate Publishing, Printers, Regional
Managers, Customer Service Representatives, Regional Customer Relation Managers,
and others.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
Employee names have been redacted from the organizational chart provided. Idaho
Power considers this personnel information confidential and as such, this information is
available for Staff to audit at Idaho Powets headquarters upon signing a protective
agreement. Please contact Doug Jones at 388-2615 or Camila Victoria at 388-5821 to
arrange an on-site audit.
b) The enclosed CD contains work files for all employees in the Customer
Relations and Energy Efficiency department and all employees who charge time to the
Idaho Rider as of July 1, 2009. An exact analysis of employees who spend at least 5
percent of their work hours on DSM has not been conducted (see the Company's
Response to Staffs Production Request No. 12(a)). Idaho Power considers salary
information confidential and as such, this information is available for Staff to audit at
Idaho Powets headquarters upon signing a protective agreement. Please contact
Doug Jones at 388-2615 or Camila Victoria at 388-5821 to arrange an on-site audit.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
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 wil
likely be cost-effective.
RESPONSE TO REQUEST NO. 13: The Manager of the Customer Relations
and Energy Efficiency department decides if programs are implemented. Prior to the
final decision of whether or not to offer a program, Idaho Power uses a collaborative
approach to investigate a program's viabilty. After a program or measure is determined
to likely be cost-effective by the Research & Analysis group, Idaho Power staff consults
with the program manager(s), the Energy Effciency Program Leaders, the Customer
Research and Analysis Leader, the EEAG and other stakeholders, and the Energy
Efficiency Guiding CounciL.
The EEAG is comprised of thirteen members, including representatives from the
residential, industrial, commercial, and irrigation sectors, as well as representatives for
the elderly, low income, environmental organizations, state agencies, and public utilty
commissions. Current members of the EEAG include the following individuals:
Energy Effciency Advisory Group
Catherine Chertudi - City of Boise, Public Works Department
Celeste Becia - Idaho Power Company
Don Sturtevant - Simplot
Ken Robinette - South Central Community Action Partnership
Kent Hanway - CSHQA
Linnea Wittekind - Oregon Public Utilty Commission
Lynn Anderson - Idaho Public Utilties Commission
Lynn Young - AARP
Mike Youngblood - Idaho Power Company
Nancy Hirsh - Northwest Energy Coalition
Sid Erwin - Idaho Irrigation Pumpers Association
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
Sue Siefert - Idaho Offce of Energy Resources
Tom Eckman - Northwest Power & Conservation Council
The Idaho Power Energy Efficiency Guiding Council is comprised of Company
senior management and representatives from the Customer Relations and Energy
Efficiency Department. Current members of the DSM Executive Guiding Council
include the following individuals:
DSM Executive Guiding Council
Darrel Anderson - Executive Vice President of Administration & CFO
Dan Minor - Executive Vice President of Operations
Ric Gale - Senior Vice President of Corporate Responsibilty
Lisa Grow - Senior Vice President of Power Supply
Warren Kline - Vice President of Customer Operations
Vern Porter - Vice President of Engineering & Operations
Greg Said - General Manager Regulatory Affairs
Theresa Drake - Manager Customer Relations and Energy Effciency
Celeste Becia - Energy Effciency Program Leader, Residential
Todd Schultz - Energy Efficiency Program Leader, Commercial/Industrial/
Irrigation
Pete Pengily - Customer Research & Analysis Leader
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
REQUEST NO. 14: Table 2 on page 8 of Idaho Powets 2009 DSM Annual
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 tariff rider revenues collected for 2008 and for 2009.
RESPONSE TO REQUEST NO. 14: The below table shows 2008 and 2009 total
Company revenues and total DSM tariff rider revenues, including Idaho and Oregon.
Base rate revenues are not available in total or by sector because when revenues are
received, base revenues are not tracked separately.
TOTAL COMPANY REVENUE TOTAL RIDER REVENUE
2008 2009 2008 2009
Residential $353,261 ,718.31 $409,479,319.22 $ 6,122,940.72 $12,288,496.08
Commercial $203,035,114.88 $232,815,684.32 $ 3,679,717.52 $ 6,857,260.18
Industrial $122,302,387.56 $141,529,985.29 $ 2,070,471.19 $ 3,716,882.92
IrriQation $105,711,521.28 $109,654,508.71 $ 2,010,472.01 $ 3,720,445.06
Total Tariff
Rates $784,310,742.03 $893,479,497.54 $13,883,601.44 $26,583,084.24
Accrued
Interest $(17,116.22)$ (167,553.53)
Total
Revenue $784,310,742.03 $893,479,497.54 $13,866,485.22 $26,415,530.71
The response to this Request was prepared by Darlene Nemnich, Senior
Regulatory Affairs Analyst, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST NO. 15:Please provide a matrix showing Idaho Powets
expenditures in 2008 and in 2009 for post-implementation DSM program evaluations of
impacts, processes, market effects and cost-effectiveness.
RESPONSE TO REQUEST NO. 15: Idaho Power provided a matrix of all
studies performed during 2008 and 2009 on pages 30-32 of the Demand-Side
Management 2009 Annual Report, Supplement 2: Evaluation. As stated under 5.b.,
page 3 of The Memorandum of Understanding ("MOU") for Prudency Determination of
DSM Expenditures signed by Staff on January 25, 2010, and published on page 2 of the
Company's Demand-Side Management 2009 Annual Report, Supplement 1: Cost-
Effectiveness ("Supplement 1 "):
A copy of each DSM evaluation completed since filng the
previous DSM annual report wil be included as an appendix
to the annual DSM report, as well as any confidential cost
information that are not included. The utilty wil supplement
its DSM report with any confidential cost information once
the Staff has signed a protective agreement with the utilty.
In adherence with the MOU, Idaho Power wil make available to Staff for audit all
expenses paid to third parties in 2008 and 2009 for evaluations upon request following
the execution of a protective agreement. Please contact Doug Jones at 388-2615 or
Camila Victoria at 388-5821 to arrange an on-site audit.
As a point of clarification, only evaluation expenses for studies conducted by third
parties are directly tracked and accounted for in program expenses. General expenses
for internally conducted customer surveys, cost-effectiveness analyses, or evaluations,
which generally only include Idaho Power labor, are charged to the Research and
Analysis group. Expenses for evaluations performed by the Northwest Energy
Efficiency Allance applicable to Idaho Powets service territory and included in the
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
Company's Demand-Side Management 2009 Annual Report, Supplement 2: Evaluation
are not tracked individually.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
REQUEST NO. 16: For the AC Cool Credit program, please provide Idaho
Powets complete criteria used for selecting customers to whom marketing materials are
mailed.
RESPONSE TO REQUEST NO. 16: Customers selected to receive marketing
materials for the AlC Cool Credit program are in the geographic area where the
infrastructure required to support AC Cycling has been installed and is operational
(once the lack of paging in the Twin Falls and Pocatello area was discovered, marketing
to those areas was suspended). Areas that are currently targeted are Ada, Canyon,
Elmore, Gem, Payette, and Washington counties in Idaho and Malheur County in
Oregon. As stated in the Company's Response to Staffs Production Request NO.4,
currently, Idaho Power is only installng switches where the Advanced Metering
Infrastructure system is available.
In addition to the geographic criteria, other criteria include customers that:
. Have an active Idaho Power Utilty Service Agreement
. Do not have a bil factor in Idaho Powets Customer Information
System ("CIS+") of "AIRCON" (which would indicate a current or
previous participant)
. Have Premise Type in CIS+ of house (rather than barn, shop, etc.)
. Have a marketing Information Indicator of yes in CIS+ indicating
that the customer has not requested all marketing material be
stopped
. Has Electricity use equal or greater than 500 kWh for the most
recent month of July (this helps to target customers who actually
have central AlC)
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
The marketing list is further edited by removing:
· Customers who have called, e-mailed, or returned an enrollment
card saying they are not interested in the AlC Cool Credit program
· Customers who have sent in their enrollment form but have not yet
had a switch installed
· Customers who have already been turned down for an install
(equipment not in good working order, no access, etc.)
· Out of country and APO-type addresses, addresses that specifically
reference shop, barn, pump, garage, etc.
The intent of these criteria is to reach the targeted group of residential customers
with operational central air-conditioning, which primarily include single-family, owner-
occupied homes.
Some very specific targeted mailngs have been used, for instance, targeting
Green Power participants that were not already program participants. For marketing to
the Mountain Home Air Force Base participants, the program manager has worked
directly with the Company's contact on the base.
Even though bil stuffers have been an effective and inexpensive method of
marketing the program, it is not possible to target market as much as it is for regular
mailngs. Bil stuffers can only be restricted based on customer type (residential) and
county. It is not possible to prevent them from being mailed to customers who are
already on the program, or who have already said they are not interested.
In order to understand customers who are or are not current customers of the
program, the Company has also engaged in demographic research using PRIZM(! data,
which is third-part demographic data licensed through CLARITAS, a subsidiary of
Nielsen Media. Using demographic information such as income, age, education,
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
household type, home ownership status, and other variables that CLARITAS has
gathered on Idaho households, the PRIZM(! codes are appended to customer records,
allowing segmentation of customers into 66 different groups defined by CLARITAS.
Segmentation analysis allows for both the analysis of current participants and for
assessing potential targeted segments for marketing. Demographic analysis is also
used to calibrate the appropriate messaging of marketing materials based on the
exhibited characteristics of current participants. As the Company moves more towards
targeted marketing and away from bulk mailngs for the AlC Cool Credit program, it is
expected that demographic targeting wil have an increased role in increasing marketing
effectiveness.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
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.
RESPONSE TO REQUEST NO. 17: During the 2008 and 2009 time period, no
changes were made to cost-effectiveness assumptions and calculations for lighting
measures in consideration of the upcoming federal changes which wil be phased in
beginning in 2012. A description of the Energy Independence and Security Act of 2007
is included on page 29 of Idaho Powets Demand-Side Management 2009 Annual
Report. Idaho Power does update cost-effectiveness models when new information is
released. Most commercial lighting assumptions, including measure life, costs, and
savings, were updated when Idaho Powets Demand-Side Management Potential Study
was completed in 2009. Residential compact fluorescent light bulb ("CFL") savings
were updated when the Regional Technical Forum ("RTF") approved changes to retail
sales assumptions in May 2009.
The federal changes are being considered in future program design changes for
the 2011 and 2012 period. T-12 fixture replacements wil continue through 2011. The
commercial lighting incentives offered after July 2012 wil be determined in 2011. The
retailer markdown on CFL twist bulbs wil end in 2011. Despite these federal changes,
there are stil potential savings to be gained in lighting. As noted by the Northwest
Energy Effciency Allance ("NEEA") at the June 2, 2010, Cost-Effectiveness Advisory
Committee meeting, market saturation is less than what was originally forecasted in
2008. According to KEMA and the National Electrical Manufacturets Association
("NEMA"), overall CFL sales declined in 2008 and 2009 both regionally and nationally.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23
REQUEST NO. 18: Regarding Idaho Powets Residential Energy Efficiency
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 planned through 2012.
RESPONSE TO REQUEST NO. 18:
a) The most recent evaluations of the residential energy efficiency lighting
program conducted by NEEA, but which included Idaho Powets service territory, were
the 2008 ENERGY STAR(! Consumer Products Lighting Market Progress Evaluation
Report and the 2008-2009 CFL Tracking Study Market Progress Evaluation. These two
evaluations were managed by NEEA and were included on the CD titled "NEEA Market
Effects Evaluations Report" provided with the Company's Demand-Side Management
2009 Annual Report, Supplement 2: Evaluation.
b) Idaho Powets current Evaluation Plan does not include the Residential
Energy Effciency Lighting program due to the expected impacts of the Energy
Independence and Security Act of 2007 ("EISA"). A description of the EISA is included
on page 29 of Idaho Powets Demand-Side Management 2009 Annual Report. The
Company is reviewing the program impacts of the law and is planning to make
appropriate program changes as needed. Once the program is implemented reflecting
the EISA, Idaho Power wil revise its Evaluation Plan accordingly.
Historically, Idaho Power has claimed savings from the Residential Energy
Efficiency Lighting program based on deemed savings from the RTF. The savings are
derived from evaluations and field tests. In 2010, Idaho Power updated the claimed
savings from this program due to an updated deemed savings value from the RTF.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25
REQUEST NO. 19: In Case No. IPC-E-09-09, Staff Production Request Nos. 1-
5 requested information about Idaho Powets Irrigation Effciency Rewards Program. In
recognition of Idaho Powets 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 Effciency Rewards program from the perspective of
program participants? 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 of IPC's program?
c) IPC.E.09.09 REQUEST NO.3: At the top of page 6 of the
Irrigation Effciency Rewards program description included in Attachment 1, Energy
Efficiency Rider Expense Documentation, is the statement that "...it is expected that
Program participation wil likely be more constant going forward as many systems that
were previously improved become eligible to participate 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?
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26
d) IPC-E-09-09 REQUEST NO.4: Has any post-implementation
evaluation (impact, process, or market effects) of Idaho Powets 2003-2007 Irrigation
Effciency Rewards program been completed beyond reviewing payments, summarizing
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.
e) IPC-E-09-09 REQUEST NO.5: Idaho Power states that it "plans to
conduct billng analyses of participants in the Irrigation Efficiency Rewards program"
and pursue "exploration of opportunities to partner with other regional organizations to
conduct an updated impact evaluation of the Program." Is it Idaho Powets 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.
RESPONSE TO REQUEST NO. 19:
a) Yes, please see page 59 of Supplement 1 of Idaho Powets Demand-Side
Management 2009 Annual Report. As was agreed upon in the MOU for Prudency
Determination of DSM Expenditures signed by Staff on January 25, 2010, and
published on page 2 of Supplement 1 of Idaho Powets Demand-Side Management
2009 Report:
Idaho Power determines cost-effectiveness on a measure
basis, where relevant, and program basis. As part of the
Demand-Side Management 2009 Annual Report
Supplement 1: Cost-Effectiveness and where applicable,
Idaho Power has begun publishing the cost-effectiveness by
measure, calculating the participant cost test (PCT) at the
program level, listing the assumptions associated with cost-
effectiveness, and citing sources and dates of metrics used
in the cost-effectiveness calculation. In future demand-side
management annual reports, Idaho Power wil also include
the Rate Payer Impact (RIM) test as specified in the
memorandum of understanding (MOU) included in
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 27
Supplement 2: Evaluation. Within the MOU the IPUC staff
has agreed to provide reasonable and necessary leeway for
the implementation of the guidelines described in the MOU
for the Demand-Side Management 2009 Annual Report.
Additional information pertaining to Idaho Powets cost-effectiveness calculations
is contained in Supplement 1 under the heading of "Cost-Effectiveness." Specific
program metrics, assumptions, and cost-effectiveness ratios for the Irrigation Effciency
Rewards program can be found on pages 59 and 60 of Supplement 1.
b) In addition to the information provided to Staff in IPC-E-09-09, as noted in
footnote (f) on page 60 of Supplement 1, "Net-to-Gross (NTG) percentage of 75% is
included in energy saving estimate" to account for "free-ridership."
c) In addition to the information provided to Staff in IPC-E-09-09, in 2009,
Idaho Power joined with representatives from BPA, the Energy Trust of Oregon ("ETO"),
the RTF, and Rocky Mountain Power to form an RTF subcommittee to review deemed
measures for irrigation hardware applications. One of Idaho Power's purposes of
working with the subcommittee was to explore different ideas for energy savings
validation, measurement and verification studies, and/or evaluation efforts. Idaho
Power participated in four meetings and conference calls with the RTF subcommittee
during 2009. At the January 5,2010, meeting, the subcommittee presented its findings,
and the RTF agreed upon the methodology for calculating the deemed irrigation
hardware measures. The RTF concluded that utilities should make appropriate
adjustments to the inputs for calculating energy savings for unique service area
characteristics. The RTF's decision stated that the deemed irrigation measures should
be reviewed in thirteen months.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28
Idaho Power has not completed an impact evaluation of the Irrigation Effciency
Rewards program. The Company stil plans to complete a biling analysis of participants
in 2010. The Company believes its customers are best served by waiting for the results
of evaluations currently underway in the region. The meeting minutes of the January 5
meeting of the RTF state, ". . . Rocky Mountain Power is conducting an evaluation of
savings from its irrigation hardware program; the evaluator has been selected and the
work wil begin shortly. We wil have information from the Idaho market. . . ."
The Company also believes that the market is not 100 percent transformed while
inefficient equipment is widely available to its customers, as is currently the case.
d) In addition to the information provided to Staff in Case No. IPC-E-09-09, in
2010, Idaho Power issued a request for proposal to hire a contractor to perform process
evaluations of several energy effciency programs. Idaho Power currently has a
contract in place with a third party to conduct a process evaluation of the Irrigation
Efficiency Rewards program.
Please note that the MOU was finalized in January 2010 and on page 3, 5.a.
states:
a. It is anticipated that over a reasonable frequency
cycle (e.g., 2 to 3 years), all substantial programs wil have
undergone process and impact evaluations. However, Staff
agrees that the initial evaluation cycles may be longer for
2008 and 2009 programs until these guidelines are fully
implemented.
In 2009, Idaho Power joined with representatives from BPA, the ETO, the RTF,
and Rocky Mountain Power to form an RTF subcommittee to review deemed measures
for irrigation hardware applications. One of Idaho Powets purposes of working with the
subcommittee was to explore different ideas for energy savings validation,
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 29
measurement and verification studies, and/or evaluation efforts. Idaho Power
participated in four meetings and conference calls with the RTF subcommittee during
2009. At the January 5, 2010, meeting, the subcommittee presented its findings, and
the RTF agreed upon the methodology for calculating the deemed irrigation hardware
measures. The RTF concluded that utilties should make appropriate adjustments to
the inputs for calculating energy savings for unique service area characteristics. The
RTF's decision stated that the deemed irrigation measures should be reviewed in
thirteen months.
Idaho Power has not completed an impact evaluation of the Irrigation Effciency
Rewards program. The Company has included an impact evaluation of the Irrigation
Efficiency Rewards program in its Evaluation Plan for 2011. Idaho Power believes it is
in the best interests of its customers to await the results of similar studies currently
underway in the region. The meeting minutes of the January 5 meeting of the RTF
state, ". . . Rocky Mountain Power is conducting an evaluation of savings from its
irrigation hardware program; the evaluator has been selected and the work wil begin
shortly. We wil have information from the Idaho market. . . ."
e) Idaho Power expects the Commission to assess prudency of its Irrigation
Effciency program based on the fact that the Company has demonstrated the program
to be cost-effective from the utility perspective, the total resource cost perspective, and
the participant cost perspective. Idaho Power has had the savings methodology for this
program validated by the RTF and has had the program design vetted through EEAG.
The Company has complied with the spirit and the specifications of the MOU signed by
Staff and Idaho's other investor-owned electric utilties. Additionally, as stated earlier in
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30
this Response, Idaho Power is continuing its evaluation of the program. It is currently
under contract with a third party to conduct a process evaluation of the Irrigation
Efficiency Rewards program, it has an impact evaluation scheduled for 2011, it plans on
completing a biling analysis in 2010, and it is working collaboratively with the RTF,
BPA, and Rocky Mountain Power to evaluate the mutually similar irrigation programs.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31
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 Powets plans for future verification of pre- and post-
weatherization conditions and program evaluations?
RESPONSE TO REQUEST NO. 20: As a point of clarification, Rider funds are
not used to fund the Weatherization Assistance for Qualified Customers ("WAQC")
program. Consequently, WAQC expenses are not included in the Idaho Rider
expenses in Case No. IPC-E-10-09 for which the Company is asking for a determination
of prudency.
a) Idaho Power participates in the State of Idaho Weatherization Assistance
Program. According to the State of Idaho Weatherization Assistance Program 2010
grant application, on page 27, "AII agencies will receive on-site reviews (of completed
jobs) and file reviews." In addition to Energy Programs Coordinator review of files and
completed jobs, at least one agency weatherization staff from each agency conducts a
peer exchange review. During these reviews, approximately five percent of participating
homes are visited and job completion is verified. According to the Idaho Weatherization
Operations Manual, Section 5.1 titled Program Monitoring, ". . . the State wil conduct
on-site visits to each sub-grantee during the contract period. The focus of the on-site
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 32
visits wil be to provide training and technical assistance and conduct inspections of
weatherized homes."
b) No.
c) Idaho Power plans to participate in the State of Idaho Weatherization
Assistance Program and utilze the EA-4 softare developed and owned by the State to
validate the energy savings impact of the program. According to the Idaho
Weatherization Operations Manual, Section 5.2 titled Periodic Evaluations, "Department
of Energy (DOE) and Health and Human Services conduct periodic reviews of the State
of Idaho, Department of Health and Welfare as it pertains to Weatherization Services
and may include reviews of the Subgrantees jobs and accompanying records for
programs under this part."
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 33
REQUEST NO. 21: In Idaho Powets 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.
RESPONSE TO REQUEST NO. 21: It was an oversight by the Company not to
include the Commercial Education Initiative in the Evaluation Plan. Idaho Power is
currently under contract with a third party to evaluate the Commercial Education
Initiative along with several other programs. The other energy efficiency programs that
are currently being evaluated by third-part contractors include Building Effciency,
Custom Efficiency, Easy Upgrades, Irrigation Effciency Rewards, Heating and Cooling
Efficiency, Home Improvement, Energy House Calls, and the Residential Energy
Education Initiative.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 34
REQUEST NO. 22: Please provide copies of all written internal correspondence
t
or meeting notes in 2008, 2009 and 2010 regarding Idaho Powet (sic) decision to sign
its agreement with the Northwest Energy Efficiency Allance (NEEA) for NEEA's current
funding cycle.
RESPONSE TO REQUEST NO. 22: As a point of clarification, the dollars used
to fund NEEA in its current funding cycle (2010-2014) are not included in the Idaho
Energy Efficiency Rider expenses in IPC-E-10-09 for which the Company is asking for a
determination of prudency.
Notwithstanding the foregoing, included on the enclosed CD are copies of all
discoverable written internal correspondence and meeting notes regarding Idaho
Powets decision to sign its agreement to fund NEEA during the 2010-2014 funding
cycle. Idaho Power has not provided e-mails subject to attorney-client privilege nor
those containing attorney-work product.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 35
REQUEST NO. 23: Please provide all internal and external correspondence with
NEEA or its contractors regarding Idaho Power's decision to provide an additional
$160,000 to NEEA for the Consumer Electronics Initiative.
RESPONSE TO REQUEST NO. 23: Included on the enclosed CD are copies of
all known internal and external correspondence with NEEA or its contractors regarding
Idaho Powets decision to provide an additional $160,000 to NEEA for the Consumer
Electronics Initiative.
The response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 31st day of August 2010.
~lJ't~LISA D. NORDTRõ
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 36
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 31st day of August 2010 I served a true and
correct copy of the foregoing IDAHO POWER COMPANY'S RESPONSE TO THE
SECOND 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
Neil Price
Deputy Attomey General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-l Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email NeiI.Price(apuc.idaho.gov
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83702
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email botto(aidahoconservation.org
Idaho Irrigation Pumpers
Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email elo(aracinelaw.net
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email tony(ayankel.net
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-l U.S. Mail
_ Overnight Mail
FAX
-l Email peter(arichardsonandoleary.com
greg(arichardsonandoleary.com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 37
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
-. U.S. Mail
_ Overnight Mail
FAX
-. Email dreading(amindspring.com
~Q'1~
Lisa D. Nordstrom
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 38