20190730IPC to Staff 28-30.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
RECEIVED
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July 30, 2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-19-11
2018 Demand-Side Management Expenses - ldaho Power Company's
Response to the Second Production Request of the Commission Staff
Enclosed for filing in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the Second Production Request of the Commission
Staff.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to Staffs production requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
2
Lisa D
LDN:kkt
Enclosures
P.O. 8ox 70 (83707)
1221 W. ldaho St.
Boise, lD 83702
Dear Ms. Hanian:
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 h opower. com
RECEIVED
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2018 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED
CASE NO. rPC-E-19-11
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
Company dated July 17,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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REQUEST NO. 28: Please provide the RFP and any associated materials
including but not limited to, announcements, invitations to apply, program timeline, etc., for
the Small Business Direct lnstall Program.
RESPONSE TO REQUEST NO. 28: Please see attachments on the enclosed non-
confidential and confidential CDs. Out of an abundance of caution, ldaho Power has
marked all of the communication with potential vendors as confidential because certain
emails may contain proprietary information the vendor may consider confidential, or
communications include vendor-specific login details to the RFP portal.
As a point of clarification, ldaho Power began internal evaluation and scoping of the
Small Business Direct lnstall Program at the end of 2018, and all of the RFP process
activity occurred in 2019.
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 file folders have been labeled confidential; all files provided on the
confidential disk 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.
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 SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 29: Please provide the letters and tech sheets mentioned in the
response to Request No. 7, which were sent to wholesalers and plumbers in June
regarding the heat pump water heater incentive. lf different, please send the letter and tech
sheets sent to retailers as well.
RESPONSE TO REQUEST NO. 29: ln June 2018, 267 letters were sent to
wholesalers and plumbers ("professionals"). ln July 2018, 100 letters were sent to retailers.
The tech sheet sent with the letters was identical to both professionals and retailers.
Please see the attachments on the enclosed non-confidential CD.
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 SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 30: Page 154 of the 2018 DSM Annual Report states that 87% of
NEEA market transformation savings come from codes and standards.
a) Please identify the specific federal and state codes and standards that
produced those savings.
b) Please describe in as much detail as possible the specific NEEA activities
that produced those savings.
c) Please provide the most recent NEEA evaluations of its codes and standards
activities.
RESPONSE TO REQUEST NO. 30: ln ldaho Power's Demand-Side Management
2018 Annual Report, ldaho Power reported that 87 percent of the Northwest Energy
Efficiency Alliance ("NEEA') market transformation saving came from codes and
standards, which is based on NEEA's preliminary report.l When the Company received
the final NEEA 2018 savings report on March 28, 2019, it showed savings from codes and
standards to be 83 percent of NEEA savings. Please note, this response is based on
NEEA's final 2018 savings report and the attachments were prepared by NEEA staff.
30 a&b - Please see the attachment on the enclosed non-confidential CD titled
"Attachment - Response to Staffs Request No. 20-A&B."
30c - Please see the attachments on the enclosed non-confidential CD included in
the folder "Attachments - Response to Staff's Request No. 30-C."
The response to this Request is sponsored by Pete Pengilly, Customer Research &
Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 30th day of July 2019.
LISA D. NORD OM
Attorney for ldaho Power Company
1 Footnote 3, page '176 of ldaho Power's Demand-Side Management 2018 Annual Report.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of July 2019 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash i n gton (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
ldaho Conseruation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
X Hand Delivered_U.S. Mail
_Overnight Mail_FAXX Email matt.hunte uc.idaho.gov
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
Kim T utive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5