20111021IPC 1-21 to CAPAI.pdf

an.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: [phone]
Facsimile: [phone]
InordstromCcidahopower.com
dwalkerCcidahopower.com
jwilliamscaidahopower.com
Attorneys for Idaho Power Company
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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
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U.S. Mail
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FAX
-l Email petercarichardsonandoleary.com
gregcarichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
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-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
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FAX
-l Email elocaracinelaw.net
Anthony Yankel
29814 Lake Road
Bay Vilage, Ohio 44140
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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
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-l Email kboehmcaBKLlawfirm.com
jrhcabattisher.com
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-l Email khigginscaenergystrat.com
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-l Email myorkcahollandhart.com
tnelsoncahollandhart.com
madavidsoncahollandhart.com
fschmidtcahollandhart.com
Inbuchanancahollandhart.com
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-l Email remalmgrencamicron.com
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-l Email Arthur.brudercahq.doe.gov
Steven. portercahq.doe.gov
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-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
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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
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-l Email bottocaidahoconservation.org
Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
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-l Email kmilercasnakeriveralliance.org
NW Energy Coalition
Nancy Hirsh, Policy Director
NW Energy Coalition
811 First Avenue, Suite 305
Seattle, Washington 98104
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-l Email nancycanwenergy.org
Hoku Materials, Inc.
Dean J. Miler
McDEVITT & MILLER LLP
420 East Bannock (83702)
P.O. Box 2564
Boise, Idaho 83701
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-l Email joecamcdevitt-miler.com
heathercamcdevitt-miller.com
Scott Paul, CEO
Hoku Materials, Inc.
One HokuWay
Pocatello, Idaho 83204
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-l Email spaulcahokucorp.com
rÆJ2t2~
Lisa D. Nordstrom
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST
TO COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO - 8