20140702Staff 43-47 to IPC.pdf

RECE 11,,I t]NEIL PRICE
DEpUTy ATT.RNEv GENERAL ldy^rr ASlq JUL -2 pl{ 2: 59IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 lDAl-ir-i, L i.; .r.
BOISE, IDAHO 83720_0074 UTILI|r:S il0;,rF;iis;Sti:,ii
(208) 334-03 14
ISB NO. 6864
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5983
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THB MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR A ) CASE NO.IPC-E-14-04
DETERMINATTON OF 2013 DEMAND-SIDE )
MANAGEMENT EXPENSES AS PRUDENTLY ) SNCOND PRODUCTIONINCURRED. ) NTQUEST OF THE) cowtMISsIoN srAFF 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
WEDNESDAY, JULY 16,20141.
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.
' Staffis requesting an expedited response. If responding by this date will be problematic, please call Staffls attorney
at [phone].
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 2,2014
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.
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.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.43: Idaho Power's Conservation Potential Assessment appendix states
on page B-10 that the "Behavioral Feedback Tool" measure "models a wide range of options for
providing homeowners with ongoing information on their energy use, for example via a web
portal. These tools are based on the premise that homeowners will reduce energy use if they
better understand how they use energy and the associated costs. The level of assumed savings is
based on isolated behavioral effects and excludes the technology effects of all other measures
listed here." Please explain which measures were included in the "wide range of options"
modeled here, including the specifics of the web portal.
REQUEST NO. 44: Please provide all evidence demonstrating that each of the
behavioral feedback tool measures was appropriately assigned a one-year measure life.
REQUEST NO.45: Please provide the calculations, energy savings estimates, and
sources (including dates) demonstrating that each of the behavioral feedback tool measures is not
cost-effective.
R-EQUEST NO. 46: Idaho Power's Conservation Potential Assessment Appendix states
on page F-l that "The market adoption rates for the Idaho Power study were developed using the
ramp rates from the Northwest Power and Conservation Council's Sixth Plan as a starting point.
The ramp rates were then adjusted based on actual Idaho Power program history and information
from program evaluations."
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 2,2014
Please provide the assumptions, calculations, and sources (including dates) used to
develop the final ramp rates for each measure in Appendix F. Please provide all workpapers in
executable format.
REQUEST NO. 47: Page 49 of the DSM Report states that the third party evaluation of
Heating and Cooling Efficiency recommended that Idaho Power "develop a brand for Idaho
Power's energy effrciency programs [at the portfolio level] to increase customer awareness."
Does Idaho Power plan to implement this suggestion? Please explain why or why not,
DATED at Boise, Idaho, this )ypday of July 2014.
ln-,\Q
Neil Price
Deputy Attorney General
Technical Staff: Stacey Donohue (43-47)
i:umisc:prodreq/ipcel4.npdesdnk prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 2,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF JULY 2014, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO rDAHO POWER COMPANY, IN CASE NO. IpC-E-r4-04, By MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
PETER J zuCHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH ST
BOISE ID 83702
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 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