20130719Staff 30-52 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL ?ilIl
rDAHo puB,.rc urrlrrrEs coMMrssroN :I i: -iril i I ii'i I i : I tr
PO BOX 83720
BOISE, IDAHo 93720-0074 'll; , -
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomeys for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-13-8
DETERMINATION Or 2012 DEMAND-SIDE )
MANAGEMENT EXPENDITURES AS ) SBCOND PRODUCTION
PRUDENTLY INCURRED. ) nnQuEST oF THE
) COVTMISSION STAFF TO
) TOAHO 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 on or before FRIDAY, AUGUST 912013.
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.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 19,2OI3
REQUEST NO. 30: Please explain the Company's process for issuing RFPs for DSM
goods/services and the criteria used to award contracts.
REQUEST NO. 31: Most cost-effectiveness summaries in the DSM 2012 Annual
Report Supplement 1: Cost-Effectiveness included a line item labeled 'Non-Utility
Rebates/Incentive". This line item was either zero or absent in each of the Company's programs
in2012. Please describe the specific types of benefits that could be included in this line item and
describe how the Company would learn if the customer benefited from non-utility rebates or
rebates in addition to utility incentives.
REQUEST NO.32: Would the Company reduce its incentive amounts if it could
confirm that customers were receiving significant non-utility rebates or incentives? Please
explain why or why not.
REQUEST NO. 33: Does the Company consider stimulus funding to be a non-utility
rebate or incentive? Please explain why or why not.
REQUEST NO.34: Does the Idaho Power Measure Database include energy savings
estimates from the 2009 Nextant Potential Assessment?
REQUEST NO. 35: Page2-15 of the EnerNOC Potential Assessment indicates that
energy efficiency measure data, including energy savings, comes in part from the "Idaho Power
Measure Database." If the answer to Request No. 34 is yes, did the EnerNOC Potential
Assessment update the measure savings estimates from the 2009 Nextant Potential Assessment?
Please explain why or why not.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 19,2OI3
REQUEST NO. 36: The "Evaluation of Sprinkler Inigation System Components in
Southern Idaho" statement of work states that "Irrigation components and systems measured in
the project do not necessarily have to receive electric service from Idaho Power Company."
Please provide the location and electric service provider for all of the irrigation components and
systems measured in the project.
REQUEST NO.37: Did the Towers Watson study normalize the Company and market
salary benchmarks for cost of living differences between the utilities' service territories?
REQUEST NO. 38: Please provide full documentation for all Office of Energy
Resources (OER) projects, including but not necessarily limited to the completed lighting tool,
project surrmary, signed and dated pre-approval application (for non-standard lighting projects
or projected incentive payments over $1,000), signed and dated MOU for contractors, signed and
dated payment application, and proof of purchase (including date of installation) for products and
labor.
REQUEST NO. 39: The Agreement between the OER and the Company states that
"OER may use up to 10% of the monies from this dedicated fund [of incentive payments] to
reimburse reasonable and prudent administration costs associated with the reinvestment of
incentive payments into cost-effective energy efficiency projects." Please provide full records
for this dedicated fund, including but not limited to project incentive deposits, OER invoices for
administrative payments, and administrative payments made to the OER.
REQUEST NO.40: Before October 27,2011, did the Easy Upgrades Terms and
Conditions include a paragraph prohibiting projects that received grant/stimulus funding from
also receiving Company incentives on the portion of the project funded by the grant/stimulus
money? If so, please explain why that clause was removed.
REQUEST NO. 41: In addition to the OER projects, were any other stimulus or grant
funded commercial or industrial projects incented through the Company's energy efficiency
programs?
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 19,2013
REQUEST NO. 42: Please provide the source and justification for the Easy Upgrades
Net-to-Gross Q.ITG) value stated in the Demand-Side Management (DSM) 2012 Annual Report,
Supplement 1 : Cost-Effectiveness.
REQUEST NO. 43: Does the non-standard lighting tool for Easy Upgrades use
prescriptive or deemed estimates for labor and measure costs, or are those costs taken from the
project's invoices?
REQUEST NO. 44: For each of the Company's Demand Response programs, please
provide adatadump of all of the incentive payments paid during 2012 and charged to the Power
Cost Adjustment. Please include date, amount, payee, and a brief description of the project.
REQUEST NO. 45: For each employee paid from the DSM Rider during the last five
years, please provide the compensation on January 1, 2008, the date of each salary increase since
then, the new salary after each increase, and the amount of employee incentive received.
Employees need not be identified by name or title.
REQUEST NO. 46: Please provide copies of the complete reports prepared by Towers
Watson between 2008-2013 evaluating employee pay and benefits.
REQUEST NO. 47: Page l4 of Mr. Tatum's direct testimony states that "the results of
the total compensation benchmarking analysis are presented in summary format annually to
Idaho Power's Board of Director's Compensation Committee and the most recent presentation of
the total compensation analysis is attached as Exhibit No. 1." Are other materials presented to
the Compensation Committee to assist in its determination of pay increases? If so, please
provide those materials.
REQUEST NO. 48: Please clarify the amount of Energy Star courses offered to real
estate agents in2012 as part of the Energy Star Homes Northwest program. How many
participants attended? How many participants received a class completion certificate?
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JULY I9,2OI3
RBQUEST NO. 49: What assumptions did the Company use to assume a $240lMWh
dispatch price for the Irrigation Peak Rewards program?
REQUEST NO. 50: Please describe the Northwest Energy Effrciency Alliance's
(NEEA) involvement with Continuous Energy Improvement (CEI) in2012. What companies
did NEEA continue to work with and/or add to its CEI efforts?
REQUEST NO. 51: How many heat pump water heaters did NEEA incent in Idaho?
Please provide the type of heat pump water heater(s) incented.
REQUEST NO. 52: The Company states that as part of NEEA's Consumer Electronics
Energy Forward Campaign, NEEA worked with Best Buy and Sears to increase retailer
promotion of energy efficient TV's. How many physical stores did NEEA representatives visit
and where?
!L( /'L
DATED at Boise, Idaho, this 9* aurof July 2013.
Karl T. Klein
Deputy Attorney General
Technical Staff: Stacey Donohue/3O - 43
Donn EnglisU44 - 47
Nikki Karpavich/ 8 - 52
i:umisc:prodreq/ipcel3.8kkdesdnk prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 JULY 19, 2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I9TH DAY oF JULY 2013,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC.E.13-08, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A HILTON
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
lnordstrom@idahopower. com
i [e-mail]
dockets@idahopower,com
CBearry@idahopower. com
DARLENE NEMNICH
TIM TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
dnemnich@idahopower. com
ttatum@idahopower. com
CERTIFICATE OF SERVICE