20220616Staff 7-13 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. II2O2
-': \;_ t;..i ,,:i-'r.
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITTES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
DETERMINATION OF 2O2I DEMAND-SIDE
MANAGEMENT E)PENSES AS PRUDENTLY
INCURRED
CASE NO. IPC.E-22-08
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,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY, JULY 7,2022.
This Production Request is to be considered as 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 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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO TDAHO POWER
)
)
)
)
)
)
)
)
)
1 JUNE 16,2022
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. 7: Please provide the Northwest Energy Efficiency Alliance ("NEEA")
Annual Saving report for 2021.
REQUEST NO. 8: Please provide the cost-effectiveness workpapers and calculations
for each measure, kit, giveaway, and/or program under the Educational Distributions Programs
in202l in Excel format, with all formulas intact.
REQUEST NO. 9: The Company's202lDemand-Side Management ("DSM") Annual
Report states that for Welcome Kits in 2022, "the Educational Distributions program will
continue to count the savings and pay for the cost-effective energy savings portion of each kit,
while the remaining costs associated with the kits will be included in the ldaho Power's
Residential Energy Efficiency Education Initiative ("REEEI") efforts." DSM Annual Report at
47. Please answer the following:
a. Please provide the Company's rationale for allocating costs between the Welcome
Kits and the REEEI.
b. Please explain and provide a list of programs and measures where the Company
allocated costs between separate programs in a similar manner (as described
above) in202l and plans to implementin2022.
c. By allocating costs between the Welcome Kits and the REEEI, does the Company
consider the Welcome Kits to be cost-effective? Please explain.
d. Please explain the benefit of allocating costs to REEEI for the Welcome Kits
program.
e. What is the projected amount of costs to be included in the REEEI efforts?
f. Please provide the projected cost-effectiveness calculations for the Welcome Kits
program in2022 in Excel format, with all formulas intact. Please provide the
projected cost-effectiveness calculations with all cost directly assigned to the
Welcome Kits program. Please clearly identiff savings and costs in the response.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 16,2022
g. 1n2022, what is the total expenses for the program and what portion of those
expected expenses are expected to be cost-effective?
REQUEST NO. 10: For the Welcome Kits program, please provide the following:
a. A breakdown of the cost of each kit in 2021. Please include the cost of each bulb,
each night light, the pamphlet, shipping, packaging, and any additional cost for
the kits.
b. A breakdown of the cost or projected cost of each kit in 2022. Please include the
cost of each bulb, each night light, the pamphlet, shipping, packaging, and any
additional cost for the kits.
c. A breakdown of the forecasted cost of the Welcome Kits program in2022 (i.e.,
marketing, administration, rebates/kit contents, etc).
d. Of the customers that receive Welcome Kits in 2021, how many customers
participated in other Energy Efficiency programs in202l and2022?
e. Of the customers that received Welcome Kits in 2020, how many customers
participated in other Energy Efficiency programs in2020 and202l?
f. The cost-effectiveness results for the Welcome Kits program in202l in Excel
format, with all formulas intact. Please clearly identifr savings and costs in the
response.
REQUEST NO. 11: Please provide a breakdown of all cost for REEEI in Idaho (i.e.,
educational material, Kill A Watt Meter Program, Teacher Education, Marketing, etc).
REQUEST NO. 12: The202l DSM Annual Report states, "the Educational
Distributions effort is administered through the REEE[." DSM Annual Report at 47. Are the
costs of administering the Education Distributional programs through the REEEI assigned to the
Educational Distribution program or the REEEI? If they are assigned to the REEEI, please
explain why and identiff how much costs are assigned.
SECOND PRODUCTION REQUEST
TO TDAHO POWER J JUNE 16,2022
REQIIEST NO. 13r Please describe the Company's efforts :m2021to increase the cost-
effectiveness for the Weatherization Solutions for Eligible Customers and Weatherization
Assisffinoe for Qualified Customers progremm.
DATED atBoise,Idaho, *, l6t"dayof June 2022.
Riloy
Deputy Attorney General
i:umbcpro&e{ipoe!2.8mlc ptod rcq 2
SECOND PRODUCTION REQLJEST
TO IDAHO POWER 4 JUNE 16,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF JUNE 2022, SERVED
THE FOREGOING SECOND PRODUCTION REQIIEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-22-08, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
I5O N CAPITOL BLVD.
PO BOX 500
BOISE ID 83701-0500
E-MAIL: [e-mail]
boisec itvattomey @cityofboise.org
CONNIE ASCHENBRENNER
ZACK THOMPSON
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
wIL GEHL
ENERGY PROGRAM MGR
BOISE CITY DEPT PUBLIC WORKS
I5O N CAPITOL BLVD.
PO BOX 500
BOISE ID 83701-0500
E-MAIL: [e-mail]
Y
\
CERTIFICATE OF SERVICE