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Home My WebLink About20111021IPC 1-21 to CAPAI.pdfan.isIDA~POR(I LISA D. NORDSTROM Lead Counsel InordstromCâidahopower.com An IDACORP Company October 20, 2011 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilties Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-11-08 General Rate Case Dear Ms. Jewell: Enclosed for filing are an original and one (1) copy of Idaho Power Company's First Production Request to Community Action Partnership Association of Idaho in the above matter. Very truly yours, Je.vf/1~ 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) JASON B. WILLIAMS (ISB No. 8718) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 InordstromCcidahopower.com dwalkerCcidahopower.com jwilliamscaidahopower.com Attorneys for Idaho Power Company '" ,. r: 1" r.,~..,r.-,\ t: ,~~/ i: . 201 I OCT 20 Pri q: 37 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR ELECTRIC )SERVICE IN IDAHO. ) ) ) ) ) CASE NO. IPC-E-11-08 IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), by and through its attorneys, and hereby requests that the Community Action Partnership Association of Idaho ("CAPAI") answer the following production requests and provide the following information and documents in accordance with the Idaho Public Utilties Commission's ("Commission") Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. To allow the Company to utilze these responses in preparing its rebuttal testimony, it is necessary that the responses to these production requests be provided as soon as possible, but no later than November 1 0, 2011. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 1 This production request is to be deemed continuing in nature and CAPAI is requested to provide, through supplementation, additional documents or information that are responsive to this request that it, or any person acting on its behalf, may later come into possession or become aware of. REQUEST FOR PRODUCTION NO.1: Please provide a copy of all materials, analyses, and workpapers created or relied upon by Ms. Ottens in preparing her testimony. REQUEST FOR PRODUCTION NO.2: Please provide a copy of all materials, analyses, and workpapers created or relied upon by Ms. Ottens in preparing her testimony concerning rate of return. REQUEST FOR PRODUCTION NO.3: On page 23, line 15 of her testimony, Ms. Ottens refers to "an average 20 year waiting list for these applicants." Please explain what inputs were used in this calculation and the formula by which this number was derived. REQUEST FOR PRODUCTION NO.4: Please provide the actual number of applicants on the Idaho State Weatherization Assistance Program ("WAP") wait list. Of these applicants, how many qualify for Idaho Power's Weatherization Assistance for Qualified Customers ("WAQC") program? REQUEST FOR PRODUCTION NO.5: On page 23, lines 14-15 of her testimony, Ms. Ottens states that "(in) Ada County alone there are 6000 homes that are eligible for WAQC funding. Based on current levels of funding, this equate(s) to an average 20 year waiting list for these applicants." (Emphasis added.) Have the occupants of these 6,000 homes actually been qualified to participate in WAQC? IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 2 REQUEST FOR PRODUCTION NO.6: Have the 6,000 homes/occupants referenced above in Production Request NO.5 been qualified for WAP or are they automatically placed on the WAQC waiting list based solely upon their eligibilty? REQUEST FOR PRODUCTION NO.7: Must applicants on the 20-year waiting list apply annually to participate in WAP? Do the applications of unserved applicants carry over year-to-year? Please explain. REQUEST FOR PRODUCTION NO.8: Do Community Action Partnership ("CAP") agencies automatically enroll Low Income Home Energy Assistance Program ("L1HEAP") recipients in WAP or do CAP agencies allow L1HEAP recipients to apply separately? Please explain. REQUEST FOR PRODUCTION NO.9: How many of the applicants on the WAP wait list live in tribal territory Of these, how many that live in Idaho Powets service territory qualify for WAQC? REQUEST FOR PRODUCTION NO. 10: For each year from 2005 to the present, how many people applied for WAQC? REQUEST FOR PRODUCTION NO. 11: For each year from 2005 to the present, how many WAQC applicants were in fact qualified to receive service? REQUEST FOR PRODUCTION NO. 12: For each year from 2005 to the present, what number of WAQC applicants on the waiting list resulted in projects benefitting Idaho Power customers? REQUEST FOR PRODUCTION NO. 13: For each year from 2005 to the present, how many applicants on the WAQC waiting list were subsequently found to not be qualified due to use of a heat source other than electricity provided by Idaho Power? IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 3 REQUEST FOR PRODUCTION NO. 14: How many applicants are on the WAP wait list for non-Idaho Power fuel vendors (e.g., propane, wood, natural gas)? REQUEST FOR PRODUCTION NO. 15: On page 14, lines 16-17, Ms. Ottens states that "CAPAI seeks the $1.5 millon increase necessary to simply bring Idaho Power into relative parity with AVISTA." Please provide all studies and other documentation demonstrating that this level of funding is required to satisfy the need for low-income weatherization. REQUEST FOR PRODUCTION NO. 16: Please provide all studies and other documentation demonstrating that the need for low-income weatherization in the Avista, Rocky Mountain Power, and Idaho Power service territories is proportional to the amount of weatherization assistance funding provided by each utility. REQUEST FOR PRODUCTION NO. 17: Did the existence of Idaho Power's Weatherization Solutions Program in any way impact the amount of WAQC funding requested by CAPAI? If so, how? REQUEST FOR PRODUCTION NO. 18: Is it CAPAI's intent to set WAQC funding at a level that wil eliminate the WAP list? Please explain. REQUEST FOR PRODUCTION NO. 19: If CAPAI felt that the level of low- income weatherization fund was insufficient during the years of 2003-2010, why did it not request increased funding during that time period? REQUEST FOR PRODUCTION NO. 20: If CAPAI felt that the level of low- income weatherization fund was insufficient in 2007, why did it not request increased funding when both parties filed a joint application in Case No. IPC-E-07-09 to extend funding at $1.2 millon? IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 4 REQUEST FOR PRODUCTION NO. 21: Please identify the expert retained by CAPAI to analyze the Rocky Mountain Power evaluation study referenced on page 25 of Ms. Ottens' testimony. DATED at Boise, Idaho, this 20th day of October 2011. ~j2.~ LISA D. NORDST OM Attorney for Idaho Power Company IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 20th day of October 2011 I served a true and correct copy of IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Karl T. Klein Deputy Attorneys General Idaho Public Utilties Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Don.Howellcapuc.idaho.gov Karl. Kleincapuc. idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email petercarichardsonandoleary.com gregcarichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email drcabenjohnsonassociates.com 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 -l Email elocaracinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email tonycayankel.net IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 6 The Kroger Co. Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Kevin Higgins Energy Strategies, LLC 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Micron Technology, Inc. MaryV. York HOLLAND & HART, LLP 101 South Capital Boulevard, Suite 1400 Boise, Idaho 83702 Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 The United States Department of Energy Arthur Perry Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Dwight D. Etheridge Exeter Associates, Inc. 10480 Little Patuxent Parkay, Suite 300 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email kboehmcaBKLlawfirm.com jrhcabattisher.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email khigginscaenergystrat.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email myorkcahollandhart.com tnelsoncahollandhart.com madavidsoncahollandhart.com fschmidtcahollandhart.com Inbuchanancahollandhart.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email remalmgrencamicron.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Arthur.brudercahq.doe.gov Steven. portercahq.doe.gov Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email detheridgecaexeterassociates.com IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 7 Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email bmpurdycahotmail.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email bottocaidahoconservation.org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email kmilercasnakeriveralliance.org NW Energy Coalition Nancy Hirsh, Policy Director NW Energy Coalition 811 First Avenue, Suite 305 Seattle, Washington 98104 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email nancycanwenergy.org Hoku Materials, Inc. Dean J. Miler McDEVITT & MILLER LLP 420 East Bannock (83702) P.O. Box 2564 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email joecamcdevitt-miler.com heathercamcdevitt-miller.com Scott Paul, CEO Hoku Materials, Inc. One HokuWay Pocatello, Idaho 83204 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email spaulcahokucorp.com rÆJ2t2~ Lisa D. Nordstrom IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 8