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LISA D. NORDSTROM
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March 18,2019
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VIA HAND DELIVERY
Diane Hanian, Secretary
!daho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-19-06
!n the Matter of the Application of ldaho Power Company for Authority to
Revise the Energy Efficiency Rider, Tariff Schedule 91
ldaho Power Company's Response to the First Production Request of the
lndustrial Customers of ldaho Power
Dear Ms. Hanian
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 Industrial
Customers of ldaho Power.
The attachment to Response to Request for Production No. 3 is confidential.
Please handle the confidential information in accordance with the Protective Agreement
executed in this matter.
Very truly yours,
CZaJ Oz(*aa, ,
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n o rd strom @ id a hopowe r. com
NICE'VED
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO REVISE THE ENERGY
EFFICIENCY RIDER, TARIFF SCHEDULE
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CASE NO. tPC-E-19-06
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
I NDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of the lndustrial Customers of ldaho Power
Company dated February 25,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 1: Please provide all discovery responses
related to this docket, whether 'formal' or informal and all exchanges of information
along with workpapers and attachments provided IPUC Staff and/or other entities,
whether or not they are a Party.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Besides the
attachments to the Application in this matter provided to the ldaho Public Utilities
Commission ("Commission") by ldaho Power with the initial filing, there has been no
other exchanges of information. On February 15, 2019, at the request of Mr.
Richardson, copies of Confidential Attachments 1 and 6 to the Application were
provided to the lndustrial Customers of ldaho Power ("lClP'). As a matter of course,
copies of ldaho Power's responses to all parties' discovery requests in this case will be
provided to lClP.
The response to this Request is sponsored by Kimberly Towell, Executive
Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
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REQUEST FOR PRODUCTION NO. 2: Reference the table on page 2 of the
Application. For each row with case numbers please provide:
A) The annual Rider revenue collected at that percentage level.
B) The annual expenditures corresponding to the time period referenced in
"A',.
C) The beginning and ending balance in the Rider Account for each time
period.
D) The amount of Rider funds transferred to, or from, the PCA.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: PIease see the
attachment provided with this request, which shows the beginning balance, accrued
interest, funding, expenses, PCA transfers, and ending balance for the ldaho Energy
Efficiency Rider ("ldaho Rider") by year from 2002-2018. The attachment also footnotes
if there was a corresponding change in the Rider for that year as listed in the chart on
page 2 of the Application. Because the Rider collection percentages were changed
mid-year, years when changes occurred reflect a blending of the collection percentage.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 3: On page 3 of the Application is a
reference to "recently completed forecast Rider balances tor 2019 through 2021..."
Please provide all results, workpapers in electronic format with functioning formulae,
input and output data with sources, and detail all assumptions.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see the
confidential attachment provided on the enclosed confidential CD for ldaho Power's
workpapers in developing the forecast ldaho Rider balances for 2019 through 2021.
The confidential CD will be provided to those parties that have executed the Protective
Agreement in this matter.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 4: For each yeat,2002 through 2017,
please identify, and provide copies of, the source (including dates) of the data used to
measure the cosUbenefit analysis for each program.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: ldaho Power did not
produce annual cost-benefit analyses reports for actual program results prior to the
establishment of the Demand-Side Management ("DSM") 2009 Annual Report ("2009
DSM Report"). Since the 2009 DSM Report, ldaho Power has produced the Demand-
Side Management Annual Report, Supplement 1: Cost-Effectiveness, which includes all
sources (including dates) of data used to measure each program's cost-effectiveness.
The Supplement 1 reports have been filed with the Commission and sent to intervenors
with each annual DSM prudence case between 2010 and 2017 and are publicly
available on the Commission's website as part of the following cases:
. IPC-E-10-09. |PC-E-11-05. IPC-E-12-15. IPC-E-13-08. IPC-E-14-04. tPC-E-15-06. tPC-E-16-03. IPC-E-17-03. IPC-E-18=03
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 5: Attachment 2 to the Application notes
that the Northwest Energy Efficiency Alliance ("NEEA") contract with Idaho Power ends
in June 2020. What is the current level of payment to NEEA? What is the expected level
of payment to NEEA assuming the contract is renewed in 2020? Please explain how
ldaho Power's funding of NEEA is determined to be cost effective, or not. ls it
anticipated that the reasons for the reduction in the EE Rider will also impact in any way
the cost effectiveness evaluation of Idaho Power's participation in NEEA, please
explain?
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The current level of
payment to NEEA for the 2015-2019 funding cycle is $13,450,835 or approximately
$2,690,167 annually on a system-wide basis. lf ldaho Power renews its NEEA contract,
the payment is anticipated to be $14,710,808, or $2,942,162 annually, on a system-
wide basis for the 2020-2024 funding cycle.
With respect to a cost-effectiveness determination of ldaho Power's NEEA
funding, NEEA states that NEEA assesses the cost-effectiveness of the regional
portfolio on a 2O-year horizon and updates it annually. For the 2015-2019 investment
portfolio, the 2O-year cost-effectiveness of the NEEA investment is a levelized cost of
2.9 cents per kilowatt-hour ('kwh'), well below the 2015-2019 Business Plan target of
3.5 cents per kWh, and the benefit cost ratio is 1.4. NEEA uses a TRC approach to
value the longterm costs and benefits stream of the alliance's regional portfolio. NEEA
uses regional assumptions to perform an assessment of the cost-effectiveness of the
programs in the alliance's portfolio of initiatives.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
ldaho Power is not aware of, nor has it quantified, any direct relationship
between the reasons for the reduction in the ldaho Rider and the cost-effectiveness
evaluation of ldaho Power's participation in NEEA.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 6: Attachment 1 (confidential) to the
Application indicates that the cost of the Company's conservation programs (both
incentives and expenses) supported by the Rider are expected to decrease by a stated
sum between 2002 and 2017.
A) Please explain in detail the reason for this expected decrease in
expenditures.
B) Does the Company also expect to achieve different levels of kW and/or
kWh savings as a result of these lower expenditures? Please detail expected changes.
C) Does the Company plan to eliminate any specific programs as a result of
the reduced expenditures? Please identify each such program and explain the reason
for its elimination. Please also identify any reductions in existing programs that will
result from the reduced expenditures and explain the reason for the planned reductions.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The Company believes
that lClP intended to reference the period of 2019 through 2021, the years modeled in
Attachment 1, and its response covers the 2019 through 2021 penod.
A) For each lntegrated Resource Plan ("lRP") Idaho Power contracts with a
third-party consultant to determine the cost-effective of energy efficiency potential in its
service area. ln the report completed for the 2019 lRP, the amount of cost-effective
energy efficiency potential is decreasing over the next 20 years. The decrease is
attributed in part to the 2020 Energy lndependence and Security Act ("E|SA") Phase ll
code implementation that requires that most light bulbs be 60 to 70 percent more
efficient than they were when EISA was signed into law in 2007. Thus, while this
energy savings from energy efficient lighting will be realized in grid savings and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
customer energy usage, energy savings will no longer count in energy efficiency
program savings but will be accounted for in the Company's load forecast once it
becomes part of lighting code in 2020. The 2019 potential study does, however, indicate
that savings from the commercial lighting programs should increase based on the use of
lighting controls.
B) Yes. The Company expects energy efficiency-related costs and kWkWh
savings to decline over the referenced period. The Company also expects the energy
efficiency efforts will remain cost-effective at the lower levels.
C) No. At this time, the Company does not plan to eliminate any specific
programs as a result of the reduced expenditures. The programmatic savings from
residential lighting will decrease after 2020 because of the EISA. This will affect the
claimed saving potential for Educational Distributions, Energy Efficient Lighting, Energy
House Calls, Multifamily Energy Efficiency Savings Program, and the Company's two
income qualified programs, Weatherization Assistance for Qualified Customers and
Weatherization Solutions for Eligible Customers, because residential lighting is a
component of these programs.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 18th day of March 2019.
LI D.N M
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of March 2019, lserved a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
upon the following named parties by the method indicated below, and addressed to the
following:
Commission Staff
Karl T. Klein
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
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berly T Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 10
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