20230405Staff to IPC 1-11.pdf

CLAIRE SHARP ED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-23-10DETERMINATIONOF2022DEMAND-SIDE )MANAGEMENT EXPENSES AS )PRUDENTLY INCURRED )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than WEDNESDAY,APRIL 26,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 APRIL 5,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide the monthlyinterest calculations for the balance in
the Demand Side Management("DSM")tariff rider account for 2022.
REQUESTNO.2:Please provide the DSM tariff rider revenue by month and by
customer class for 2022.
REQUESTNO.3:Please provide the cost-effectiveness workpapers and calculations
for each energy efficiency and demand response program in 2022 in Excel format,with all
formulas intact.
REQUESTNO.4:Please provide a listing of all legal and consulting fees,including,
but not limited to Evaluation,Measurement and Verification ("EM&V"),charged to the Idaho
DSM tariff rider during 2022.
REQUESTNO.5:Please provide the amount of labor expense charged to the DSM
tariff rider for 2022.Please also include the number of Full Time Equivalents funded by the
rider.Please also provide the general wage adjustment percentage for non-union personnel
approved by the Compensation Committee of the Board of Directors for each year.
REQUESTNO.6:Please provide a current organizational chart by title and name
showing all Idaho Power and contract employees who charge time to the DSM rider.Please
include complete job descriptions,required qualifications,salary ranges,bonus opportunities,
and total compensation ranges,including benefits,for all employees identified in this request.
REQUESTNO.7:Please provide copies of all internal audit reports referencing any of
the Company's DSM expenses and processes for 2022.If an audit was completed and no reports
were issued,please provide the date and scope of the audit and all internal auditor workpapers.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 5,2023
REQUESTNO.8:Please provide a list of market transformation and marketing
activities offered in 2022 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;and
b.Please provide a financial comparison of those activities.If applicable,please
identify how much the Company was reimbursed from NEEA for those marketing
activities.
REQUESTNO.9:For each date during 2022 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.
REQUESTNO.10:Please provide a detailed overview of the activities,success
metrics,quantifiable benefits,and associated costs of the market transformation pilotproject
referenced in the Annual Report at 158.
REQUESTNO.11:For the Welcome Kits program,please provide the following:
a.A breakdown of the 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;
b.A breakdown of the expected 2023 Welcome Kits contents,their forecasted costs,
and all other associated costs.(i.e.,marketing,administration,rebates,etc);
c.Of the customers that receive Welcome Kits in 2021,how many customers
participated in other Energy Efficiencyprograms in 2021 and 2022;and
d.The cost-effectiveness results for the Welcome Kits program in 2022 in Excel
format,with all formulas intact.Please clearly identify savings,costs,and costs
assigned to the REEEI in the response.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 APRIL 5,2023
DATED at Boise,Idaho,this day of April 2023.
Sh
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.10csjjt prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 APRIL 5,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5th DAY OF APRIL 2023,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF
TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-10,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA D NORDSTROM ZACK THOMPSON
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE