20130812IPC to Staff 30-52.pdf

3Iffi*.
An IDACORP CompanY
JULIA A. HILTON
Corporate Counse!
ih [e-mail]
August 9,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-08
2012 Demand-Side Management Expenditures - ldaho Power Company's
Response to the Second Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed forfiling in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the Second Production Request of the Commission Staff
to ldaho Power Company. ln addition, enclosed in a separate envelope are an original and
three (3) copies of ldaho Power Company's Confidential Response to the Second
Production Request of the Commission Staff to ldaho Power Company.
Also enctosed are four (4) copies each of non-confidential and confiaehtial disks
containing information responsive to Staff's production request. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
JAH:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
Very truly yours,
Julia A. Hilton
JULIA A. HILTON (lSB No. 7740')
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702\
P.O. Box 70
Boise, ldaho 837OT
Telephone: [phone]
Facsimile: [phone]
i h ilton@ idahopower. com
I no rd strom @ ida hopower.com
Attorneys for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2012 DEMAND-
SIDE MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED
ali
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-13-08
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO !DAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("ldaho Powe/' or "Company"), and in
response to the Second Production Request of the Commission Staff ("Staff') to ldaho
Power Company dated July 19,2013, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 30: Please explain the Company's process for issuing RFPs for
DSM goods/services and the criteria used to award contracts.
RESPONSE TO REQUEST NO. 30: On July 25, 2013, Karl T. Klein e-mailed
Lisa D. Nordstrom stating:
Please disregard Request No. 30 in the Second Production
Request of Commission Staff to ldaho Power Company.
Staff asked a substantially similar question last year, the
Company answered it, and Staff doesn't need for the
Company to do answer it again in this case.
Therefore, a response to this Request has not been provided herein.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
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/lncentive". This line item was either zero or absent in each of the Company's
programs in 2012. 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.
RESPONSE TO REQUEST NO. 31: The "Non-Utility Rebates/lncentive'("NUl')
line has been included in the Supplement 1 template since 2009. The intent of that line
has been to capture any additional benefits customers may receive through other third-
party incentives or tax credits as described on page 6-6 of the Naflonal Action Plan for
Energy Efficiency (NAPEE) Understanding Cost-Effectiveness of Energy Efficiency
Programs.
NUI benefits are generally self-reported by the program participant. When the
cost-effectiveness of the program is looked at as a whole, only a fraction of the projects
within the program may have received NUI benefit from an outside source. lf included,
these benefits would affect the Participant Cost Test and Total Resource Cost test and
would increase the cost-effectiveness of the programs from these two perspectives.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.3
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.
RESPONSE TO REQUEST NO. 32: lf the Company could confirm customers
were receiving significant non-utility rebates or incentives, the Company would consider
reducing its incentive. On a project-by-project basis, the sum of non-utility rebates, and
Company incentives, is not intended to exceed 100 percent of the project cost.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 33: Does the Company consider stimulus funding to be a non-
utility rebate or incentive? Please explain why or why not.
RESPONSE TO REQUEST NO. 33: Yes, the Company does consider stimulus
funding to be a non-utility rebate or incentive. ldaho Power believes considering
stimulus funding as non-utility rebates or tax incentives falls within the guidelines of the
industry's cost-effective standards. Please see page 6-6 of the Nafional Action Plan for
Energy Efficiency (NAPEE) Understanding Cost-Effectiveness of Energy Efficiency
Programs, pages 1-9 of the End-Use Technical Assessmenf Guide, Volume 4:
Fundamentals and Methods, and page 18 of lhe California Standard Practice Manual.
Non-utility rebates or incentives, utility incentives, grants, donations, or other
such mechanisms play a key role in encouraging customers to undertake energy
efficiency projects.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 34: Does the ldaho Power Measure Database include energy
savings estimates from the 2009 Nextant Potential Assessment?
RESPONSE TO REQUEST NO. 34: Yes. Some of the measures included in
the Building Efficiency and Easy Upgrades programs rely on the savings estimates from
the 2009 Nexant Demand-Side Management Potential Study ("Nexant Study"). The
measures are identified on pages 60-61 and 68-78 of ldaho Power's Demand-Side
Management 2012 Annual Report, Supplement 1: Cost-Effectiveness.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO. 35: Page 2-15 of the EnerNOC Potential Assessment indicates
that energy efficiency measure data, including energy savings, comes in part from the
"ldaho Power Measure Database." lf 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.
RESPONSE TO REQUEST NO. 35: The Energy Efficiency Potential Study
conducted by EnerNOC, lnc. ("EnerNOC Study") was not used to update the measure
level saving estimate for the two programs which rely on the 2009 Nexant Study. The
energy efficiency potential in the EnerNOC Study was developed using EnerNOC's
Load Management Analysis and Planning ("LoadMAP") tool. The scope of the study
was to estimate the future 2O-year energy efficiency potential and create an analytical
framework for quantifying the future resource potential of energy efficiency. The scope
of the EnerNOC Study did not include an engineering review and assessment of the
Company's current measures and programs. The measure definitions within LoadMAP
do not align with ldaho Power's current measures within its programs because of the
detailed methodology that was used by EnerNOC and how it segmented customer
characteristics. For example, commercial measures in the study are segmented by
building type, end use, vintage, and up to 10 different efficiency levels. The multiple
layers of segmentation create over 7,000 unique measures combinations for the
commercial model that feeds into the potential forecast. Pages 81 and 93 of ldaho
Powe/s Demand-Side Management 2012 Annual Report state that ldaho Power plans
to contract with a third-party consultant in 2013 to evaluate existing and new measures
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
for the Building Efficiency and Easy Upgrades programs. The project is currently
underway and the updated savings will be used for 2013 analysis and reporting.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST NO. 36: The "Evaluation of Sprinkler Irrigation System Components
in Southern Idaho" statement of work states that "lrrigation components and systems
measured in the project do not necessarily have to receive electric service from ldaho
Power Company." Please provide the location and electric service provider for all of the
irrigation components and systems measured in the project.
RESPONSE TO REQUEST NO. 36: Please see the confidential document
provided on the confidential CD. The confidential CD will be provided to those parties
that have executed the Protective Agreement in this proceeding.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
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?
RESPONSE TO REQUEST NO. 37: The Towers Watson market compensation
benchmarks used for the Financial Analyst ll, System Administrator !1, and Senior
Engineer were not adjusted for cost of living differences. The Company believes that
the size of the organization, measured in terms of revenue earned, is the most relevant
indicator for position value; therefore, whenever available, data is utilized only from
companies in a comparable revenue category of $1-3 billion to price jobs. The salary
data used to price the Lineman and Customer Service Representative ll positions were
from the four-company intermountain peer group that includes, Rocky Mountain Power
(Utah), NV Energy (Nevada), NorthWestern Energy (Montana), and Avista Corporation
(Washington). Because these utilities surround ldaho, and these positions are typically
filled regionally, the Company believes this approach to be appropriate.
The response to this Request was prepared by Sharon Gerschultz, Director
Compensation & HRIS, Idaho Power Company, in consultation with Julia A. Hilton,
Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O
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 summary, 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.
RESPONSE TO REQUEST NO. 38: The requested information is voluminous,
proprietary, and confidential. lt will be made available for Staff to audit pursuant to
ldaho Code S 61-610 and Rule of Procedure 227 (IDAPA 31.01.01 .227) at ldaho
Power's corporate headquarters. Please contact Doug Jones at [phone] or
Camilla Victoria at [phone] to arrange a time to review the requested material.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST NO. 39: The Agreement between the OER and the Company states
that "OER may use up to 1Oo/o of the monies from this dedicated fund [of incentive
paymentsl 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.
RESPONSE TO REQUEST NO. 39: ldaho Power did not make any
administrative payments to OER in 2012. Please see the confidential document
provided on the confidentia! CD. This document contains a record of all OER project
incentives transferred to the OER dedicated fund. The confidential CD will be provided
to those parties that have executed the Protective Agreement in this proceeding.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST NO. 40: Before October 27,2011, did the Easy Upgrades Terms and
Conditions include a parugtaph prohibiting projects that received granUstimulus funding
from also receiving Company incentives on the portion of the project funded by the
granUstimulus money? lf so, please explain why that clause was removed.
RESPONSE TO REQUEST NO. 40: Yes. Before October 27 , 2011, the Easy
Upgrades Application and Terms and Conditions included the following sections:
Section 1
GranUStimulus Funding
For projects receiving granUstimulus funding (federa!
or otherwise), only the portion of the project not
funded by those funds is eligible for ldaho Power
incentives. The Idaho Power incentive added to the
granUstimulus funds shall not exceed 100% of the
project costs.
Section 2
Will this project receive grant or stimulus funding?
Yes No
lf yes, what is the dollar amount of the grant or
stimulus funding? $
Section 3
ldaho Power wil! not pay more than IOOYo of the
equipment price and labor, as shown on the invoices.
Projects receiving incentive payments through other
ldaho Power incentive programs are not eligible for
payment through the Program for the same
equipment and features.
The above-labeled Sections 1 and 2 created significant confusion for program
participants and especially for trade allies participating in the Easy Upgrades program.
The trade allies were not always aware if the participant was receiving other funding for
a project and sometimes the participant did not know if he/she would actually receive
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
the grants for which he/she had applied. Additionally, the self-reported grant amounts
were difficult for the Company to verify. As a result, in December 2011, the Company
removed Sections 1 and 2. However, the remaining section, labeled Section 3,
remained intact as part of the Easy Upgrades Terms and Conditions.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
REQUEST NO. 41: ln addition to the OER projects, were any other stimulus or
grant funded commercial or industrial projects incented through the Company's energy
efficiency programs?
RESPONSE TO REQUEST NO. 41: Yes, there have been other commercial or
industrial projects that received stimulus or grant funding that qualified for ldaho
Powe/s energy efficiency program incentives. The Company does not know the exact
number of projects or the amount of funding from sources outside of ldaho Power's
contro! or knowledge because of the reporting issues cited in the Company's response
to Staffs Production Request No.40.
The response to this Request was prepared
Research & Analysis Leader, ldaho Power Company,
Hilton, Corporate Counsel, ldaho Power Company.
by
in
Pete Pengilly, Customer
consultation with Julia A.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
REQUEST NO. 42: Please provide the source and justification for the Easy
Upgrades Net-to-Gross (NTG) value stated in the Demand-Side Management (DSM)
2012 Annual Report, Supplement 1: Cost-Effectiveness.
RESPONSE TO REQUEST NO. 42: The NTG value for the Easy Upgrades
program was obtained from the 2009 Nexant Study. As stated on pages 2-3 of the
Nexant Study, the "net-to-gross values were derived from the values recommended by
the California Public Utilities Commission." ln Appendix C, the Easy Upgrades
measures and their respective NTG values are listed on pages C-27 through C-29. The
NTG values for each of the measures range from 0.80 to 0.96. The Company used the
lower NTG value of 0.80 to analyze the program. The Nexant Study and appendices
were published in ldaho Power's Demand-Side Management 2009 Annual Report,
Supplement 2: Evaluation, which can be found on ldaho Powe/s website at:
http ://www. ida ho power. com/EnergvEfficiencv/reports. cfm.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
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?
RESPONSE TO REQUEST NO. 43: As a point of clarification, ldaho Power
does not have a non-standard lighting tool for the Easy Upgrades program; the
Company includes non-standard measures in its lighting tool. The costs included in the
Easy Upgrades program's lighting tool for non-standard lighting projects reflect the
invoices received from participants.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
REQUEST NO. rt4: For each of the Company's Demand Response programs,
please provide a data dump 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.
RESPONSE TO REQUEST NO. 44: Please see the confidential Excel file
provided on the confidential CD. This attachment contains information that is
confidential, proprietary, and/or has commercia! value. ldaho Power requests
references to granular data are excluded from any Staff reports and/or analysis. The
confidential CD will be provided to those parties that have executed the Protective
Agreement in this proceeding.
The Excel file is a data dump of all demand response program incentives
charged to the Power Cost Adjustment in 2012 for ldaho Power's three demand
response programs: A/C Cool Credit, FlexPeak Management, and lrrigation Peak
Rewards.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
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.
RESPONSE TO REQUEST NO. 45: The requested information is included in
the confidential Exce! file provided on the confidential CD. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding. There were a tota! of 96 employees that charged time to the Idaho and
Oregon energy efficiency riders ("Riders") from 2008-2012. The Company is providing
wage information for only the years that an employee charged time to the Riders. Of
those 96 employees, averaging their labor hours over the years they charged time to
the Riders and applying them to the hours of a full-time equivalent (1,912 hours),
approximately 30 percent of the employees charged more than 50 percent of their time
to the Riders, 34 percent charged less than 50 percent but more than 10 percent of their
time to the Riders, and 35 percent charged less than 10 percent of their time to the
Riders.
Please note that the items in the Excel file listed as "Retention lncentive" refer to
ldaho Powe/s efforts to retain sought-after experienced personnel with specific skills in
the energy efficiency profession. ln 2009, Idaho Power developed a three-year
retention plan to retain certain employees in selected energy efficiency job
classifications. The retention payments were paid from the Riders in 2010, 2011, and
2012 as reflected in the Excelfile.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
Also please note that Employee lncentive Plan ("20XX lncentive") payments are
not charged to the Riders; however, this information has been provided pursuant to this
Request.
The response to this Request was prepared by Sharon Gerschultz, Director
Compensation & HRIS, ldaho Power Company, in consultation with Julia A. Hilton,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
REQUEST NO. 46: Please provide copies of the complete reports prepared by
Towers Watson between 2008-2013 evaluating employee pay and benefits.
RESPONSE TO REQUEST NO. 46: Towers Watson has not been asked to
prepare reports evaluating employee pay and benefits. lt has been asked to estimate
Idaho Power's benefits as a percentage of pay. Separately, the Company gathers
independent market compensation data and incorporates the Towers Watson benefits
information into a total compensation analysis. This total compensation analysis began
in 2011 following ldaho Public Utilities Commission Order No. 32239 directing Idaho
Power to include in its next periodic pension analysis a broader review of total employee
compensation and benefits as compared to peer utility companies. Please see the
confidential 2011 total compensation analysis provided on the confidential CD. The
2012 analysis was submitted as confidential Exhibit No. 1 to the Direct Testimony of
Timothy E. Tatum in this case on April 3, 2013. The confidential CD will be provided to
those parties that have executed the Protective Agreement in this proceeding.
The response to this Request was prepared by Sharon Gerschultz, Director of
Compensation & HRIS, ldaho Power Company, in consultation with Julia A. Hilton,
Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
REQUEST NO. 47: Page 14 of Mr. Tatum's direct testimony states that "the
results of the total compensation benchmarking analysis are presented in summary
format annually to ldaho Powe/s Board of Directods Compensation Committee and the
most recent presentation of the tota! compensation analysis is attached as Exhibit No.
1." Are other materials presented to the Compensation Committee to assist in its
determination of pay increases? lf so, please provide those materials.
RESPONSE TO REQUEST NO. 47: The Compensation Committee does not
determine individua! pay increases. The Compensation Committee approves the
Company's General Wage Adjustment ("GWA"), which, if granted, is effective for the
majority of employees. The confidentia! Excel file provided on the confidential CD was
presented to the Compensation Committee of the Board of Directors for use in
determining the Company's 2013 GWA. All eligible employees, excluding executives
and senior managers, are eligible for the GWA each year. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding.
The Compensation Committee charter contains the following responsibilities with
respect to the Company's employee compensation and benefit plans:
(1) To establish and review at least annually the
Company's general compensation program and other
employee benefit programs including the goals and
objectives of these programs, and amend or
recommend that the Board amend these programs
and/or the goals and objectives if the Committee
deems it appropriate.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22
(2\ To review management's assessment of the
relationship between the Company's general
compensation program and other employee benefit
programs and any risks arising therefrom that are
reasonably likely to have a material adverse effect on
the Company.
(3) To perform such duties and responsibilities as may be
assigned to the Committee under the terms of the
Company's general compensation programs and
other employee benefit programs or by the Board.
The total compensation benchmarking analysis is prepared to demonstrate the
compensation program methodology used, and the relationship to employee benefit
programs. lt is not utilized to adjust compensation either for employees in the five
benchmark positions or any other employees. Those analyses are conducted by the
Human Resources Department in conjunction with business leadership.
The response to this Request was prepared by Sharon Gerschultz, Director
Compensation & HRIS, ldaho Power Company, in consultation with Julia A. Hilton,
Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23
REQUEST NO. 48: Please clarify the amount of Energy Star courses offered to
real estate agents in 2012 as part of the Energy Star Homes Northwest program. How
many participants attended? How many participants received a class completion
certificate?
RESPONSE TO REQUEST NO. 48: As previously stated in ldaho Poweds
response to Staffs Production Request No. 28, "This course is taught by Northwest
ENERGY STAR@ trainers and tocal Home Performance Specialists ('HPS'). One HPS
offered the course in 2012." ln researching the response to this Request, Idaho Power
discovered that the class referred to in Staff's Production Request No. 28 was taught on
December 15, 2011, instead of 2012 as previously reported. Twenty-one realtors
attended this class and all received continuing education credits and Certificates of
Completion. There were no classes taught in ldaho Power's service area in 2012.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
REQUEST NO. 49: What assumptions did the Company use to assume a
$240lMWh dispatch price for the lrrigation Peak Rewards program?
RESPONSE TO REQUEST NO. 49: The approximate dispatch price of
$24Olmegawatt-hour ("MWh") for the lrrigation Peak Rewards program was calculated
from customer incentives listed in Schedule 23, expected participant load data, and an
assumed realization rate for each week of the program season. This dispatch cost was
determined from the average of the variable energy incentive amounts for each
dispatchable option weighted by the percent of customers choosing each option and
adjusted by the realization rates and utility line losses. ln order to estimate the price to
dispatch the program, the Company used the maximum billing demand for dispatch
participants from the prior year to estimate the demand on which a customer's
payments would be based. The realization rates for each week of the program season
were determined through methods used in program evaluations and are further
explained beginning on page 8 of the lrrigation Peak Rewards Program Report, which is
included in ldaho Power's Demand-Side Management 2012 Annual Report, Supplement
2: Evaluation. The realization rates varied by week because of the variation in irrigation
use and crops grown throughout the season.
The resulting average estimated dispatch price for the program season was
$235/MWh, which was rounded up to $240lMWh for the DSM annual report. Please
see the attached spreadsheet which shows the calculation of the estimated dispatch
price for the lrrigation Peak Rewards program.
lf the Company dispatched the program, the variable incentives paid to the
participants would be calculated from actual billing demands for the Automatic Dispatch
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25
Option and from the interval meter data for the Manual Dispatch Option participants.
The estimated dispatch price is based on estimated load reduction at the generation
level. The assumptions used in calculating the estimated average dispatch cost over
the program season are: (1) the prior year's maximum billing demand for the Automatic
Dispatch Option and nominated kilowatts for the Manual Dispatch Option approximate
the metrics from which customers' variable incentives would be calculated; (2) the
realization rates determined from the analysis of the program for each one week period
approximate what actual load reduction the Company would realize during an event;
and (3) ldaho Power's transmission and distribution line losses are 13 percent.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.26
REQUEST NO. 50: Please describe the Northwest Energy Efficiency Alliance's
(NEEA) involvement with Continuous Energy lmprovement (CE!) in 2012. What
companies did NEEA continue to work with and/or add to its CE! efforts?
RESPONSE TO REQUEST NO. 50: The response to this Request is
confidentlal and will be provided separately to those parties that have executed the
Protective Agreement in this proceeding.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.2T
REQUEST NO. 51: How many heat pump water heaters did NEEA incent in
ldaho? Please provide the type of heat pump water heater(s) incented.
RESPONSE TO REQUEST NO. 51: ln 2012, NEEA provided incentives for 33
heat pump water heaters in ldaho. Thirty-two were Tier 1 units and one was a Tier 2
unit. Tier 2 units conform to the Northern Climate Heat Pump Water Heater
Specification.
The current Northern Climate Heat Pump Water Heater Specification and Tier
information is on page 3 of the specifications and can be found via the following link:
http://neea.oro/docs/default-source/northern-climate-heat-pump-water-heater-
specification/no rthern-cl i mate-specification. pdf?sfvrsn =8
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.2S
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?
RESPONSE TO REQUEST NO. 52: The attached list, provided by NEEA,
details the physical stores NEEA representatives visited, the stores' locations, and the
dates of the visits.
The fu l! report is available at: https://cond uitnw.orq/Paqes/File.aspx? Rl D= 1 394.
The response to this Request was prepared by Pete Pengilly, Customer
Research & Analysis Leader, ldaho Power Company, in consultation with Julia A.
Hilton, Corporate Counsel, ldaho Power Company.
DATED at Boise, ldaho, this gth day of August 2019.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 29
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 9th day of August 2013 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
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
!daho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Bearry, LegalAssistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.30
CERTIFICATE OF ATTORNEY
ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURING THE
COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDING
ARE PROTECTED FROM PUBLIC INSPECTION
Gase No. IPC-E-I3-08
The undersigned attomey, in accordance with RP 233, hereby certifies that ldaho
Power Company's response to the Idaho Public Utilities Commission Staffs ("Staff')
Production Request No. 50 and the attachments provided in response to Staffs
Production Request Nos. 36, 39, and 44-47 contain information that is a trade secret or
privileged or confidential as described in ldaho Code S 9-340, ef seg., and $ 48-801, ef
seg., and as such are exempt from public inspection, examination, or copying.
DATED this 9th day of August 2013.
Counsel for ldaho Power Company