20100903IPC to Staff 3.pdf

eslDA~POR~
LISA D. NORDSTROM
Lead Counsel
Inordstromcæidahopower.com
An IDACORP Company
September 3, 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 MATTER OF IDAHO POWER COMPANY'S APPLICA TlON 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 Supplemental Response to the First Production Request of the Commission
Staff to Idaho Power Company in the above matter.
iJ)i2~~
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]
InordstromCâidahopower.com
dwalkerCâidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
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If, , .UTtUrtlto-"'
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
) SUPLEMENTAL RESPONSE TO THE
) FIRST PRODUCTION REQUEST OF
) THE COMMISSION STAFF TO
) IDAHO POWER COMPANY
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
supplemental response to the First Production Request of the Commission Staff to
Idaho Power Company dated August 9, 2010, herewith submits the following
information:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO.3: Please provide a spreadsheet containing the following
information for each customer and each measure incented under the CUSTOM
EFFICIENCY and REBATE ADVANTAGE programs for 2008 and 2009 program years:
. Customer Name
. Contact name
. Customer address and phone number
. Measure(s) implemented
. Energy savings
. Demand reduction
. Method of energy savings and demand reduction calculation
. Incentive amount
. Customer investment
. Measure Implementation date
. Incentive date
. Installation verification date
LYNN ADNERSON AUGUST 30, 2010, E-MAIL REQUEST: Regarding Custom
Efficiency, in the last paragraph on page 8 of Idaho Powets response to Production
Request No.3, are the statements: "The measure implementation date, as requested
by Staff, may vary from a few days to a month prior to incentive payment and these
dates are not electronically stored." And, "The tracking of the installation date varies
from project to project."
As a follow-up to this response, please explain why implementation dates are not
stored electronically and why tracking installation dates varies from project to project.
SUPPLEMENTAL RESPONSE TO REQUEST NO.3: As stated in the
Company's original response to Staffs Production Request No.3, Idaho Power does
not record and store program data in the exact manner as the Staff has asked the
Company to report it. Staff asked for three specific dates in their production request:
(1) measure implementation date, (2) the incentive date, and (3) the installation
verification date. The incentive date is straightforward and tracked in the Custom
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
Efficiency's spreadsheet and Idaho Powets accounting system. For Custom Efficiency,
the measure implementation date and the installation verification date are not so
straightforward. They are often the same date. When Idaho Power staff visits a
complex project which has been developing for months and conducts the final
inspection (or the project is inspected by a third-party engineering firm), these dates are
the same. The installation date can also occur months before the installation is verified.
Prior to an incentive being paid, Idaho Power relies on either an on-site inspection by an
Idaho Power engineer, a third-party engineering firm, an Idaho Power Customer
Representative, or an invoice.
Idaho Power believes that identifying and tracking the implementation date on
projects in Custom Efficiency is not as significant as the verification date of a measure.
Idaho Power uses the verification date as the trigger to pay an incentive. For example,
capital improvement projects are often quite large and complicated and may take
months to complete. It is not simply a matter of installng a new piece of equipment and
turning it on. A good example is a refrigeration project currently being undertaken by an
Idaho Power customer. The equipment was installed during a recent plant shutdown.
The customer continues to debug and tune the control system to this date. One small
piping error was identified that needs to be corrected. Idaho Power engineers wil not
do the final inspection on the system until the equipment is operating as designed. After
the inspection, the incentive wil be paid.
The second part of Staffs Request asks "why tracking installation dates varies
from project to project" and quotes Idaho Powets response, "The tracking of the
installation date varies from project to project." In the Company's original Response to
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
Staffs Production Request No.3, a word was inadvertently omitted. This section
should have stated, "The tracking of the installation verification date varies from project
to project."
The original response continues:
For all large projects, Idaho Power engineers make on-site
visits to confirm that the measure(s) were implemented as
planned. For smaller projects, it is not cost-effective for
Idaho Power engineers to visit all sites for verification
purposes. Rather, Idaho Power uses a combination of
engineer site visits, site visits by other Idaho Power field
personnel, and, in some cases, invoices and pictures taken
of the installation by the customer.
As stated in the Company's original Response to Staffs Production Request No.
3, these files are 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 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.
DATED at Boise, Idaho, this 3rd day of September 2010.
~Il~~
LISA D. NORDS ROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3rd day of September 2010 I served a true and
correct copy of the foregoing IDAHO POWER COMPANY'S SUPPLEMENTAL
RESPONSE TO THE FIRST 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 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 NeiI.PriceCâpuc.idaho.gov
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83702
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email bottoCâidahoconservation.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
-- U.S. Mail
_ Overnight Mail
FAX
-- Email elo~racinelaw.net
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
-- U.S. Mail
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FAX
-- Email tonyCâyankel.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
-- U.S. Mail
_ Overnight Mail
FAX
-- Email peter~richardsonandoleary.com
gregCârichardsonandoleary.com
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email dreading~mindspring.com
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IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6