20200501Staff 6-12 to IPC.pdf

SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 MAY 1, 2020
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917

Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorneys for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
DETERMINATIN OF 2019 DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
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CASE NO. IPC-E-20-15

SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY

The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than FRIDAY,
MAY 22, 2020.
This Production Request is to be considered as continuing, and Idaho Power 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
RECEIVED
2020 May 1,PM12:40
IDAHO PUBLIC
UTILITIES COMMISSION

SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 MAY 1, 2020
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.

REQUEST NO. 6: Please provide a list of market transformation and marketing
activities offered by NEEA that the Company has opted out of for all or part of its service
territory.
a. For those activities, please provide a side-by-side comparison of NEEA marketing
activities and those conducted by the Company.
b. Please provide a financial comparison of those activities. If applicable, please
identify how much the Company was reimbursed from NEEA for those marketing
activities.

REQUEST NO. 7: Please provide copies of all print, web, television, and radio ads,
and/or content used to market the Company’s DSM programs in Idaho.

REQUEST NO. 8: Please provide the amounts budgeted and spent on DSM marketing
in 2019. Please identify which program each expenditure was billed to and provide
documentation to support the amount spent, including copies of invoices and proof of payment.

REQUEST NO. 9: Please provide the 2019 website analytics for each DSM program or
measure website and include the following information—to the extent such analytics are
available to the Company.
a. Number of page views;
b. Number of unique visitors;
c. Session duration;
d. Source of incoming traffic;
e. Interactions while on the website (For example, are visitors using the program
applications or looking at qualified product lists.); and

SECOND PRODUCTION REQUEST
TO IDAHO POWER 3 MAY 1, 2020
f. Exit pages (Are users exiting to other Idaho Power pages or returning back to
search engines or social media.)

REQUEST NO. 10: Please provide the number of Advanced Metering Infrastructure
(“AMI”) switches for the A/C Cool Credit and Irrigation Peak Rewards programs that the
company has in inventory. Additionally, has the Company purchased any AMI switches for
these programs since December 31, 2018?

REQUEST NO. 11: Please provide a copy of the Technical Resource Manual that was
used for the Company’s 2019 DSM report.

REQUEST NO. 12: Please provide the following for the Weatherization Assistance for
Qualified Customers program:
a. The incentives or expenses paid for each measure type;
b. The potential savings for each measure in the energy audit tool, such as EA5 or
EA6, used for cost-effectiveness screenings; and
c. The cost effectiveness analysis, based on consumption data, showing the Annual
Gross Savings by measure type.

DATED at Boise, Idaho, this 1st day of May 2020.

_________________________________
Dayn Hardie
Deputy Attorney General

i:umisc:prodreq/ipce20.15dhbl prod req 2
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 1st DAY OF MAY 2020, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-15, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:

LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]

CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]

/s/ Reyna Quintero __
SECRETARY