20190517Staff 1-27 to IPC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
TDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 10655
RECEIVED
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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 IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2018 DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
CASE NO. IPC.E-19.11
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Idaho Power; Company) provide the following documents and information as soon as possible,
by FRIDAY, JUNE 7,2019.
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
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. Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 MAY 17,2019
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 the cost-effectiveness workpapers and calculations
for each demand-side management DSM program in2018 in Excel format, with all formulas
intact.
REQUEST NO. 2: Please provide all electronic workpapers, with links intact and
formulae enabled, supporting the tables on pages l4 through 57 of the Company's DSM 2018
Annual Report, Supplement 1.
REQUEST NO.3: Please provide the revenue received (excluding interest) by class and
tariff schedule for the DSM tariff rider in 20 I 8.
REQUEST NO. 4: Please provide the calculation of the interest accrued to the DSM
tariff rider account.
REQUEST NO. 5: Please explain why the Company's estimated kWh savings decreased
between 2017 and2018 (2018 DSM Annual Report, page 10).
REQUEST NO. 6: Please provide the hourly rate billed and total amount paid to
Thomas Eckman for his testimony in this current case. Provide documentation for any contracts,
payments, and the accounts to which payments were charged.
R-EQUEST NO. 7: Please provide a list of market transformation and marketing
activities offered by NEEA that Idaho Power has opted out of for all or part of its service
territory.
a. For these activities, please provide a side-by-side comparison of NEEA marketing
activities and those conducted by the Company.
FIRST PRODUCTION REQUE,ST
TO IDAHO POWER 2 MAY 17,2019
b. Please provide financial comparisons of these activities. Where applicable, please
identify whether, and how much funding was refunded from NEEA to the Company
to conduct these marketing activities.
REQUEST NO. 8: Please provide copies of all print, web, television, and radio ads
and/or content used to market the Company's energy efficiency programs in Idaho. In addition,
please include the Energy Efhciency Winter Guide mentioned on page 160 of the DSM 201 8
Annual Report. Please provide any ads or content created for social media platforms that differ
from materials supplied above.
REQUEST NO. 9: Please provide the amount budgeted and spent for the DSM-related
marketing campaign for 2018. Please provide documentation supporting the amount spent,
including invoice copies and proof of payment.
REQUEST NO. 10: Please provide copies of all bill inserts referencing energy
efficiency in Idaho that were sent out with customer bills during 2018.
REQUEST NO. 11: Please provide 2018 website analytics information for each DSM
program or measure website and include the following information, if available:
a. Number of visitors (page views)
b. Number of unique visitors
c. Session duration
d. Source of incoming traffic
e. Interactions while on site (For example, on your Heat Pump Water Heater
website, are they downloading the incentive application or looking at the qualified
products list?)
f. Exit pages (Are users exiting to other Idaho Power pages or returning back to
search engines?)
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 77,2019aJ
REQUEST NO. 12: On page 119 of the DSM 2018 Annual Report, the Company states
that the evaluator recommended changing program design of the Commercial and Industrial
(C&D Energy Efficiency Program so that the program intervened at a different level in the
market. The Company explained that an upstream or midstream model "is an entirely different
program approach that would be considered if the current approach proved inadequate."
a. Please provide the citation for this recommendation.
b. Please explain how the Company defines "inadequate" in this context.
c. Please explain what prevents Idaho Power from developing parallel programs for
C&I with interventions at the upstream (manufacturer) or midstream (distributor
or installer level).
REQUEST NO. 13: Were the savings values for the Home Energy Reports weather-
normalized? Please explain.
REQUEST NO. 14: For the Green Motors Initiative described on page 145 of the
Company's DSM 2018 Annual Report, please provide the following information:
a. Workpapers and calculations showing how the kWh savings values inTable 24
were determined.
b. Criteria used to determine whether or not a particular motor qualifies for an
incentive under the Green Motors Initiative.
c. Workpapers and calculations showing how the Annual Gross Energy Savings,
NPV DSM Avoided Costs, and Gross Incremental Participant costs on page 39 of
the Company's DSM 2018 Annual Report, Supplement I were determined.
REQUEST NO. 15: For the Energy Savings Kits program, please explain why the
deemed savings per lamp is identical for 9 watt and 6 watt LED Light Bulbs (ldaho Power
Energy-Saving Kit Program Summary Report, Appendix A, page 24).
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 17,20194
REQUEST NO. 17: On page 1 of its Shade Tree Evaluation Report, DNV GL reports a
mortality rate of 360/o at 3-5 years since planting. What steps is the Company taking to improve
the survival rate of trees planted under the Shade Tree Project?
REQUEST NO. 18: On page 2 of its Shade Tree Evaluation Report, DNV-GL provides
a summary of non-electric impacts (Table 2). Were any of these values used in the Company's
Cost and Benefit calculations? If so, please provide workpapers, with links and formulae
enabled, showing how these values were used.
REQUEST NO. 19: The Company reported a cumulative energy (kWh) savings of
1,560,005 kWh in its 2018 DSM Annual Report, Supplement 1, page 30. Please answer the
following:
a. Please explain how this value was determined and provide supporting workpapers
with all links and formulae enabled.
b. Was the 360/o mortality rate reported by DNV GL used in the Company's
cumulative kWh savings?
REQUEST NO. 20: Table l-l (page 1-2) of Tetra Tech's 2017 Custom Projects Impact
Evaluation Report shows thatreahzation rates for custom pumps and compressed air measures
were 155.2o/o and 66.80 , respectively. What steps is Idaho Power taking to improve the
methods used to estimate the energy savings realized through these programs?
REQUEST NO. 21: Table 3-13 (page 3-9) of Tetra Tech's 2017 Custom Projects Impact
Evaluation Report shows thatrealization rates for projects 1690 and 1699 were l55.3Yo and
36.40 , respectively. What steps is Idaho Power taking to improve the methods used to estimate
energy savings realized through its Custom Streamlined Process program?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 MAY 17,2019
REQUEST NO. 16: On page 17 of the Idaho Power Energy-Saving Kit Program
Summary Report, the Company states that 50Yo of all respondents reported installing all 9 LED
light bulbs. Please explain how this compares to the installation rate used to develop the 8.20
kWh Regional Technical Forum (RTF) value shown on Appendix A, page 24.
REQUEST NO.22: Section 1.3 (pages 1-l through 1-4) of Tetra Tech's 2017 Custom
Projects Impact Evaluation Report makes a number of impact recommendations, including:
a. Consider including post-verification customer follow-up for control-based
projects.
b. Continue close communications with Wastewater Cohort contacts.
c. Use RTF method for New Construction Baseline
d. Use rated capacity and wattage for equipment.
e. Consider requiring a pump curve submission for pumping projects.
Please explain what, if any, steps Idaho Power is taking to implement each of the above listed
recommendations. For any of these recommendations that the Company is not implementing,
please explain why the Company is not implementing them.
REQUEST NO. 23: Does Idaho Power include realization rates reported by its
evaluators when determining benefits of its individual programs? If so, please explain how these
are applied. If not, please explain why these are not used.
REQUEST NO. 24: Does Idaho Power use realization rates reported by its evaluators to
identiff improvement opportunities in its programs? If so, please explain how realization rates
are used. [f not, please explain why realization rates are not used to identify improvement
opportunities.
REQUEST NO. 25: For each date during 2018 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.
REQUEST NO. 26: Please provide the number of switches for the A/C Cool Credit
Program that the Company currently has in inventory. Additionally, please provide the amount
that is included in the Company's Energy Efficiency Tariff Rider balance as of December 31,
2018 for the A/C Cool Credit switches.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 MAY 17,2019
REQUEST NO.27: Please provide a copy of the Idaho Power Technical Resource
Manual that was used for the Company's DSM 2018 Annual Report.
Dated at Boise, Idaho, this
i/utility/umisc/production requests/ipcel9.l lmhck prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER
i--7)\
{ + day of May 2019
F,N Matt Hunter
Deputy Attomey General
7 MAY 17,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF MAY 2079,
SERVED THE FOREGOING FIRST PRODUCTION RE,QUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-Ig-I1, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@i dahopower.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail:
ABIGAIL R GERMAINE
BOISE CITY ATTORNEY'S OFFICE
PO BOX 500
BOrSE rD 83701-0s00
E-MAIL: agermaine@,cityofboise.org
,[' '/ -,SECRETARY
CERTIFICATE OF SERVICE