20140616Staff 1-42 to IPC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702.5983
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
DETERMINATION OF 2013 DEMAND.SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC.E.I4-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Idaho Power Company (Company; IPC)
provide the following documents and information as soon as possible, but no later than
MONDAY, JULY 7,2014.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho Power 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 produced.
This Production Request is to be considered as continuing, and Idaho Power is requested
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JUNE 16,2OI4
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 identiff the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please list all expenses charged to the demand-side management
("DSM") tariff rider during 2013. Please include date, vendor, amount, a brief description of the
expense, and the account to which the charges were booked. Please separate all expenses by
program so that expenditures provided reconcile with the amounts reported in the 2013 DSM
annual report. If any amounts are allocated among different programs or jurisdictions, please
describe the allocation method. Please also identify if each expense is an incentive payment,
purchased service, labor/administrative, or materials and other expense. Please provide the
requested information in Excel format.
REQUEST NO.2: Please provide the same information requested above for demand
response incentive payments not included in the tariff rider.
REQUEST NO.3: Please provide the calculation of the interest accrued to the DSM
tariff rider account.
REQUEST NO. 4: Please provide the revenue received (excluding interest) from the
DSM tariff rider.
REQUEST NO. 5: Please provide all DSM research and evaluation expenses for 2013,
including date, vendor, and program to which the expense applied.
REQUEST NO. 6: The Company has indicated that the decrease in acquired energy
savings can be attributed, in part, to reduced deemed savings estimates approved by the Regional
Technical Forum. Please provide a list of all measures offered by the Company that were affected
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JUNE 16,2OI4
by changes in RTF estimates. Please also include the energy savings for those measures using
both the previous RTF deemed savings amount and the new RTF deemed savings amount.
REQUEST NO. 7: Please provide the cost-effectiveness work papers and calculations
for each DSM program in 2013 in Excel format with all formulas intact.
REQUEST NO.8: Please provide the list of projects, incentive payments, and locations
for all Office of Energy Resources ("OER") projects incented by the Company in 2013.
REQUEST NO. 9: Please compare, by DSM program, the amount of energy efficiency
acquired by Idaho Power in2013 against the amount of economic potential and the achievable
potential identified in the 2013 DSM Potential Study. In addition to quantifuing the difference,
please describe the reasons for any difference in acquisition versus potential.
REQUEST NO. 10: Did Idaho Power's energy efficiency portfolio achieve its IRP
targets in2013? Please provide the target compared to total acquisition, and explain any
difference.
REQUEST NO. 11: Page 82 of Idaho Power's IRP, Appendix C shows 8 aMW of
"cumulative new energy efficiency" forecast for 2013. Please indicate which Idaho Power DSM
programs were forecasted to make up these 8 aMW and provide actual achievement for
"cumulative new energy efficiency" in 2013. Please explain any discrepancy between the
forecast and the achievement.
REQUEST NO. 12: Page 16 of the 2013 DSM Annual Report notes the "success of these
Facebook advertisements" for the Home Improvement Program campaign based on increased
program website traffic. Did this increased traffrc also materially increase program participation?
Please explain why or why not.
REQUEST NO. 13: Please explain the function of Idaho Power's o'personal" Facebook
page relative to its "business" Facebook page.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JUNE 16,2OI4
REQUEST NO. 14: Page l8-19 of the DSM Annual Report state that in2012 only 55%;o
of business customers and only 50% of residential customers (in20l2-2013) knew that Idaho
Power offers energy efficiency programs. Please provide these percentages for 2009-20IL
REQUEST NO. 15: Please provide Idaho Power's DSM marketing plans and budget for
2009 -20t3.
REQUEST NO. 16: Page24 of the DSM Annual Report says'oldaho Power markets its
residential energy efficiency programs through... radio and television commercials..." in addition
to several other types of marketing. Please provide the time, length, content summary, and
broadcast station for each radio or television add funded by Idaho Power in2013.
REQUEST NO. l7: Please provide a listing of all marketing expenses incurred by Idaho
Power for energy efficiency measures. Please include date, amount, vendor, and a brief
description of the marketing materials. Please identifu any of these expenses that were not
charged to the DSM tariff rider.
REQUEST NO. 18: Please provide the number of residential customers recruited by
Idaho Power for A/C Cool Credit Program who: l) moved into a home with a load control device
and2) the number of previous participants who moved to a location without a load control device.
Please also provide the number of customers in both categories who signed up for A/C Cool
Credit.
REQUEST NO. 19: Page 30 of the DSM Annual Report states that the Ductless Heat
Pump Pilot "targets existing homes heated with electric zonal systems." Are homes that have
zonal electric heat but also use wood heat eligible for participation? Please explain why or why
not.
REQUEST NO.20: Has Idaho Power considered incenting fixtures through its Energy
Efficient Lighting program? Please explain why or why not.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JUNE 16,2014
REQUEST NO. 21: Page 35 of the DSM Annual Report states that "Idaho Power
considered sending energy-efficient bulbs to new customers as part of its new customer mailing;
however, an energy efficiency postcard for newly purchased homes highlighting lighting and
other programs, was developed instead." Please explain why the direct-mail option was not
pursued in tandem with the postcard. What response did the Company have as a result of the
postcard mailing?
REQUEST NO.22: Page 31 of the DSM Annual Report says that information about the
DHP pilot was included in the "postcard for newly purchased homes that was initiated in2013
and mailed to customers who have purchased a home that is new to them." Are those postcards
only mailed to customers who buy homes with electric zonal heat or to all customers who buy
new homes? Also, please provide a copy of the postcard.
REQUEST NO. 23: Please explain how the Company uses the customer call center as a
means to collect customer information from those who inquire about the Company's DSM
programs. Please explain the processes and procedures in place to respond to interested
customers.
REQUEST NO.24: Please provide copies of all Company-developed 2013 marketing
and outreach materials including, but not limited to, print, bill stuffers, bill boards, TV
advertisements, radio spots, youtube/vimeo videos, social media, etc. Electronic links are
acceptable. Please detail how many customers viewed or received the materials. Please include
the frequency in which the marketing materials ran.
REQUEST NO.25: Please provide copies of all NEEA-developed marketing and
outreach materials that targeted Idaho Power customers. Please separate by program.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JUNE 16,2OI4
REQUEST NO.26: Please provide copies of any additional marketing and outreach
materials that were not developed by NEEA or the Company, but were promoted to Idaho Power
customers.
REQUEST NO.27: According to the HANSA GCRNon-participant study, an
overwhelming majority of residential and commercial non-participants are unaware of the
Company's energy efficiency offerings. What targeted strategies, if any, will the Company
employ to increase program awareness?
REQUEST NO. 28: Please explain why the Company chooses not to pursue a residential
behavior -based energy efficiency program.
REQUEST NO.29: Please provide the locations for all Commercial training and
educational programs and include the title of the training, the number of participants, and how
Idaho Power marketed the training(s) to the participants.
REQUEST NO.30: Please explain the extent that changes in RTF deemed savings
affected savings for the Energy Effrciency Lighting program after June 2013. If the Company
does not believe RTF changes affected savings, please explain why savings post-June 2013 were
significantly lower than the first half of the year.
REQUEST NO. 31: Please provide a list of all participating stores for the Energy
Efficiency Lighting program. Please note if each store featured in-store advertising for the
program. If the store did not feature in-store advertising, please explain why not. Please also
provide copies of the featured signage.
REQUEST NO. 32: Going forward, how will the Company increase coordination with
Energy Efficient Lighting retailers to find mutually beneficial in-store advertising solutions (TRC
recommendation, p. al?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JI_INE 16,2014
REQUEST NO. 33: In the 2013 DSM Annual Report, Supplement 1, lists a "baseline
bulb" as a replacement for thirteen various CFL's for the Energy Efficiency Lighting program.
What baseline bulb is the Company referring to?
REQUEST NO.34: On page 56, 80 and 82 of the Residential Process Evaluation
conducted by TRC, please complete the section that states "Error! Reference source not found."
REQUEST NO. 35: According to the TRC Residential Process Evaluation, ENERGY
STAR homes Customer Reps generally are not following the programs marketing handbook to
raise awareness to builders and developers, real estate agents and brokers, and regional Building
Contractor Associations (p. 81). Why not?
REQUEST NO. 36: Why does a large reporting discrepancy between NEEA and Idaho
Power's ENERGY STAR home participation exist? (TRC Residential Process Evaluation,
ENERGY STAR Homes, p. 86.)
REQUEST NO. 37: Please describe NEEA's work in Idaho for the Commercial Real
Estate, Existing Building Renewal, Industrial Technical Training, and the Commercial Lighting
Top Tier Trade Ally programs. What was the total cost to operate each individual program in
Idaho? If trainings andlor education occurred, please provide the location, a brief description of
the training(s), and the number of participants.
REQUEST NO.38: Regarding NEEA's Commercial Real Estate, Existing Building
Renewal, Industrial Technical Training, and Commercial Lighting Top Tier Trade Ally programs,
does the Company believe NEEA's work overlaps with ldaho Power programs? If so, how?
REQUEST NO.39: Does the Integrated Design Lab receive funding out of the
Commercial Real Estate, Existing Building Renewal, Industrial Technical Training, or the
Commercial Lighting Top Tier Trade Ally programs?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JI-INE 16,2OI4
REQUEST NO. 40: Please describe and provide copies of all NEEA materials and
activities related to Consumer Marketing, Market Channel Development, and Utility
Customization and Event Support in Idaho Power's service territory. Please provide the total cost
of each program.
REQUEST NO.41: Regarding the Consumer Marketing, Market Channel Development,
and Utility Customization and Event Support, does the Company believe NEEA's work overlaps
with Idaho Power programs and/or resources? If so, please provide a detailed explanation for the
overlap.
REQUEST NO. 42: Please provide the demand reduction for each FlexPeak event called
in 2013.
,lV
DATED at Boise, Idaho, this t rg day of June 2014.
{-) }B-
Neil Price
Deputy Attorney General
Technical Staff: Donn English (l-7,17)
Stacey Donohue (8-16, 18-23)
Nikki Karpavich (24-42)
i:umisc:prodreq/ipcel4.npdesdnk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 8 JTINE 16, 2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I6.h DAY oF JUNE 2014, SERVED
THE FOREGOING FIRST PRODUCTION RE,QUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC.E-14-04, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH ST
BOISE ID 83702
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
DARLENE NEMNICH
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
DR DON READING
6070 HILL ROAD
BOISE ID 83703
CERTIFICATE OF SERVICE