20160621Staff 27-36 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:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
DETERMINATION OF 2OI5 DEMAND.SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED
N,ECEIVED
,ii:li 2l ,$H I0: 35
CASE NO. IPC.E.16-03
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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BEFORE THE IDAHO PUBLTC UTTLITIES COMMISSION
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
TUESDAY, JULY 5,2016.1
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 Staff is requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at [phone].
THIRD PRODUCTION REQUEST
TO IDAHO POWER JLINE 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
3l.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.27: Please provide all presentations made to the EEAG about the 2010
DSM MOU in2014 and 2015.
REQUEST NO. 28: Please provide the total amount spent marketing the Company's
non-DSM activities in2014 and 2015.
REQUEST NO. 29: Please provide the total amount spent on the Company's texting-
and-driving campaign in20l4 and 2015.
REQUEST NO. 30: Please provide the weekly News Briefs emails that were distributed
to media in Idaho Power's service territory in 2015.
REQUEST NO. 3l: Did Idaho Power claim duct sealing savings for the 34 homes that
were serviced as test-only in the Energy House Calls Program?
REQUEST NO.32: Please explain the significant decrease in expenses for the
Residential Education Initiative from 2014 to 2015 cited on page 172 of Appendix 5 in the 2015
DSM report.
REQUEST NO. 33: Please provide an estimate for the number of low-income
households on the waiting list for weatherization services in its service territory. Staff
understands that the Company does not maintain this waiting list, but believes that the Company
may have an understanding about the need for low-income weatheization services through its
close collaboration with the CAP agencies in its service territory.
THIRD PRODUCTION REQUEST
TO IDAHO POWER JLINE 2I,2016
REQUEST NO. 34: In Request No. 22, Staff asked for information on the dates that
demand response programs were used in 2015. Please provide the same information for2014.
REQUEST NO.35: Please provide the available capacity the Company had to meet
demand on the dates in 2014 and 2015 in which demand response programs were used. Please
separate the available capacity by resource.
REQUEST NO.36: Please provide the number of participants in the A/C Cool Credit
program for each month since the implementation of the program.
Dated at Boise, Idaho, this f o*of June 2016.
Technical Staff: Stacey Donohuel2T-33
Donn English/34-36
i:umisc:prodreq/ipcel6.3bkdesd prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER
Attorney General
JUNE 2I,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF JUNE 2016,
SERVED THE FOREGOING THIRD 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 : lnordstrom@idahopower. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail : dreading@mindsprin&com
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail : [e-mail]
CERTIFICATE OF SERVICE