20141203Staff 1-11 to IPC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
BAR NO. 8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
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BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR ) CASE NO. rPC-E-14-38
AUTHORITY TO FUND ITS CONTINUED )
PARTICIPATION IN THE NORTHWEST ) FIRST PRODUCTION
ENERGY EFFICIENCY ALLIANCE ) REQUEST OF THE
THROUGH THE ENERGY EFFICIENCY ) COMMISSION STAFF TO
RIDER.) IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, 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, DECEMBER 17, 2014.1
This Production Request is to be considered as continuing, and Idaho Power 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 produced.
Please provide answers to each question and any supporting workpapers that provide detail or
are the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person preparing
' Staffis requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney at
(208) 334-03 I 8.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER 3,2014
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. Reference IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the number of Industrial Technical Training classes
NEEA offered in Idaho for each year from 2010-2014. Please provide the topic, the number of
participants, and the cost to deliver the trainings and webinars in Idaho Power's service territory.
REQUEST NO. 2: Please provide the Company's forecasted number of Industrial Technical
Trainings that it will offer in Idaho for each year from 2015-2019. Please provide the topic, the
estimated number of participants, and the estimated cost to deliver the trainings and/or webinars.
REQUEST NO.3: Why does the Company believe that "it remains unclear if Idaho
customers will utilize the deep energy retrofit tool that is under development as a direct result of
NEEA's prior EBR initiative"? (Kline Direct Testimony, p. 9)
REQUEST NO. 4: Does the Company plan to replicate NEEA's Kilowatt Crackdown event?
If not, please explain why not.
REQUEST NO. 5: Please explain why the Company is not funding the "Associated
Administrative Expenses" (Attachment 3, p. 13).
REQUEST NO. 6: For the 2015-2019 Business Plan time period, please provide the
Company's total estimated marketing expenditures as a result of opting out of NEEA's Marketing
and Stakeholder Support option. Please also break out expenses by category (including but not
limited to internal labor and external labor) and include a brief description of the marketing materials.
REQUEST NO. 7: Please provide the Company's marketing plans which include NEEA-
funded programs. Please distinguish the NEEA marketing efforts from the Company's local
progrfims.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY DECEMBER 3, 2OI4
REQUEST NO. 8: Page 12 of Mr. Kline's Direct Testimony states that "Idaho Power's
media purchase rates are often lower than the nonprofit rates that NEEA can obtain." Under what
circumstances are the Company's media purchase rates lower than nonprofit rates?
REQUEST NO. 9: Please provide the PowerPoint presentation used for the April24,2014
EEAG conference call.
REQUEST NO. 10: During the20l0-2014 Business Plan, what percentage of NEEA's total
regional savings was allocated to Idaho Power?
REQUEST NO. 11: Please provide the2015-2019 forecasted energy savings for Idaho
Power. Please indicate which initiatives are likely to generate the majority of energy savings.
Dated at Boise, Idaho, tni, 5C aay of Dece mber2014.
Technical Staff: Nikki Karpavich
i:umisc:prodreq/ipcel4.38djhdenk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Deputy Attomey General
DECEMBER 3, 2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF DECEMBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF, IN CASE NO. IPC-E-14-38, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWTNG:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
THERESA DRAKE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE