20160512IPC to Staff 1-15.pdf

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LISA D. NORDSTROM
Lead Counse!
[e-mail]
May 12,2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-16-03
2015 Demand-Side Management Expenses - ldaho Power Company's
Response to the First Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to Staffs production requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
f*r:-n ft^tx",*,
Lisa D. Nordstrom
LDN:csb
Enclosures
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An IDACORP Companv
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (837021
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rdstrom@ ida hopower. com
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERM!NATION OF 2015 DEMAND-SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. |PC-E-16-03
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated April 21 ,2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 1
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.
RESPONSE TO REQUEST NO. 1: The requested information is voluminous,
proprietary, and confidential. lt will be made available for audit pursuant to ldaho Code
S 61-610 and Rule of Procedure 227 (IDAPA 31.01 .01.227) at ldaho Power's corporate
headquarters. Please contact Doug Jones at [phone] or Camilla McClusky at
[phone] to arrange a time to review the requested material.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: Please provide the same information requested above for
demand response payments not included in the tariff rider.
RESPONSE TO REQUEST NO. 2: The requested information is proprietary and
confidential. !t will be made available for audit pursuant to ldaho Code $ 61-610 and
Rule of Procedure 227 (IDAPA 31.01 .01.227) at ldaho Power's corporate headquarters.
Please contact Doug Jones at [phone] or Camilla McClusky at [phone]
to arrange a time to review the requested material.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 3: Please provide the calculation of the interest accrued to the
DSM tariff rider account.
RESPONSE TO REQUEST NO. 3: Please see the Excel file provided on the
non-confidential CD. The Company calculates interest based on the average of the
beginning and ending balances for the month. lnterest is recorded on a one-month lag.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 4: Please provide the revenue received (excluding interest) by
class and tariff schedule for the DSM tariff rider in 2015.
RESPONSE TO REQUEST NO. 4: Please see the Excel file provided on the
non-confidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 5: Please provide the cost-effectiveness workpapers and
calculations for each DSM program in 2015 in Excel format with all formulas intact.
RESPONSE TO REQUEST NO. 5: Please see the Excel file provided on the
non-confidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
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 ldaho
Power plans to address this over-collection.
RESPONSE TO REQUEST NO. 6: The ldaho Energy Efficiency Rider ("Rider")
(IPUC No. 29, Tariff No. 101, Schedule 91) is collecting at the percentage approved by
the ldaho Public Utilities Commission ("Commission") in Order No. 32426; the Rider
does not "over-co!lect."
ldaho Power does not have any near-term plans to adjust the Rider percentage
or refund amounts to customers. However, the Company closely monitors the Rider
account and has regular communication with its Energy Efficiency Advisory Group and
Commission Staff ("Staffl') about the Rider balance.
The response to this Request is sponsored by Tami White, Rate Design
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 7: Please provide copies of all audit reports for all interna! audits
of the Company's DSM expenses and processes.
RESPONSE TO REQUEST NO. 7: Please see the e-mail provided on the non-
confidential CD, in lieu of a report (a report is only issued if there are findings noted
during the audit), associated with the 2015 testing of the internal controls related to the
Company's DSM liability process. This process is the Regulatory - DSM Liability
(RDSL) Sarbanes-Oxley ("SOX") process, which is reviewed by lnternal Audit as part of
compliance with annual SOX requirements.
The response to this Request is sponsored by Jeff McCormick, Audit Services
Audit Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
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.
RESPONSE TO REQUEST NO. 8: The amount budgeted for the 2015
Residential Energy Efficiency Awareness Campaign was $397,848.00.
The amount spent on the 2015 Residential Energy Efficiency Awareness
Campaign was $466,537.93.
Copies of all print and web ads, television and radio spots, and supporting
invoices are provided on the non-confidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 9
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)
RESPONSE TO REQUEST NO. 9: The following table shows the dwelling
distributions for the Weatherization Assistance for Qualified Customers ("WAQC")
program for PY 2012-2015:
2012 2013 2014 2015
Single Family 67 92 71 85Townhome0000Multi-family 3 18 48 5
Mobile/Manufactured Home 164 141 131 145Non-profitBuildings 4 3 5 8
Total 238 254 255 243
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
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)
RESPONSE TO REQUEST NO. 10: The following table demonstrates the
dwelling distributions for weatherized homes in the Weatherization Solutions for Eligible
Customers program for the years 2012-2015:
2012 2013 2014 2015
Single Family 60 103 64 88
Townhome6121Multi-family022027
Mobile/Manufactured Home 75 60 32 55
Total 141 166 118 171
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
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.
RESPONSE TO REQUEST NO. 11: ldaho Power estimates savings at the
whole-house level, not at the measure level. The primary source for the savings
estimate methodology is the following document: The Uniform Methods Project:
Methods for Determining Energy Efficiency Savrngs for Specific Measures, Chapter 8.
Whole-Building Retrofit with Consumption Data Analysis Evaluation Protocol. The
document can be found at http://www.nrel.qov/docsffy13osti/53827.pdf. Additional
reference documents for whole-house consumption analysis methods include: Ducfless
Heat Pump lmpact & Process Evaluation: Billing Analysis Report and SEEM
Calibration, Phase 1, Adjustments to Reflect Total Heating Energy, 2014 Update. The
documents can be accessed or downloaded at https://neea.org/docsidefautt-
source/reports/ductless-heat-pump-impact-process-evaluation--billing-analysis-report. pdf?sfursn=6 and
http://rtf. nwcou ncil.org/results. htm?q=calibration%20report.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 12
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.
RESPONSE TO REQUEST NO. 12: ldaho Power does not estimate savings for
the WAQC program at the measure level. Please see the Company's response to
Staff's Request No. 11 for savings methodology reference documents.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
REQUEST NO. 13: Please provide a current organizational chart by title and
name showing all ldaho 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 ldaho Power
employee with whom we may arrange an on-site audit for confidential information.
RESPONSE TO REQUEST NO. {3: The confidential organizational chart with
names and titles for the Energy Efficiency and Corporate Communications departments
is available for viewing at the Company's corporate headquarters. Employees who
charge time to the Rider are highlighted. Other employees who charge time to the
Rider are embedded in various areas of the business and/or regional offices, including
Agricultural Representatives, Application Development Analysts, Customer
Representatives, Financial Analysts, GIS Analysts, and System Administrators. For this
reason, organizationa! charts for these positions are not included.
Confidential job descriptions, minimum education and experience requirements,
salary ranges, and target annual incentive percentages are also available for viewing at
the Company's corporate headquarters. The benefits provided to these employees are
the standard programs offered to all employees, including health and welfare, life and
disability insurance, retirement, and paid time-off benefits.
Per Staffs request, please contact Doug Jones at [phone] or Camilla
McClusky at [phone] to arrange a time to review the requested material.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
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.
RESPONSE TO REQUEST NO. 14: The confidential dates and percentage of
2015 wage increases for the employees noted in the Company's response to Staffs
Request No. 13 is found on the confidential Excel file provided on the confidential CD.
The confidential CD will only be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
REQUEST NO. 15: Please provide a copy of the Company's Technical
Resource Manual.
RESPONSE TO REQUEST NO. 15: The Company believes Staff is referring to
Idaho Power's Technical Reference Manual included under the Research/Surveys
section of ldaho Power's Demand-Side Management 2015 Annual Report Supplement
2: Evaluation ltled in Case No. IPC-E-16-03. ln the PDF version, it can be found on
page 447 ot 854.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 12th day of May 2016.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of May 2016 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Brandon Karpen
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conseruation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
lndustrial Gustomers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17