20170406Staff 1-12 to IPC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
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Street Address for Express Mail:
472 W, 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
DETERMINATION OF 2016 DEMAND-SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED
CASE NO. IPC-8.17.03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Idaho Power Company (Company; Idaho
Power) provide the following documents and information as soon as possible, but no later than
THURSDAY, APRIL 27,2017 .
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
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 APRIL 6,2017
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 2016. 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 in2016 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 in20l6.
REQUEST NO. 5: Please provide the cost-effectiveness workpapers and calculations
for each DSM program in20l6 in Excel format with all formulas intact.
REQUEST NO. 6: Please provide copies of all audit reports referencing any of the
Company's DSM expenses and processes for 2012-2016. If no reports were issued, please
provide the date and scope of the audit and all internal auditor workpapers.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 6,2017
REQUEST NO. 7: Please provide the amount budgeted and spent for the DSM-related
marketing campaign for 2016. 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. 8: 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.
REQUEST NO. 9: Please provide a copy of the Company's Technical Resource
Manual.
REQUEST NO. 10: For each date during 2016 in which demand response progftrms
were used, please provide the date, the amount of load reduction (by program), the system peak,
and the daily load curves.
REQUEST NO. 11: Please provide the date and percentage of wage increases granted
to each employee by year (2011-2016) whose salaries are funded in total or part by the Energy
Efficiency Tariff Rider.
REQUEST NO. 12: Please provide copies of or access to the surveys and other back up
documentation used in the general wage adjustment information as provided in Confidential
ExhibitNo.4.
FIRST PRODUCTION REQUEST
TO IDAHO POWER J APRIL 6,2017
Dated at Boise,Idaho, this
Technical Staff: Donn English/l-l0
Joseph Terrylll-12
i:umisc:prodreq/ipce I T.3djhdejt prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER
tr day of Apr itzot|
Deputy Attorney General
4 APRIL 6,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY oF APRIL 2017,
SERVED THE FOREGOING F'IRST PRODUCTION REQUEST OF THE
COMMISSION STAFT' TO IDAHO POWER COMPANY IN CASE NO. IPC-E-17-03,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : [e-mail]
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE