20220422IPC to Staff 1-6.pdf

SEHH.
Lisa D. Nordstrom
AnnrcomcorrY,
P.O. Bor 70 (&1707)
tzll W. ldlho 5t.
Boisc, lD E3702
LISA D. NORDSTROM
[.ead Counsel
I nordstrom@ida hoporrer.com
April22,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-22-08
ln the Matter of the Application of Idaho Power Company for a Determination
of 2021Demand-Side Management Expenses as Prudently lncurred
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to the First
Production Request of the Commission Staff to ldaho Power Company in the above-
entitled mafter.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
X*!.ff^u^-*,
LDN:sg
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ida hooower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2021 DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. IPC-E-22-08
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powef or "Company"), and in
response to the First Production Request of the Commission Staff dated April 1 ,2022,
herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISS]ON STAFF TO IDAHO POWER COMPANY - 1
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REQUEST FOR PRODUCTION NO. 1: Please provide the cost-effectiveness
workpapers and calculations for each energy efficiency and demand response program
in 2021 in Excel format, with all formulas intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the
aftachment provided for this response.
The response to this Request is sponsored by Quentin Nesbift, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 2: Please provide the revenue (excluding
interest) by class and tariff schedule for the DSM tariff rider in 2021.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The table below
contains the 2021 ldaho Power Energy Efficiency Rider funding by rate class:
2021
Rate Class Tariff Schedule Rider Funding
Residential
Commercial
lndustrial
lrrigation
Lighting
01,03,05,06
07,08, 09
19,26, 29, 30
24
15,40, 41,42
15,302,686
8,393,672
4,902,890
4,602,916
144,M7
Total $ 33,346,611
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 3: Please provide the calculation of the
interest accrued to the DSM tariff rider account.
Please see the
attachment provided for this response.
The response to this request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY .4
REQUEST FOR PRODUCTION 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. lf applicable,
please identiff how much the Company was reimbursed from NEEA for
those marketing activities.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The Company did not
opt out of any market transformation or marketing activities offered by NEEA in 2021.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ]DAHO PO\A'ER COMPANY.5
REQUEST FOR PRODUCTION NO. 5: For each date during 2021 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 FOR PRODUCTION NO. 5: Please see the
attachment provided for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 6: PIease provide the Company's DSM
labor expense and DSM full-time equivalent employees charged to the tariff rider for
2020 and2021.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: PIease see the table
below for 2020 and 2021 ldaho Power Demand-Side Management labor expense and
full-time eq u ivalent employees:
tMaximum Allowed Labor Expense calculated based on the prior year's actual average wages per FTE
per Order Nos. 34874 and 35270.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
Year
DSM
FTEs
Marimum Allowed
Labor Erpense*
Actual Labor
Expense
Labor Erpense
(Over)/Under lhe 2o/o Cap
Labor Expense
Gharged to Tadff Rider
2020 25.09 $3,303,013 $3,408,382 ($105,369)$3,303,013
2021 23.34 $3,233,933 $3,205,211 $28,722 $3,205,211
Respecttully submitted this 22ndday of April 2022.
&'-!-(r,l-l"*,
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POWER GOMPANYS RESPONSE TO T}IE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPA}ST.8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the22nd day of Apral2022,l served a true and correct
copy of ldaho Power Company's Response to the First Production Request of the
Commission Staff to ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Riley Newton
Deputy Aftomey General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
Hand Delivered
_U.S. Mail
_Overnight Mai!
_FAX
FTP SiteX Email: Rilev. [e-mail]
City of Boise
Ed Jewe!!
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
Hand Delivered
_U.S. Mail
Overnight Mail
-FAX
FTP SiteX Email: [e-mail]
Bo iseC itvAttornev@citvofbo ise. o ro
WilGehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
Hand Delivered
_U.S. Mail
Overnight Mail
-FAX
FTP SiteX Email:[e-mail]
:,U:.rh &r^J.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 9
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-22-09
IDAHO POWER COMPANY
REQUEST NO. 1
ATTACHMENT NO. 1
SEE ATTACHED SPREADSH EET
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
cAsE NO. IPC-E-22-08
IDAHO POWER COMPANY
REQUEST NO. 3
ATTACHMENT NO. 1
SEE ATTACHED SPREADSH EET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-A8
IDAHO POWER COMPANY
REQUEST NO.5
ATTACHMENT NO. 1
SEE ATTACHED SPREADSH EET