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Home My WebLink About20110914IPC to Staff 1-8.pdfDONOVAN E. WALKER Lead Counsel dwalker(ãidahopower.com eslDA~POR~ An IDACORP Company September 14, 2011 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilties Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-11-16 IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR APPROVAL OF ITS ENERGY EFFICIENCY INCENTIVE AGREEMENT WITH THE IDAHO OFFICE OF ENERGY RESOURCES Dear Ms. Jewell: Enclosed for filing are an original and three (3) copies of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power Company in the above matter. Also enclosed are three (3) copies of a confidential disk containing information being produced in response to the above production request. Please handle the enclosed confidential information in accordance with the Protective Agreement executed in this matter.YOU:aJ~ DEW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, 1083707 DONOVAN E. WALKER (ISB No. 5921) JASON B. WILLIAMS Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalkercæidahopower.com jwilliams((idahopower.com RECEI 2011 SfP '4 PH 3: 26 Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR )APPROVAL OF ITS ENERGY ) EFFICIENCY INCENTIVE AGREEMENT ) WITH THE IDAHO OFFICE OF ENERGY )RESOURCES. ) ) ) ) CASE NO. IPC-E-11-16 IDAHO POWER COMPANY'S 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 response to the First Production Request of the Commission Staff to Idaho Power Company dated August 24, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO.1: Please provide a complete list and description of individual projects comprising the initial $9.6 milion estimated cost of the K-12 Energy Effciency Project for public schools (K-12 Project). Include in these descriptions the names of the schools and school districts, the measures to be implemented, costs of the measures, lives of the measures, all administrative costs, expected energy and demand savings, expected annual and lifetime bil savings for each participating school, and expected incentive payment from the Company. RESPONSE TO REQUEST NO.1: Idaho Power does not have all of the above- requested information at this time, and does not expect that it would have all such information, nor that all of the above-requested information is even relevant to the agreement executed with the Idaho Offce of Energy Resources ("OER"). Under the agreement, OER would pursue its own projects with its own grant of federal funds. It mayor may not apply to Idaho Power for energy efficiency incentives, and would either qualify or not qualify for such incentives according to Idaho Power's existing rules for the operation of those incentive programs. OER would be treated no differently than any other customer or entity that would apply for energy efficiency incentives with Idaho Power. Idaho Power would not have the above-requested information for any other potential applicant under the existing energy efficiency programs, and because OER has not yet applied for any incentives from Idaho Power pursuant to this agreement, Idaho Power would not have the information for OER's programs either. As stated in Idaho Power's Application, the intent of the agreement with OER is that OER would apply for and qualify its projects for energy efficiency incentives with Idaho Power in the same way, and pursuant to the same rules and parameters, as any IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 other customer or entity. If any other person or entity qualifies for an energy efficiency incentive payment from Idaho Power, that person or entity is free to take that incentive payment and spend it as they see fit. Pursuant to the agreement, if OER's programs qualify for incentive payments, the payments wil be placed into a separate fund that is dedicated to the reinvestment of those funds into additional cost-effective energy effciency programs and/or measures for Idaho Powets customers. The response to this Request was prepared by Donovan E. Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO.2: For Company costs incurred for the initial $9.6 millon K-12 Project, the savings net-to-gross (NTG) ratio is zero and the benefit/cost (B/C) ratios are zero from both the total resource cost (TRC) test and utility cost (UCT) test perspectives. Does the Company agree? If not, please explain. RESPONSE TO REQUEST NO.2: Please see Idaho Powets response to Staff's Production Request NO.1. The response to this Request was prepared by Donovan E. Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 REQUEST NO.3: If the Company denies that its NTG and B/C ratios are zero for the K-12 Project, please provide the expected B/C ratio, including OER's administrative costs, from the TRC, UCT, Participant and Rate Impact perspectives, including all data and explanations for all assumptions (e.g. net-to-gross ratio) used in the calculations. RESPONSE TO REQUEST NO.3: Please see Idaho Powets response to Staffs Production Request NO.1. The response to this Request was prepared by Donovan E. Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 REQUEST NO.4: Please provide the same information as requested in Request NO.1 above, but for the projects expected to be completed using the reinvestment of the Company's incentive payments (Reinvestment Projects) for projects included in the initial $9.6 milion Project. RESPONSE TO REQUEST NO.4: Please see Idaho Power's response to Staff's Production Request NO.1. The response to this Request was prepared by Donovan E. Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 REQUEST NO.5: Please provide expected B/C ratios for the total Reinvestment Projects, including OER's administrative costs, from the TRC, UCT, Participant and Rate Impact perspectives, including all data and explanations for all assumptions (e.g. net-to-gross ratio) used in the calculations. RESPONSE TO REQUEST NO.5: Please see Idaho Power's response to Staff's Production Request NO.1. The response to this Request was prepared by Donovan E. Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 REQUEST NO.6: Please provide total B/C ratios for the Agreement from the TRC, UCT, Participant and Rate Impact perspectives, including all data and explanations for all assumptions (e.g. net-to-gross ratio) used in the calculations. RESPONSE TO REQUEST NO.6: Please see Idaho Powets response to Staffs Production Request NO.1. The response to this Request was prepared by Donovan E. Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST NO.7: Please provide a list of all K-12 public schools energy efficiency projects for which the Company has paid incentives or expects to pay incentives in 2009, 2010 and 2011 (excluding any ARRA-funded projects included in response to Request NO.1 above). Include in these descriptions the names of the schools and school districts, the measures implemented, costs of the measures, lives of the measures, all administrative costs, energy and demand savings, annual and lifetime bill savings for each participating school, incentive payments by the Company and dates paid, and project completion dates. RESPONSE TO REQUEST NO.7: Idaho Power does not track projects by building type for all of its programs. However, through a query of Idaho Power's records, the Company was able to identify the projects where the incentive recipient's name included the word "schooL." Non-public school projects were then manually scrubbed from the data. Some projects are conducted in schools by third parties and the incentives are assigned to the third party by the program participant resulting in the word "school" not being found. Consequently, the lists the Company is providing in response to this production request are not comprehensive. Idaho Power considers the spreadsheet provided on the confidential CD to be confidential customer information. Therefore, the confidential CD wil be provided to those parties that have executed the Protective Agreement in this matter. Public schools have and are able to participate in three of Idaho Powets energy efficiency programs and the data differs slightly for each program and sometimes by program year. The confidential spreadsheet provided on the confidential CD contains incentive recipient, total project cost, amount of incentive, energy savings, demand saving, IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 general measure type(s), and incentive payment date and, in more recent data, the completion date. Sometimes the school district and the school names are the same. Idaho Power has not historically electronically tracked all measures in a project, bil savings by project, lives of the measures, and administrative costs. This information is tracked on a program level and the measure life and administrative cost per measure is provided in Idaho Powets Demand-Side Management 2010 Annual Report: Supplement 1: Cost-Effectiveness. Since this data comes from multiple programs, multiple years, and from different data bases, the availability and form of the data varies from program to program and sometimes from year to year. The confidential spreadsheet provided on the confidential CD contains the following three tabs: Tab 1: "Easy Upgrades 2009_2011." Tab 2: "Custom Effciency 2009-2011." School districts may have multiple rows for different schools but the projects' costs, savings, incentives, and paid date are by district. Tab 3: "Building Efficiency 2009_2011." This tab is in column format with a column for each measure utilized. The response to this Request was prepared by Pete Pengily, Customer Research and Analysis Leader, Idaho Power Company, in consultation with Donovan Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10 REQUEST NO.8: Please provide B/C ratios for the 2009-2011 total K-12 Public Schools Projects (excluding any ARRA-funded projects) from the TRC, UCT, Participant and Rate Impact perspectives, including all data and explanations for all assumptions (e.g. net-to-gross ratio) used in the calculations. RESPONSE TO REQUEST NO.8: Idaho Power does not calculate the TRC, UCT, Participant and Rate Impact tests ratios at the project leveL. In 2010 alone, Idaho Power incentivized over 1,800 projects in the three energy efficiency programs available for schools. As agreed upon in the 2010 Memorandum of Understanding signed by the Idaho Public Utilties Commission Staff and Idaho's Investor Owned Utilties, Idaho Power calculates the TRC, UCT, participant cost test, and the ratepayer impact measure test at the program and the measure leveL. The most recent program and measure cost-effectiveness tests results, along with the assumptions and data sources, can be found in Idaho Power's Demand-Side Management 2010 Annual Report: Supplement 1: Cost-Effectiveness. The response to this Request was prepared by Pete Pengily, Customer Research and Analysis Leader, Idaho Power Company, in consultation with Donovan Walker, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 14th day of September 2011. NOV AN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 14th day of September 2011 I served a true and correct copy of the within and foregoing IDAHO POWER COMPANY'S 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 Karl T. Klein Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 -2 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email KarI.Klein((puc.idaho.gov Offce of Energy Resources John Chatburn, Interim Administrator Office of Energy Resources 304 North 8th Street, Suite 250 P.O. Box 83720 Boise, Idaho 83720-0199 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email john.chatburn((oer.idaho.gov Donovan E. Walker IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12