20210408Staff 1-17 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
Street Address for Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2O2O DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
CASE NO. IPC.E.2I.O4
FIRST 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,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by THURSDAY, APRIL 29r2021.
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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APRIL 8,2021
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 energy efficiency and demand response program in2020 in Excel format, with all formulas
intact.
REQUEST NO. 2: Please provide the revenue (excluding interest) by class and tariff
schedule for the DSM tariff rider in2020.
REQUEST NO.3: Please provide the calculation of the interest accrued to the DSM tariff
rider account.
REQUEST NO. 4: 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
identiff how much the Company was reimbursed from NEEA for those marketing
activities.
REQUEST NO. 5: Please provide the number of Advanced Metering Infrastructure
("AMI") switches for the A/C Cool Credit and Inigation Peak Rewards programs that the Company
has in inventory.
REQUEST NO. 6: On page 3 of the 2020 DSM Annual report, the Company states that
due to COVID-I9 protocols, in-home work was suspended for the following programs: (l) Easy
Savings: Low-lncome Energy Efficiency Education; (2) Energy House Calls; (3) Home Energy
Audit Program; (4) Multifamily Energy Savings Program; and (5) Weatherization Solutions for
Eligible Customers. Please answer the following questions for each program:
a. Please provide the current status of each program.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 8,2021
b. Please provide the safety protocols and guidelines the Company is adhering to in
order to deem the programs safe to administer.
c. Once deemed safe to administer the programs, does the Company expect any
limitations and modification to the programs? If yes, please explain.
d. Once deemed safe to administer the programs, does the Company expect any issues
with ramping up the programs? If yes, please explain.
REQUEST NO. 7: On page 5l of the 2020 DSM Annual Report, the Company states that
there is a waiting list for the Energy House Calls Program. Please answer the following regarding
the Energy House Calls Program:
a. Please provide the current number of customers on the waitlist for the program.
b. How many customers were on the waitlist at the end of 2020?
c. How long does the Company anticipate it will take to serve all customers on the wait
list?
d. When the Company deems the program safe to administer again, does the Company
foresee any issues with retaining contractors to administer the program? If yes,
please explain.
e. Please provide a breakdown of expenses incurred for the program following the
suspension of the program due to COVID-19 in March of 2020.
REQUEST NO. 8: On page 6l of the 2020 DSM Annual report, the Company states that
there is a waiting list for the Home Energy Audit program. Please answer the following regarding
the Home Energy Audit Program:
a. Please provide the current number of customers on the waitlist for the program.
b. How many customers were on the waiting list at the end of 2020?
c. How long does the Company anticipate it will take to serve all customers on the wait
list?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 APRIL 8,2021
REQUEST NO. 9: On page 45 of the 2020 DSM Annual Report, the Company states that
due to Welcome Kits no longer being cost-effective as a stand-alone measure that the kits will now
be offered as a promotional item in 2021. Please answer the following questions regarding the
Welcome Kits in 2021
a. What are the Company's projected cost for implementing the program as a
promotional item?
b. What are the projected savings for the kit?
c. How will these savings be reported?
d. What programs does the Company plan to cross-promote in conjunction with the
Welcome Kits?
e. What offerings will be included in the Welcome Kits?
REQUEST NO. 10: On page 3l of the 2020 DSM Annual Report, the Company states that
communication levels exceeded 90Yo for the cycling events for the A/C Cool Credit program.
When communication failed for the cycling events please answer the following questions:
a. What communication occurs with the customers in the event of a communication
failure from a cycling event?
b. What is the Company's process for diagnosing the failed communication?
c. When a cycling event is activated and communication did not occur, are incentives
paid to the customers whose devices failed to communicate?
REQUEST NO. l1: Please answer the following regarding the Irrigation Peak Rewards
Program:
a. Please provide the average number of service points per customer in2020.
b. Please provide the number of customer opt-outs per dispatch event.
c. Please provide the total estimated amount of demand response reduction not realized
as a result of customer opt-outs per dispatch event.
d. Please provide the amount of device failures per dispatch event.
e. Please provide the total estimated amount of demand response reduction not realized
as a result of device failures per dispatch event.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 APRIL 8,2021
REQUEST NO. 12: On page 87 of the 2020 DSM Annual Report, the Company describes
a "do-it-yourself weatherization" bill insert. What was the cost of this insert and was it assigned to
the Weatheization Solutions for Eligible Customers program or another program? Is the Company
claiming any energy savings from the bill insert?
REQUEST NO. 13: On page 26 of the Goralski Direct Testimony, he states that the
Company continued marketing efforts for suspended programs. Please provide a list of these
marketing expenses and please explain why the Company continued marketing for suspended
programs.
REQUEST NO. 14: Please describe the methodology change to the Effective Load
Carrying Capacity ("ELCC") used in calculating the Value of Demand ("VOD") referenced in the
Goralski Direct Testimony on page 34. Please include workpapers for the Company's calculations,
in electronic format with links intact and formulae enabled.
REQUEST NO. 15: Please provide workpapers supporting Table 4-1, Table 4-2, and Table
4-3 on pages 13-14 in the DNV-GL's "Idaho Power Educational Distributions Impact and Process
Evaluation" report. Please include workpapers in electronic format with links intact and formulae
enabled.
REQUEST NO. 16: Please provide workpapers supporting Table 5, Table 6, and Table 7
on pages 12-15 in the Tetra Tech's "ldaho Power Company Irrigation Efficiency Rewards Program"
report. Please include workpapers in electronic format with links intact and formulae enabled.
REQUEST NO. 17: Please provide workpapers supporting Table 2-l and Table 2-2 on
page 8 in the ADM Associates, Inc's o'Rebate Advantage PY20l9 M&V Report". Please include
workpapers in electronic format with links intact and formulae enabled.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 APRIL 8,2021
DATED at Boise, Idaho, this Bt!' day of Apr il202l.
Edward
Deputy
i:umisc:prodreq/ipce2l.4ejtt pmd reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER
r(
6 APRIL 8,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF APRIL 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPAI\TY, IN CASE NO. IPC-E-21-04, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
dockets@ idahopo wer. com
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
ADAM LOWNEY
MCDOWELL RACKNER GIBSON PC
419 SW llth AVE., SUITE 4OO
PORTLAND OR 97205
E-MAIL: adam@.mrg-law.com
Y
CERTIFICATE OF SERVICE