20140805IPC 1-6 to Staff.pdf

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JULIAA HILTON lDAi1O plj, ,-i..corporate Gounsel UTILITIES-COf,it;[e-mail]
August 5,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-14-04
2013 Demand-Side Management Expenses- ldaho PowerCompany's First
Production Request to the ldaho Public Utilities Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
PowerCompany's First Production Requestto the ldaho Public Utilities Commission Staff.
Sincerely,
J,L?k
Julia A. Hilton
JAH:csb
Enclosures
1221 W. ldaho st. (83702)
P.O. 8ox 70
Boise, lD 83707
JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
i h i lton@ ida hopower. com
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER'S
APPLICATION FOR A DETERMlNATION
OF 2013 DEMAND SIDE MANAGEMENT
(DSM) EXPENSES AS PRUDENTLY
INCURRED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. !PC-E-14-04
!DAHO POWER COMPANY'S
FIRST PRODUCTION REQUEST
TO THE IDAHO PUBLIC
UTILITIES COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powed' or "Company"), by and
through its attorney, hereby requests that the ldaho Public Utilities Commission
("Commission") Staff ("Staff') answer the following production requests and provide the
following information and documents in accordance with the Commission's Rules of
Procedure and applicable scheduling orders and notices to be issued by the
Commission in this proceeding.
Please provide information that is responsive to the below requests as soon as
possible but no later than August 26,2014.
This production request is to be deemed continuing in nature and Staff is
requested to provide, through supplementation, additional documents, or information
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST
TO THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 1
that is responsive to this request that it, or any person acting on its behalf, may later
come into possession or become aware of.
REQUEST NO. 1: On pages 8-9 of Staff's Comments, Staff states, "lnstead of
relying on customer-preference based marketing techniques that are losing
effectiveness, ldaho Power should independently or with the help of external experts,
determine and fully fund effective marketing techniques to drive demand for programs."
a. Please provide any and all work papers, data, or other information
used to determine whether or not customer-preference based marketing techniques are
losing effectiveness.
b. Please provide any and all work papers, data, or other information
used to define and evaluate "effective marketing techniques."
REQUEST NO. 2: On page 9 of Staffs Comments, Staff "determined that the
Company is not investing sufficiently in its marketing effort when compared to national
averages." Please provide any and all work papers, data, or other information used to:
a. Establish national averages of marketing being 4 to 8 percent of
demand-side management ('DSM") budgets; and
b. Determine the sufficiency of ldaho Power's investment in
marketing.
REQUEST NO. 3: On page 7 of Staff's Comments, Staff includes a graph
entitled "Annual Percentage Change in Energy Efficiency Savings."
a. Please provide any and al! work papers, data, and other
information, including Excel spreadsheets with formulas intact, used to create the graph.
b. For each year illustrated on the graph, please provide the DSM
annual reports from Avista Corporation and Rocky Mountain Power.
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST
TO THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 2
Not including custom programs and measures, please provide the
savings assumptions, sources, and source dates used to determine each utility's annual
energy savings as required by the Memorandum of Understanding entered into by
ldaho utilities and Staff.
d. !f the savings assumptions in subsection c are not sourced from
public documents (i.e., Regional Technical Forum measure workbooks), please provide
the savings source documentation.
REQUEST NO. 4: On page 10 of Staff's Comments, Staff states that "many
utilities have found that customers in aggregate reduce their energy consumption
between 1 to 3 percent." Please provide any and all research, work papers, data, or
other information supporting this statement.
REQUEST NO. 5: On page 11 of Staffs Comments, Staff states that
"Depending on the characteristics of the measures acquired, customers could have
saved approximately $474,000 to $2,164,000 in 2013 if ldaho Power had met its IRP
targets." Please provide any and all work papers, data, and other information, including
Excel spreadsheets with formulas intact, supporting this calculation.
REQUEST NO. 6: On page 12 of Staffs Comments, Staff states that "the
opportunity cost of the Company not achieving the full economic potential identified in
the CPA could have saved customers anywhere from $2,235,156 to $10,212,708 in
2013." Please provide any and all work papers, data, and other information, including
Excel spreadsheets with formulas intact, supporting this calculation.
DATED at Boise, ldaho, this 5th day of August 2014.
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST
TO THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 3
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this Sth day of August 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO
THE IDAHO PUBLIC UTILITIES COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
D. Neil Price
Deputy Attomey General
Idaho Public Utilities Commission
47 2 W est Washington (83702 )
P.O. Box 83720
Boise, ldaho 83720-007 4
Industrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST
TO THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 4
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