20110824Staff to IPC 1-8.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEIV
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL )
OF AN ENERGY EFFICIENCY INCENTIVE )
AGREEMENT BETWEEN IDAHO POWER )
COMPANY AND THE IDAHO OFFICE OF )ENERGY RESOURCES. )
)
CASE NO. IPC-E-11-16
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that Idaho Power Company (Company; IPC)
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, SEPTEMBER 14,2011.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementa responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 24, 2011
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
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 anual and lifetime bil
savings for each participating school, and expected incentive payment from the Company.
REQUEST NO.2: For Company costs incurred for the initial $9.6 milion 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.
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, Paricipant and Rate Impact perspectives, including all data and explanations for
all assumptions (e.g. net-to-gross ratio) used in the calculations.
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.
REQUEST NO.5: Please provide expected B/C ratios for the total Reinvestment
Projects, including OER's administrative costs, from the TRC, UCT, Paricipant and Rate Impact
perspectives, including all data and explanations for all assumptions ( e.g.net-to-gross ratio) used
in the calculations.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 24,2011
REQUEST NO.6: Please provide total B/C ratios for the Agreement from the TRC,
UCT, Paricipant and Rate Impact perspectives, including all data and explanations for all
assumptions (e.g. net-to-gross ratio) used in the calculations.
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 ARR-fuded 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, anual and lifetime bil savings for each paricipating school, incentive
payments by the Company and dates paid, and project completion dates.
REQUEST NO.8: Please provide B/C ratios for the 2009-2011 total K-12 Public
Schools Projects (excluding any ARR-funded projects) from the TRC, UCT, Paricipant and
Rate Impact perspectives, including all data and explanations for all assumptions (e.g. net-to-
gross ratio) used in the calculations.
DATED at Boise, Idaho, this :i Lf 1'day of August 2011.
,tg.11LKarl . Klein
Deputy Attorney General
Technical Staff: Lynn Anderson/I-8
i:umisc:prodreq/ipce i i . i 6kkla prod req i
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 24,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF AUGUST 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-11-16,
BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOV AN E. WALKER
JASON B. WILLIAMS
LEGAL DEPARTMENT
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: dwalker§idahopower.com
jwillams§idahopower.com
MICHAEL J. YOUNGBLOOD
GREGORY W. SAID
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: myoungblood§idahopower.com
gsaid§idahopower.com
JOHN CHATBURN
SUE SEIFERT
OFFICE OF ENERGY RESOURCES
304 NORTH 8TH STREET SUITE 250
BOISE IDAHO 83720-0199
jon.chatbum§oer.idaho.gov
sue.seifert§oer .idaho. gov
CERTIFICATE OF SERVICE