20210616Staff 18-21 to IPC.pdf

MATT HI.]NTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
1I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
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.2L.O4
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(ldaho Power; Company) provide the following documents and information as soon as possible,
by WEDNESDAY, JUNE 30,2021.1
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
I Stuff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-03 I 8.
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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1 JUNE 16,202I
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
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. 18: Please provide the cost-effectiveness workpapers and calculations
for each measure, kit, giveaway, andlor program under the Educational Distributions Programs in
2020 in Excel format, with all formulas intact.
REQUEST NO. 19: On page 85 of the Annual Report, the Company states that
"$129,391 will be provided to the non-profit pooled fund to weatherize buildings housing non-
profit agencies that primarily serve qualified customers in ldaho." Please answer the following:
a. What is the origin of this program and who is administering it?
b. What are the qualifications for non-profits to participate in this program?
c. Please provide the current balance of the fund.
d. How does the Company determine funding amounts per year?
e. Please provide the list of these agencies expecting to receive service in202l.
f. Please provide a list of these agencies that have received this service from 2018-
2020.
g. Is the Savings to Investment Ratio tool used to determine the measures installed in
the agency buildings? If not, how are measures selected to be installed?
h. How does the Company claim the savings?
i. Has the Company conducted cost-effectiveness tests for only these buildings? If
so, please provide these results in Excel format, with formulas enabled.
j. Has the Company conducted any evaluations on these buildings? If yes, please
provide the evaluation.
REQUEST NO.20: On page 135 of the Annual Report, the Company states that "final
NEAA savings for 2020 will be released later in the year." When is the expected date for NEAA
savings to be finalized? If the savings are frnalized, please provide the report from NEEA for the
finalized savings for 2020 in Excel format, with all formulas intact.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 16,202I
REQIEST NO. 21: For promotional and marketing items in2020 please answer the
following:
a.What items does the Company claim energy efficiency savings on?
b.Mrat aro the sources ofthese savings?
DATED at Boiso,Idaho, this
i:umiso:prodrcq/ipco2 1.4mht prod req2
SECOND PROJUCTION REQUEST
TO IDAHO POWER
l6*o*ofJune zozt.
Matt Hunter
Deputy Attorney General
3 JI,JNE 16,202I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6th DAY OF JUNE 2021, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, 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
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. corn
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH ST
BOISE TD 83702
E-MAIL: [e-mail]
MARY GRANT
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
PO BOX 500
BOISE rD 83701-0500
E-MAIL : [e-mail]
Bo i seC ityAttomey @cityofboi se. org
ADAM LOWNEY
MCDOWELL RACKNER GIBSON PC
419 SW I lth AVE., SUITE 4OO
PORTLAND OR 97205
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: bottoOidahoconservation .org
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
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CERTTFICATE OF SERVICE