20120509Staff 7-25 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEIVED
2D12 MAY -.9 AM 10: 09
• r.-, IDAhO r 1 Lb
UTiLflS COMM!SSIO
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 A ) CASE NO. IPC-E-12-15
DETERMINATION OF 2011 DEMAND-SIDE )
MANAGEMENT EXPENDITURES AS ) SECOND PRODUCTION
PRUDENTLY INCURRED. ) REQUEST OF THE
) COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities 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, by WEDNESDAY, MAY
30, 2012.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary 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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 MAY 9, 2012
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. 7: According to the 2011 DSM Annual Report, the Company did not
cycle some A/C units as part of the A/C Cool Credit program due to the paging and advanced
metering infrastructure (AMI) system upgrade issues. Please provide the total number and total
percentage of A/C Cool Credit customers that were not cycled during 2011.
REQUEST NO. 8: How does IPC propose to continue the A/C Cool Credit program on
Mountain Home Air Force Base (MHAFB) for the 2012 summer season? Please explain the
Company's decision, the cost of the proposed solution, and the effect on cost-effectiveness.
REQUEST NO. 9: Please explain how the Company will test AMI-compatible switches
prior to the A/C Cool Credit cycling season.
REQUEST NO. 10: Please quantify and explain the customer incentive structure used
in the FlexPeak Management Program and include the number of participants in each incentive
category.
REQUEST NO. 11: Page 11 of the Annual Report states that "purchased services
include payments made to third-party contractors who help deliver Idaho Power's programs."
How much of the $4,888 listed as Purchased Services in FlexPeak Management (Supplement 1:
Cost-Effectiveness, pg. 8) were payments made to EnerNOC?
REQUEST NO. 12: Has the Northwest Energy Efficiency Alliance (NEEA) provided
support to Idaho small to medium sized businesses to promote Continuous Energy Improvement
(CEI) during the past two years? If so, please provide the number of businesses and describe the
Company's participation in the program, if any.
REQUEST NO. 13: Irrigation Efficiency claims a net-to-gross (NTG) value of 100%
because "Deemed savings from the RTF already accounts for net realized energy savings" (pg.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MAY 9, 2012
115, Supplement 1: Cost-Effectiveness). However, the [Regional Technical Forum (RTF)] only
provides deemed savings for measures in the Menu Incentive Option. Please explain why the
Company claims 100% NTG for the Custom Incentive Option in which savings are calculated by
IPC staff.
REQUEST NO. 14: Page 97 of the Demand Side Management (DSM) 2011 Annual
Report reads "Payments [under the Menu Incentive Option of Irrigation Efficiency Rewards] are
calculated on a predetermined average kWh savings per measure. In some cases, energy savings
estimated in the Menu Incentive Option are adjusted downward to reflect how the components
are actually being used. No changes occurred to the assumptions that drive the cost-
effectiveness of the measures that are part of the program." If the reduced energy savings are not
used to calculate incentive payments and are also not used to change assumptions for cost-
effectiveness calculations, please explain how the reduced energy savings are used.
REQUEST NO. 15: The RTF website reports that savings estimates for Irrigation
Hardware, which are cited in the Company's Irrigation Efficiency Rewards program, are "out of
compliance" as of February 1, 2011. However, the Company states the measures are "currently
under review" (DSM 2011 Annual Report, pg. 98). Why does the Company use savings
estimates that are out of compliance?
REQUEST NO. 16: Please provide a spreadsheet that includes the project name, project
application date, measure/project installation date, invoice date and amount, date and amount of
incentive payment, and name of incentive recipient for all Easy Upgrades projects.
REQUEST NO. 17: Please provide the list of lighting measures that were expanded
under the Easy Upgrades program in 2011, as referenced on page 78 of the DSM 2011 Annual
Report.
REQUEST NO. 18: Please indicate if the kWh threshold for qualifying projects
changed for either Easy Upgrades or Custom Efficiency between 2010 and 2011. If so, please
indicate the change for each and reason for the change.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 MAY 9, 2012
REQUEST NO. 19: Please provide copies of all pre-approval applications, lighting tool
calculations, and signed and dated memorandums of understanding (MOUs) (including Terms
and Conditions) for all Idaho Office of Energy Resources (OER) projects.
REQUEST NO. 20: Please provide copies of all invoices which OER submitted to IPC
for administrative payments and a list of all administrative payments which were made to OER.
REQUEST NO. 21: Page 112 of Supplement 1: Cost-Effectiveness cites "IPC DSM"
Potential Study by Nexant, Inc. 2009" as the source for the NTG percentage. Please explain how
Nexant calculated this figure and how it incorporates the effects of federally funded projects.
REQUEST NO. 22: Please explain why Supplement 1: Cost-Effectiveness does not
include measure-level cost-effectiveness information for Weatherization Assistance for Qualified
Customers (WAQC). Also, please provide a table with detailed cost-effectiveness information
for each measure in WAQC as was provided for all other programs.
REQUEST NO. 23: Page 65 of the DSM 2011 Annual Report reads, "Actual savings
and measure costs submitted by contractors are used in place of deemed measures to asses cost-
effectiveness [for Weatherization Solution for Eligible Customers (WSEC)]. The actual average
annual savings estimates are considered more accurate than a deemed savings because of the
number of inputs applied in the [Energy Audit 4 (EA4)] data analysis." Do the "actual savings"
refer to the savings estimates of the EA4 tool? If not, please explain the source of the "actual
savings.
REQUEST NO. 24: Please explain how Non-Electric Benefits in the Irrigation
Efficiency Program increased by 300% from 2010 to 2011, while electric savings increased by
35% and the program budget increased by 7%.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 MAY 9, 2012
REQUEST NO. 25: Please explain why the Irrigation Efficiency Rewards impact
evaluation scheduled for late 2011 - early 2012 was eliminated and not rescheduled.
DATED at Boise, Idaho, this q day of May 2012.
Ai
~Iklj ) )Z--
Karl T. Klein
Deputy Attorney General
Technical Staff: Nikki Karpavichl7-23
Stacey Donohue/24-25
i:umisc:prodreq/ipeel 2.1 5kknksd prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 MAY 9, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF MAY 2012, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-12-15, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A HILTON
LISA D NORDSTROM
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: [e-mail]
[e-mail]
DARLENE NEMNICH
GREG SAID
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: gsaid(idahopower.com
[e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON & O'LEARY
P0 BOX 7218
BOISE ID 83702
EMAIL: [e-mail]
greg(richardsonando1eary.com
BENJAMIN J OTTO
710 N 6TH STREET
BOISE ID 83702
EMAIL: botto(idahoconservation.org
DR DON READING
6070 HILL ROAD
BOISE ID 83703
EMAIL: dreading(mindspring.com
7 /21~2v~
SECRETAY
CERTIFICATE OF SERVICE