20160520Staff 16-26 to IPC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
DETERMINATION OF 2015 DEMAND-SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED
i:i ICTIVED
iiliI liiiY 20 Al'l 9: 20
r, i .? t./1.-, i"i-ii-.Ll'1.'Ii r;i-;l,riiiiSSiOil
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E-16-03
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey 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
FRTDAY, JUNE 3,2016.1
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].
SECOND PRODUCTION REQUEST
TO IDAHO POWER MAY 20,2076
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
31.0r.0r.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. 16: What documentation does IPC receive from the CAP agencies in
order to determine which specific measures are paid for with utility funds under the WAQC
program?
REQUEST NO. 17: Please provide or make available the EA5 audit reports and Job
Order Sheets for each of the 225ldaho homes completed during the 2015 WAQC program.
REQUEST NO. 18: For each of the 225ldaho homes completed during the 2015
WAQC program, please provide a list of measures installed at each home; the cost of each
measure and the amount Idaho Power paid for each measure.
REQUEST NO. 19: Please provide any quality assurance or inspection documentation
IPC collects or receives regarding the installation of measures for each of the 225 ldaho homes
completed during the 2015 WAQC program.
REQUEST NO.20: What steps does IPC take to ensure all measures installed at homes
under the WAQC program are installed properly and performing as designed?
REQUEST NO.21: What steps does IPC take to ensure participants are receiving
accurate and meaningful information as part of the Participant Education portion of the WAQC
program?
REQUEST NO. 22: For each date during 2015 in which demand response programs
were used, please provide the date, the amount of load reduction (by program), the system peak,
and the daily load curyes.
SECOND PRODUCTION REQUEST
TO IDAHO POWER MAY 20,2016
REQUEST NO.23: Please provide the amount, by units and value, of the unused
equipment inventory for the A/C Cool Credit program.
REQUEST NO.24: Please provide a list of customers choosing to self-direct their DSM
rider contributions.
REQUEST NO.25: Please provide the ledger for the self-directed accounts, showing
the contributions, expenses and final balance.
REQUEST NO.26: Does the Company believe that measures and programs should be
designed and implemented in order to pass all three primary cost-effectiveness tests (the
Participant, UCT, TRCX Please explain why or why not.
Dated at Boise, Idaho, this ZOItO*of May 2016.
Technical Staff: Johnathan Farleyll6-21
Donn EnglisU22-25
Stacey Donohue/26
i :umisc:prodreq/ipce I 6.3bkdejfsd prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER MAY 20,20t6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF MAY 2016,
SERVED THE FOREGOING SECOND 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 TD 83702
E-mail : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@,idahopower, com
PETER J zuCHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail : [e-mail]
SECRETARY
CERTIFICATE OF SERVICE