20201022IPC to Staff 1-3.pdf

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LISA D. NORDSTROT
Lcad Counsel
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October 22,2020
VIA ENCRYPTED ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Suite 2O1-A
Boise, Idaho 83714
Re Case No. IPC-E-20-33
ln the Matter of the Application of ldaho Power Company for Authority to
Revise the Energy Efficiency Rider, Tarifr Schedule 91
Dear Ms. Noriyuki:
Attached for electrcnic filing, pursuant to Order No. 34602, is ldaho Power
Company's Responses to the Commission Stfs First Prcduction Request, Nos. 1 through
3. Please handle the confidential information in accordance with the ProtectiveAgreement
executed in this matter.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
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Lisa D. Nordstrom
LDN:slb
Attachment(s)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 388€936
lnordstrom@idahoDower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORIW TO REVISE THE ENERGY
EFFICIENCY RIDER, TARIFF SCHEDULE
91.
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CASE NO. !PC-E-20-33
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Produc{ion Request of the Staff of the ldaho Public Utilities
Commission dated October 1,2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSETOTHE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF.l
REQUEST NO, t: Given the negative ending balanes shown in Attachment 1,
when does the Gompany anticipate requesting another increase to the Energy
Efficiency Rider?
RESPONSE TO REQUEST NO. ,l: ldaho Power anticipates evaluating the
appropriate Energy Efficienry Rider collection percentrage upon completion ol lhe 2021
lRP. The 2021 IRP will incorporate use of the Utility Cost Test (.UCT') for cost-
effectiveness screning in the determination of DSM savings potential. At that time, the
Gompany will determine how the then+unent funding level aligns with the long-term
forecast of energy efficiency expenses and, if needed, will make a filing to remmmend a
change to the EE Rider.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Porer Gompany.
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF.2
REQUEST NO. 2: Please explain how the forecast in IPC-E-1946, which
forecast a deficit balance starting tn 2021, differed from actual rider revenues and
expenses. Please provide any adjustments from the forecast in that case to the high
case and low case forecasts shown in Attachment 1.
RESPONSE TO REQUEST NO.2: Please see the attachment provided with this
request, which shows a comparison of the forecast from IPC-E-19-06 and actual
revenue and expenses for the period January 2019 to July 2020, as well as a
comparison to the high- and low-case forecasts from IPC-E-20-33.
Actual Januarv 2019 - July 2020 lCaho Enerov Efficiencv Rider flRide/') funding
and expenses:
o Funding $1.2 million below forecast due to sales in 2020 being below
September 2018 sales forecast.
o Labor approximately $500,000 below IPC-E-19-06 ("19-06') forecast.
r lncentives $17.2 million above 19-06 forecast.
o Other Expenses approximately $2 million below 19-06 forecast.
o Market Transformation approxirnately $300,000 below 19-06 forecast.
The savings forecast utilized in the 19-06 case for August 2020 through
December 2021 was based on energy efficiency savings identified in the Potential
Study used in the 2019 IRP with cost-effectiveness evaluated under the primary cost-
effectiveness test at the time, the Total Resource Cost test. The forecast in Case No.
IPC-E-20-33 included budget estimates for the period August 2020 through December
2020, which are developed using a mix of inputs, including prior year actuals and
proiect pipelines. For January through December 2021, the low-case energy efficiency
IDAHO POWER COMPANYS RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
savings estimate ie based on the Potential Study used in the 2019 IRP identified
savings under the Utility Cost Test ("UCT') perspec'tive, and the high-case is based on
the Potential Study to be used in the 2021 IRP identified savings under the UCT
perspec-tive.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
REOUEST NO. 3: Please provide the results, workpapers in electronic furmat
with functioning formulas, and input and ouput data with sources for the base rate
revenues forecast completed in April 2020, referenced in Attachment 2.
RESPOilSE TO REQUEST NO. 3: Please see the mnfitlential attachment
provided with this request.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
DATED at Boise, ldaho, this 22d day of October 2020.
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LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER GOMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
CERTIFICATE OF SERVICE
I HEREBY GERTIFY that on the 22d day of October 2O2O,l served a true and
correct copy of IDAHO POLVER 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:
Gommission Staff
Matt Hunter
Deputy Attomey General
11331 W. Chinden Blvd., Suite 201-A
Boise, ldaho 83714
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27s Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
710 N 6th Street
Boise, lD 83702
_ Hand Delivered
_U.S. Mail
Overnight Mail_Fru(X Email [e-mail]
_Hand Delivered
_ U.S. Mail
Overnight Mail
_FA)(X Email [e-mail]
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Ovemight Mail
_FA)(X Email [e-mail]
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Stephanie Buckner, Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF.6
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. IPC-E-20-33
IDAHO POWER COMPANY
ATTACHMENT 1 TO REQUEST NO.2
(EXCEL SPREADSHEET ALSO ATTACHED TO EMAILI
TO
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF THE GOMMISSION
STAFF