20230427IPC to Staff 1-11_Attachments.pdf

Megan Goicoechea Allen
Corporate Counsel
[e-mail]

April 26, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-10
In the Matter of the Application of Idaho Power Company for a Determination
of 2022 Demand-Side Management Expenses as Prudently Incurred

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the First
Production Request of the Commission Staff in the above matter. Please treat the
confidential documents in accordance with the Protective Agreement.

If you have any questions about the attached documents, please do not hesitate to
contact me.

Sincerely,

Megan Goicoechea Allen
MGA:cd
Enclosures
RECEIVED
2023 April 26, 3:42PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2022 DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
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CASE NO. IPC-E-23-10

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated April 5, 2023, herewith submits the following
information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 1: Please provide the monthly
interest calculations for the balance in the Demand Side Management ("DSM") tariff rider
account for 2022.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 1:
Please see the attachment provided for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
STAFF REQUEST FOR PRODUCTION NO. 2: Please provide the DSM tariff rider
revenue by month and by customer class for 2022.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 2:
The table below contains the 2022 Idaho Power Energy Efficiency Rider funding
by rate class:
2022
Rate Class Tariff Schedule Rider Funding
Residential 01, 03, 05, 06 $ 16,541,386
Commercial 07, 08, 09 $ 8,792,390
Industrial 19, 26, 29, 30 $ 5,046,836
Irrigation 24 $ 4,353,415
Lighting 15, 40, 41, 42 $ 145,957
Total $ 34,879,985

The response to this Request is sponsored by Robert Everett, Finance Team
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 3:
Please see the attachment provided for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 4:
Please see the Confidential attachment provided for this response for a summary
of all expenses associated with third-party consulting fees. Note, some of the charges
included in the summary are related to program administration, in addition to fees
associated with evaluation work. Also not included in this list are vendors whose costs
are only associated with program implementation (i.e. Small Business Direct Install
program, Multifamily program, etc.). There were no legal fees charged to the Idaho DSM
tariff rider in 2022.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 5:
The table below contains the 2022 Idaho Power Demand-Side Management labor
expense, full-time equivalent employees, and general wage adjustment percentage:
Year Idaho Rider Labor Expense FTEs General Wage Adjustments
2022 $3,381,085 24.14 2% & 6%

The response to this Request is sponsored by Robert Everett, Finance Team
Leader, Idaho Power Company and April Powell, Total Rewards Director, Idaho Power
Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 6:
Please see the Confidential attachments provided for this response.
The response to this Request is sponsored by April Powell, Total Rewards
Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 7:
Audit Services (AS) performed audits of internal controls over the Company’s DSM
expenses and processes during 2022 as part of complying with Sarbanes-Oxley (SOX)
requirements. The related SOX processes are Regulatory DSM Liability (RDSL) and
Entity-Wide Information & Communication (EWIC C02). SOX processes are tested on a
rotational basis, and all related processes were tested in 2022 (RDSL C05, RDSL C07,
EWIC Voucher #136, and EWIC Voucher #45).
The requested information is proprietary and confidential. Please see the
Confidential attachment provided for this response for the supporting workpapers. The
response to this Request is sponsored by Sonse Sutezzo, Operations Audit Manager,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 8:
The Company did not opt out of any market transformation or marketing activities
offered by NEEA in 2022.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 9:
Please see the attachment provided for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
STAFF REQUEST FOR PRODUCTION NO. 10: Please provide a detailed
overview of the activities, success metrics, quantifiable benefits, and associated costs of
the market transformation pilot project referenced in the Annual Report at 158.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 10:
Background

Idaho Power Company and Avista Corporation entered into contract with the
market transformation consultation company Brio in 2020 to test a targeted approach to
market transformation that was specific to Idaho. The effort was a recognition of the
uniqueness of the Idaho market as compared to the greater Northwest, and an attempt
to test whether a more targeted approach with local market actors would have greater
impact than a larger regional effort.
Idaho Power and Avista aligned to test the concept on ductless heat pumps as a
pilot. This came at a time when the Northwest Energy Efficiency Alliance (NEEA) was
exiting the ductless heat pump market that it had declared to be transformed. However,
that was not the case in Idaho as market barriers preventing large-scale ductless heat
pump adoption persisted.
The two-phase market transformation pilot began in April 2021 for Idaho Power
and will continues through 2023. Each phase tested a unique market actor model in
attempt to determine whether either model would be effective and scalable. The phases
will be concluded and an analysis complete by the end of 2023, at which time Idaho Power
will decide whether a similar effort would be beneficial for other energy efficient
equipment.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
Overview of the Activities
 April – May 2021 – Preparation to launch the pilot’s phase one began. This was
the contract process period between Brio and two supply chains. Market actors in
the supply chains were HVAC manufacturers, distributors, and installers.
 September 2021 – An extensive process was developed to manage generated
leads during the pilot. This process included the services of a third-party virtual
assistant.
 October 2021 – A direct mail marketing promotion was launched to 11,363
homeowners for the first of two supply chains. The promotion offered cash
incentives to encourage a homeowner to install a ductless heat pump. That
promotion was active through March 2022.
 April 2022 – A direct mail marketing promotion was launched to a different set of
11,363 homeowners for the second of two supply chains. The promotion offered
cash incentives to encourage a homeowner to install a ductless heat pump. The
promotion was active through August 2022.
 December 2022 – Launched the second contract process with a ‘Request for
Information’ to supply chain actors in preparation for the pilot’s launch of phase
two in 2023.
Success Metrics
Activity-based success metrics for the pilot were to:
 Identify prospective homeowner participants. This was completed with a result of
22,726 homeowners identified.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
 Obtain partnership with a minimum of one supply chain of manufacturer,
distributors, and installer market actors. This was successfully completed.
 Influence 600 ductless heat pump installations by the end of the two-phase Pilot in
2023 (roughly 300 for each utility). In phase one of two, the total Idaho Power
installations were 163 during 2022.
 Launch phase two at the end of 2022 to deploy in 2023. Phase two was
successfully launched in December 2022.
 Obtain learnings from phase one and incorporate them into phase two. This was
successfully completed.
 Launch marketing tactics involving direct mail, email, social media. These were
successfully completed.
Long-Term Success Metric
Ultimately the success of the market transformation efforts would be determined
by considering a baseline of what the market would have done absent the intervention
and comparing that to what was actually observed in the market.
Quantifiable Benefits
Through the pilot 163 homes transitioned to ductless heat pumps, providing lower
operating costs compared to the electric zonal heating systems they displaced.
The pilot is providing insight into what may work to generate and accelerate market
transformation across other products and services going forward. For example, the pilot
informed on the value of the quantity of qualified prospects and the actual success rate
ratio, the number of marketing tactics, the marketing tactic timing, and their frequency of

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
use. The impact of cash incentives to market transformation was also piloted. The final
report will encompass benefits such as these.
Associated Costs
Total expense paid to Brio by year is as follows:
2019 $ 53,000
2020 $ 100,148
2021 $ 261,464
2022 $ 238,450
Other Idaho Power labor and marketing expenses outside of paying Brio total
$29,228.87.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
STAFF REQUEST FOR PRODUCTION NO. 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 Efficiency programs 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 11:
a. The following table is a breakdown of the costs for each kit in 2022. The
vendor the Company contracts with does not break out material costs by bulb or
nightlight. In 2022, Idaho Power did not incur any printing costs for the flipbooks;
however, $2792 in sales tax was incurred for flipbooks purchased in 2021.
Materials $8.00
Vendor
Labor/Services $2.78
Shipping $7.72
Sales Tax (ID only) $0.48
Total per Kit $18.98

b. For the period of January 1, 2023 through June 30, 2023, the projected
breakdown of costs will be the same as specified in the table above. For the period

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
of July 1, 2023 through December 31, 2023, the following table is the breakdown
of the projected costs for each kit. The vendor does not break down material costs
by bulb or nightlight. Additionally, in 2023, Idaho Power expects to spend
approximately $50,000 for the printing of approximately 33,000 flipbooks.
Materials $5.80
Vendor
Labor/Services $2.65
Shipping $7.72
Sales Tax (ID only) $0.35
Total per Kit $16.52

c. Of the customer that received Welcome Kits in 2021, 138 customers
participated in another residential program in 2021 and 180 participated in a program in
2022. Idaho Power does not know which customers may have purchased a LED bulb or
fixture under the current retail lighting buy-down program because the buy-down program
is managed by a third-party vendor.
d. Please see the attachment provided for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

Respectfully submitted this 26th day of April 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 26th day of April 2023, I served a true and correct
copy of Idaho Power Company’s Response to the First Production Request of the
Commission Staff upon the following named parties by the method indicated below, and
addressed to the following:

Commission Staff
Claire Sharp
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Christy Davenport
Legal Administrative Assistant

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Application of Idaho Power Company for Determination of 2022 Demand-Side
Management Expenses as Prudently Incurred

Case No. IPC-E-23-10

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the attachments in response to Request Nos. 4, 6, and 7 to Idaho Power
Company’s Response to the First Production Request of the Commission Staff to Idaho
Power Company, dated April 26, 2023, may contain information that Idaho Power
Company or a third party claims is confidential as described in Idaho Code § 74-101, et
seq., and § 48-801, et seq., or is otherwise protected from public disclosure and as such
is exempt from public inspection, examination, or copying.

DATED this 26th day of April 2023.

Megan Goicoechea Allen
Counsel for Idaho Power Company