20180525IPC to Staff 1-17.pdf

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JULIA A. HILTON
Senior Counsel
[e-mail]
May 25,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-18-03
2017 Demand-Side Management Expenses - ldaho Power Company's
Response to the First Production Request of the Commission Staff
Dear Ms. Hanian
Enclosed forfiling in the above matter please find an originaland 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 confidentia! disks
containing information responsive to Staff's production requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Julia A Iton
JAH:csb
Enclosures
122 1 W. ldaho 5t. (83702)
POG€DiO0 (83707)
BdBe, rwSGE D St.
Boise, lD 83702
An IDACORP Companv
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JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ih ilton@ idahopower. com
i?ECEIVED
20i8riiY25 PH l:31
rh t 'a .l li: lf\lJl. '.* f''-r uLlU
I I i iLiTIES COil{hIISSION
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2017 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED
CASE NO. !PC-E-18-03
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Compzny"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated May 4,2018, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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REQUEST NO. 1: Please provide a list of all expenses charged to the demand-
side management (DSM) tariff rider during 2017. 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 2017 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 proprietary and
confidentia! pursuantto ldaho Code SS 74-107 throughT4-109 and 48-101. lt will be
made available to the ldaho Public Utilities Commission Staff ("Staff') for audit pursuant
to ldaho Code S 61-610 and ldaho Rule of Procedure 227 (IDAPA 31.01 .01.227) at
ldaho Power's corporate headquarters. Please contact Tami White 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 in 2017 not included in the tariff rider.
RESPONSE TO REQUEST NO. 2: The requested information is proprietary and
confidential pursuantto ldaho Code SS 74-107 throughT4-109 and 48-101. lt will be
made available to Staff for audit pursuant to ldaho Code S 61-610 and ldaho Rule of
Procedure 227 (IDAPA 31 .01 .01.227) at ldaho Power's corporate headquarters. Please
contact Tami White 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
enclosed 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
REQUESf Nq.4: Please provide the revenue received (excluding interest) by
class and tariff schedule for the DSM tariff rider in 2016.
RESPONSE TO REQUEST NO. 4: The Company assumes Staff is requesting
2017 information. The table below contains the 2017 ldaho Power Energy Efficiency
Rider funding by rate class.
2017
Rate Class Rider Fundins
Residential
Commercial
lndustrial
!rrigation
Lishtins
18,363,441
10,355,618
5,941,459
4,849,868
174,789
Total $ 39,685,175
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 - 5
$
$
$
$
$
REQUES'I NQ.l5: Please provide the cost-effectiveness workpapers and
calculations for each DSM program in 2017 in Excel format, with allformulas intact.
RESPONSE TO REQUEST NO. 5: Please see the Excel file provided on the
enclosed 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: Please provide copies of all audit reports referencing any of
the Company's DSM expenses and processes for 2013-2017. lf no reports were
issued, please provide the date and scope of the audit and all internal auditor
workpapers.
RESPONSE TO REQUEST NO. 6:Audit Services ("AS") performed audits of
interna! controls over the Company's DSM expenses and processes during the period
2013-2017 as part of complying with Sarbanes-Oxley ("SOX") requirements. The
related SOX processes are Regulatory DSM Liability ('RDSL') and Entity-Wide
lnformation & Communication ('EW|C" C02). SOX processes are tested on a rotational
basis. The following table provides testing performed on these SOX processes by year:
SOX Process 2013 2Ol4 2015 2016 2017 Comments
RDSt
€wrc
x x xxxx N/A
N/A
Not tested in 2017.
Not tested 2013,2014 and 2017N/A N/A
While the SOX control review is documented, full audit finding reports are only
issued for SOX internal control audits in the event of a finding.
The requested information is proprietary and confidential pursuant to ldaho Code
SS 74-107 through 74-109 and 48-101. lt will be made available to Staff for audit
pursuant to ldaho Code S 61-610 and ldaho Rule of Procedure 227 (IDAPA
31.01 .01.227) at ldaho Power's corporate headquarters. Please contact Tami White at
[phone] or Camilla McClusky at [phone] to arrange a time to review the
requested material.
The response to this Request is sponsored by Sonse Sutezzo, Operations Audit
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 7: Please provide the amount budgeted and spent for the DSM-
related marketing campaign for 2017. Please provide documentation supporting the
amount spent, including invoice copies and proof of payment. Additionally, please
provide copies of al! print and web ads, and television and radio spots.
RESPONSE TO REQUEST NO. 7: Please see the attachments provided on the
enclosed confidential CD for documentation supporting the amount spent. Per a May 7,
2018, phone conversation between ldaho Power and Staff, Staff agreed invoice copies
would be sufficient to fulfill this Request. Due to the volume of files being provided in
response to this Request, the individual file names and the actual documents have not
been labeled with the word "confidential." However, the main file folder and individual
invoice folders have been labeled confidential; all files provided on the confidential CD
in response to this Request should be treated as confidential and handled accordingly.
The confidential CD will only be provided to those parties that have executed the
Protective Agreement in this matter.
ln addition, please see the attachments provided on the enclosed non-
confidential CD for copies of print and web ads and television and radio spots.
The amount budgeted for the 2017 Residential Energy Efficiency Awareness
Marketing Campaign in ldaho was $765,035. The amount spent on the 2017
Residential Energy Efficiency Awareness Marketing Campaign in ldaho was $705,396.
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 - 8
REQUEST NO. 8: 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.
RESPONSE TO REQUEST NO. 8: The requested information is proprietary and
confidential pursuantlo ldaho Code SS 74-107 through 74-109 and 48-101. lt will be
made available for audit pursuant to ldaho Code S 61-610 and ldaho Rule of Procedure
227 (IDAPA 31.01 .01.227) at ldaho Power's corporate headquarters. Please contact
Tami White at [phone] or Camilla McClusky at [phone] to arrange a time
to review the requested material.
The response to this Request is co-sponsored by Pete Pengilly, Customer
Research and Analysis Leader, ldaho Power Company, and Sharon Gerschultz,
Compensation Programs Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF.9
REQUEST NO. 9: For each date during 2017 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 curves.
RESPONSE TO REQUEST NO. 9: Please see the table below for each date in
which demand response programs were used in 2017, with the estimated load reduction
by program. Please see the Excel file provided on the enclosed non-confidential CD
showing the hourly load data from each day highlighting the system peak for each day.
2017 Demand Response Event Results Adjusted for Line Losses to Reflect Generation-Level Load
Reduction (MW)
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
6t20t2017 Time
2-3
PM
3-4
PM
4-5
PM
5-6
PM
6-7
PM
7-8
PM
8-9
PM
lrrigation Peak Rewards
Totals
72.91 146.10 211.34 248.03 199.33 126.14 60.90
72.91 146.10 211.34 248.03 199.33 126.14 60.90
6t26t2017 Time
2-3
PM
3-4
PM
4-5
PM
5-6
PM
6-7
PM
7-8
PM
8-9
PM
A/C Cool Credit
Flex Peak Program
Totals
21.31
33.367
26.64
34.5744
28.92
36.00 33.92
33.37 34.57 36.00 33.92
7t6t2017 Time
2-3
PM
3-4
PM
4-5
PM
5-6
PM
6-7
PM
7-8
PM
8-9
PM
lrrigation Peak Rewards
Totals
81.72 163.89 239.03 318.07 236.35 154.18 79.04
81.72 163.89 239.03 318.07 236.35 1s4.18 79.04
7t14t2017 Time
2-3
PM
3-4
PM
4-5
PM
5-6
PM
6-7
PM
7-8
PM
A/C Cool Credit
Flex Peak Program
Totals
20.72
28.43
23.68
27.00
23.26
25.14 25.35
49.15 50.68 48.40 25.35
8t2t2017 Time
2-3
PM
3-4
PM
4-5
PM
5-6
PM
6-7
PM
7-8
PM
8-9
PM
A/C Cool Credit
Flex Peak Program
Totals
24.92
22.13
25.46
23.10
24.59
18.56
25.24
24.92 47.60 47.69 43.80
8-9
PM
8t3t2017 Time
2-3
PM
3-4
PM
4-5
PM
5-6
PM
6-7
PM
7-8
PM
8-9
PM
lrrigation Peak Rewards
Totals
49.37 115.52 181 .86 235.68 186.31 120.16 53.82
49.37 115.52 181.86 235.68 186.31 120.16 53.82
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. 10: Regarding the Home Energy Audit Program, the report
asserts marketing materials were sent to customers who "have the propensity to
participate." Please provide the criteria used for selecting these customers.
RESPONSE TO REQUEST NO.10:ldaho Power purchases third-party
demographic data to help promote its marketing and education efforts. Four segments,
or combinations, of demographic characteristics were identified as having a higher
propensity to participate in the Home Audit based on analysis of prior program
participants. The demographic parameters used to identify the four targeted clusters
included: age, marital status, home ownership, presence of children in the home,
income, and urban/rural status. The analysis determined that the targeted groups were
estimated to be 2.5 lo 3.5 times more likely to participate in the program than the
average customer.
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. 12
REQUEST NO. 11: Please provide the number of brochures printed and mailed
through the Multi-family Energy Savings Program in 2017 as well as the response rate,
if available.
RESPONSE TO REQUEST NO. 11: ln 2017, 500 brochures were printed for the
Multifamily Energy Savings Program. Approximately 350 brochures were distributed at
community outreach events, such as home and garden shows, 105 were distributed to
regional Customer Representatives for use in the field, and the remaining 30 were used
by the Program Specialists. Fifteen brochures were mailed out to property owners and
management companies. The Company does not track response rates from the
brochures.
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. 12: Please provide the number of unique site visits for the new
Multi-Family Energy Savings Program website and where customers enter that page
from (i.e. search engine, homepage, ad click through, etc.).
RESPONSE TO REQUEST NO. 12: The Multifamily Energy Savings Program
webpage launched in November 2017. Data from November 1,2017, through May 13,
2018, shows 352 unique page visits. The largest referrer is Google, and the second
largest source of traffic is ldaho Power's My Account page.
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. 13: The Residential New Construction Pilot Program description
states it used the Snake River Building Contractors Association app "to increase
customer engagement." Describe what "customer" means in this context. ls the
Company referring to builders as customers?
RESPONSE TO REQUEST NO. 13: ln this context, the term "customers" refers
to customers interested in new or remodeled homes and builders who attend the
Canyon County Parade of Homes.
The Snake River Building Contractors Association application was used
specifically for the Canyon County Parade of Homes. ldaho Power advertised on the
Snake River Building Contractors Association application because it hosts the Canyon
County Parade of Homes-a showcase tour of new and renovated homes held
annually. The event targets customers interested in new homes, home renovations,
and home construction. Residential builders also attend the Parade of Homes event.
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 - 15
REQUEST NO. 14: For the Shade Tree Project, please provide a breakdown of
program expenses, including the U.S. Forest Service Western Competitive States Grant
as well as which expenses were charged to each funding source.
RESPONSE TO REQUEST NO. 14: Funding from the U.S. Forest Service
Western Competitive States Grant was allocated to fund the purchase of trees for the
spring shade tree event in the amount of $15,090.64 and to fund one tree field inspector
over the summer of 2017 in the amount of $5,304. Funds from the U.S. Forest Service
Western Competitive States Grant were held and disbursed directly by Southwest ldaho
Resource Conservation & Development. Please refer to the Company's response to
Staff's Request No. 1 for additional information specific to program expenses by cost
element.
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 - 16
REQUEST NO. 15: For the Simple Steps, Smart Savings Program, please
provide the number and type of appliances incented during 2017 as well as sale date
and location for each, if available. Additionally, please provide the actual reduced
pricing for each appliance, where available.
RESPONSE TO EST NO. 15:Please see the confidential Excel file
provided on the confidential CD for the breakdown of sales by store location, sales date,
product type, and number of appliances.
Reduced pricing is as follows:
a Dell's Home Appltanee. Gift pack of laundry products valued at
a
$10.00 for the purchase of a qualified clothes washer.
Sears Hometown. Twenty-five dollar instant markdown for the
purchase of a qualified clothes washer except for Black Friday
promotion where customers received a 180-!oad supply of detergent
for the purchase of a qualified product.
o Customers that purchased a qualified clothes washer at Sears
also received a $25 Sears gift card.
a Re U{rllev. Thirty-five dollar RC Willey gift card for the purchase of a
qualified clothes washer during the promotional periods. ldaho Power
paid $25 towards each incentive, RC Willey added an additional $10.
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, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
REQUEST NO. 16: For the Simple Steps, Smart Savings Program, please
provide additional information regarding CLEAResult field staff working at these events.
Please include the number of employees at each event, job descriptions, required
qualifications, salary ranges, bonus opportunities, and total compensation ranges,
including benefits, for all employees identified above.
RESPONSE TO REQUEST NO. 16: Please see the Excel file provided on the
non-confidential CD for the date, location, type of event, and number of CLEAResult
staff. Because the field representative for each event is employed by CLEAResult,
ldaho Power does not possess the qualifications, salary ranges, bonus opportunities,
and tota! compensation ranges, including benefits, for this representative.
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 - 18
REQUEST NO. 17: For the Weatherization Assistance for Qualified Customers
Program, please identify ldaho Power staff labor costs for administering this program.
Please include the number of administrators, job descriptions, required qualifications,
salary ranges, bonus opportunities, and total compensation ranges, including benefits,
for a!! employees identified above.
RESPONSE TO REQUEST NO. 17: ldaho Power has one Program Specialist ll
who administers the Weatherization Assistance for Qualified Customers ("WAQC")
program for the Company. Please see the Company's response to Staff's Request No.
8 for the Program Specialist ll job description, required qualifications, salary ranges,
bonus opportunities, total compensation ranges, and benefits.
The 2017 labor and benefits charged to the WAQC program are listed below.
[abor
Benefits
Total
26,220
11,899
S
s 38,11,9
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 25th day of May 2018.
r
IAA. H TON
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of May 2018 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
Edith Pacillo
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Industrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho lrrigation Pumpers Association, !nc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
_ Hand DeliveredX U.S. Mail
_ Overnight Mail
_ FAXX Email [e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Idaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
_ Hand DeliveredX U.S. Mail_ Overnight Mail
_ FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
Christa Bearry,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20