20200417IPC to Staff 1-5.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

April 17, 2020

ELECTRONIC FILING

Diane Hanian, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-20-15
2019 Demand-Side Management Expenses – Idaho Power Company’s
Response to the First Production Request of the Commission Staff

Dear Ms. Hanian:

Attached for electronic filing is Idaho Power Company’s Response to the First
Production Request of the Commission Staff. If you have any questions about the
attached documents, please do not hesitate to contact me.

Very truly yours,

Lisa D. Nordstrom
LDN:kkt

Attachments
RECEIVED
2020 April 17,PM1:29
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

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

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CASE NO. IPC-E-20-15

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company, and in response to the First Production
Request of the Commission Staff to Idaho Power Company (“Idaho Power” or
“Company”) dated March 27, 2020, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 1: Please provide the cost-effectiveness workpapers and
calculations for each DSM program in 2019 in Excel format, with all formulas intact.
RESPONSE TO REQUEST NO. 1: Please see the attachment provided for this
response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 2: Please provide the revenue received (excluding interest) by
class and tariff schedule for the DSM tariff rider in 2019.
RESPONSE TO REQUEST NO. 2: The table below contains the 2019 Idaho
Power Energy Efficiency Rider funding by rate class:
2019
Rate Class Tariff Schedule Rider Funding
Residential 01, 03, 05, 06 $ 14,941,763
Commercial 07, 08, 09 $ 8,587,500
Industrial 19, 26, 29, 30 $ 5,045,354
Irrigation 24 $ 3,704,129
Lighting 15, 40, 41, 42 $ 145,186
Total $ 32,423,932
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
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 attachment provided for this
response. The Company calculates interest based on the average of the beginning and
ending balances for the month. Interest is recorded on a one-month lag.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 4: For each date during 2019 that 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. 4: Please see the attachment provided for this
response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
REQUEST NO. 5: Please provide the Company's DSM labor expense and DSM
full-time equivalent employees charged to the tariff rider for 2018 and 2019.
RESPONSE TO REQUEST NO. 5: The requested information is included in the
ongoing tracking of the maximum allowable labor expense, presented in the table
below.
Baseline $/FTE Maximum Amount Total Plus Annual 2% Allowed Labor in Excess
Year Labor FTEs Increase Expense of 2% Cap
2016 $122,1501
2017 $124,593
2018 $3,262,501 26.19 $127,085 $3,328,356 $ -
2019 $3,293,785 25.52 $129,627 $3,308,081 $ -

The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
Idaho Power Company.
DATED at Boise, Idaho, this 17th day of April 2020.

LISA D. NORDSTROM
Attorney for Idaho Power Company

1 2016 Baseline $/FTE established in Case No. IPC-E-17-03, Order No. 33908.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 17th day of April 2020 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
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

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Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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Industrial Customers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707

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Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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________________________________
Kimberly Towell, Executive Assistant