20160421Staff 1-15 to IPC.pdf

BRANDON KARPEN RECEIVED
DEPUTY ATTORNEY GENERAL
rDAHO pUBLTC UTrLrrrES COMMTSSTON ?016 f,PR 2l PH 2: 30
PO BOX 83720
BorsE, rDAHo 83720-0074 ,i r, ,:i.i;-Yl?&i8sro"
(zos) 334-0357 ' ':1 lf '' r"t"
IDAHO BAR NO. 7956
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-16-03
DETERMINATTON OF 2015 DEMAND-SIDE )
MANAGEMENT EXPENDITURES AS ) FIRST PRODUCTIONPRUDENTLYINCURRED ) REQUEST OTTHE
) COMMISSION STAFF TO
) IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, request that Idaho Power Company (Company;
Idaho Power) provide the following documents and information as soon as possible, by
THURSDAY, MAY 5,2016.r
This Production Request is continuing, and the 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, 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
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER APzuL 2I,2016
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. 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 a list of all expenses charged to the demand-side
management (DSM) tariff rider during 2015. 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 the expenditures provided reconcile with the amounts listed in
the Company's 2015 DSM Annual Report. Please also identify if each expense is an incentive
payment, purchased service, labor/administrative, materials and equipment, or other expense.
Please provide the requested information in Excel format with all formulas intact.
REQUEST NO.2: Please provide the same information requested above for demand
response 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) by class and
tariff schedule for the DSM tariff rider in 2015.
REQUEST NO. 5: Please provide the cost-effectiveness workpapers and calculations
for each DSM program in 2015 in Excel format with all formulas intact.
REQUEST NO. 6: Over the past several years, the Company has collected more
revenue from the tariff rider than it has expensed. Please explain how Idaho Power plans to
address this over-collection.
FIRST PRODUCTION REQUEST
TO IDAHO POWER APRIL 2I,2016
REQUEST NO. 7: Please provide copies of all audit reports for all
Company's DSM expenses and processes.
audits of the
REQUEST NO. 8: Please provide the amount budgeted and spent for the DSM-related
marketing campaign for 2015. Please provide documentation supporting the amount spent,
including invoice copies and proof of payment. Additionally, please provide copies of all print
and web ads, and television and radio spots.
REQUEST NO. 9: Please provide a breakdown of the number and type of dwellings
weatherized under the WAQC program for PY 2012-2015. (i.e., Single Family, Mobile,
Multifamily)
REQUEST NO. 10: Please provide a breakdown of the number and type of dwellings
weatherized under the Weatherization Solutions for Eligible Customers program for PY 2012-
2015. (i.e., Single Family, Mobile, Multifamily)
REQUEST NO. 11: How does the Company estimate the energy savings for individual
measures installed in participants' homes as part of the WAQC and Weatherization Solutions for
Eligible Customers programs? Please provide any reference materials used in making estimated
savings determinations.
REQUEST NO. 12: Please provide average energy savings on a per measure basis for
each of the measures reviewed in Table 3 of the 2015 Weatherization Assistance for Qualified
Customers Annual Report.
REQUEST NO. 13: Please provide a current organizational chart by title and name
showing all Idaho Power employees who charge time to the Energy Efficiency Tariff Rider.
Please include complete job descriptions, required qualifications, salary ranges, bonus
opportunities, and total compensation ranges, including benefits, for all employees identified
above. Please provide the contact information for an Idaho Power employee with whom we may
arrange an on-site audit for confidential information.
FIRST PRODUCTION REQUEST
TO IDAHO POWER APRIL 2I,2016
REQUEST NO. 14: Please provide the date and percentage of 2015 wage increases
granted to employees whose salaries are funded in total or part by the energy efficiency tariff
rider.
REQUEST NO. 15: Please provide a copy of the Company's Technical Resource
Manual.
Dated at Boise, Idaho, this t\4y day of Apr il2016.
Technical Staff: Donn English/l-6
Amber Christofferson/7-S
Johnathan Farleyl9-L2
Stacey Donohue/l3-15
i:umisc:prodreq/ipce I 6.3bkdeacjfsd prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER APRIL 2I,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OF APRIL 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E.16-03,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-mail: [e-mail]
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@ idahopower. com
CERTIFICATE OF SERVICE