20220616Staff 1-13 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
I133I 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
AUTHORITY TO MODIFY SCIIEDULE 79-
WEATHERIZATION ASSISTANCE FOR
QUALIFIED CUSTOMERS
CASE NO.IPC.E.22-15
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, Dayn Hardie, Deputy Attorney General, request that Idaho Power Company ("Company"
or "Idaho Power") provide the following documents and information as soon as possible, or by
THURSDAY, JULY 7,2022.
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
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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JUNE 16,2022
and if different the witness who can sponsor the answer at hearing if need be. See 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. 1: Please describe how customer eligibility is evaluated and determined
for the Weatherization Assistance for Qualifred Customers ("WAQC").
a. Please clarify what federal and state guidelines are used by local Community Action
Partnership ("CAP") agencies to determine the eligibility of a customer. Please
provide a copy of these guidelines.
b. Please explain what customers are required to provide to CAP agencies to verifr low-
income eligibility.
c. Please describe records kept by the company for customer eligibility.
REQUEST NO.2: Regarding Customer Eligibility, Attachment No. 2 of the Application
states, "Qualified as Low Income as defined by the federal poverty level defined in the current
Idaho Weatherization Operations Manual ("IWOM") guidelines or previously qualified for the
WAQC program." Please explain if customers who previously qualified for the WAQC with
incomes that now exceed the current low-income criteria will still qualifr.
REQUEST NO.3: Please provide a copy of the current IWOM referenced in
Attachment No. 2 of the Application.
REQUEST NO. 4: Please describe how the re-weatherization program and its cost-
effectiveness calculations will be reported.
a. Please explain the metrics that will be included in Company's Demand-Side
Management Annual Report.
b. Will the reporting for the re-weatherization program be separated from the WAQC
reporting? Please explain.
c. Will the Company separate the cost-effectiveness calculations for the re-
weatherization program from the WAQC program? Please explain.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 16,2022
d. Will the savings and cost-effectiveness calculations be included in the Company's
energy efficiency portfolio savings and cost-effective calculations? Please explain.
REQUEST NO. 5: Please respond to the following regarding HVAC replacement
optons
a. Please explain which HVAC replacement options will be available as part of the
proposed re-weatherization program. If available, please provide a list of the HVAC
replacement options available for the program with the estimated cost of materials and
labor.
b. If multiple HVAC replacement options are available, please include the factors used
in the decision (i.e. cost, impact based on cost-effectiveness, etc.) and describe how
the Company will determine the best available option.
REQUEST NO. 6: Regarding WAQC carryover funds is the Company proposing to use
only the $870,985 currently available to fund the re-weatherization program or does it also
propose to include future WAQC carryover funds from the WAQC program for future years'
re-weatherization?
REQUEST NO. 7: Page 8 of the Application states, "Some of the requirements in
Attachment2 may be subject to change once re-weatherization projects begin and more
information is gathered through stakeholder collaboration and feedback." Please describe how
the Company will propose these potential changes and how the Commission will be informed of
potential changes to the program. Additionally, please identiff any items in Attachment 2 that
are not subject to change, i.e., "projects available until carryover funds run out or until the CAP
Agency contract ends in 2025."
REQUEST NO. 8: Please describe inspection records that are maintained by the
Company for the WAQC program.
REQUEST NO. 9: Does the Company receive copies ofjob completion forms, listed in
Attachment2 of the Application, from the CAP agency? If yes, please provide examples. If the
Company does not receive the forms, please explain why not.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY J JUNE 16,2022
REQUEST NO. 10: Page 8 of the Application states that, "Idaho Power estimates that
there are approximately 1,000 homes eligible for re-weatherization." How does the Company
plan to inform these customers that they are eligible for the re-weatherization program?
REQUEST NO. 11: Page 4 of the Application states "for the second verification
method, Idaho Power contracts with two companies that employ building performance specialists
to veriff the installed measures." What records are these specialists providing to the Company?
Please provide samples of the reports the specialists gave to the Company confirming the WAQC
measures were installed correctly over the past five years. Please provide a list of items the
specialists checked to veriff the installed measures in the WAQC.
REQUEST NO. 12: In Attachment2, under Re-Weatherization Funding, it states
"Production job costs will be limited to a $9,000 maximum annual job average plus the
administrative fee of l0o/o of the production cost per job." Please clarifu whether the jobs are
capped at $9,000 or ifthe average annualjob costs are capped at $9,000? Ifthe average cost is
capped, please explain what processes the Company will employ to ensure the job average does
not exceed $9,000.
REQUEST NO. 13: Please explain how the Company determined the $9,000 arunual job
average. Please provide any supporting documents or calculations used to determine the amount.
DATED at Boise,Idaho, this / 6L day of June 2022.
Deputy General
i :umisc:prodreq/ipce22. I 5dhlc prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JUNE 16,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I6TH DAY OF JUNE 2022, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TrrE COMIIrSSrON STAFF
TO IDAITO POWER COMPANIY, IN CASE NO. IPC-E-22-15, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : [e-mail]
[e-mail]
CONNIE ASCHENBRENNER
ZACK THOMPSON
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : saschenbrenner@ idahopower.com
zthompson@idahopower. com
SECRET
CERTIFICATE OF SERVICE