20230622Staff 12-19 to IPC.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL foi e-'=
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-23-10
DETERMINATION OF 2022 DEMAND-SIDE )MANAGEMENT EXPENSES AS )PRUDENTLY INCURRED )SECOND 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 THURSDAY,JULY 13,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 identify the name,job title,location,and
telephonenumber of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER l JUNE 22,2023
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.12:Please provide a breakdown of the Education Distributions costs
and savings by offering (i.e.,nightlight giveaways,student energy efficiencykits,welcome kits).
If applicable,please describe the factor or factors driving the $627,935 increase in education
distribution expenses between 2021 and 2022.
REQUESTNO.13:Please provide the followingfor Commercial Energy Savings Kits:
a.The contract end date for the current Commercial Energy Saving Kit vendor.
b.Of the customers that received a kit in 2021,how many customers participated in
other Commercial Energy Efficiency programs in 2021 and 2022.
c.Of the customers that received a kit in 2022,how many customers participated in
other Commercial Energy Efficiency programs in 2022 and 2023.
REQUESTNO.14:Of the 88 new construction projects in 2022,please provide a
breakdown of projects delayedby labor shortages or supply chain issues.If possible,please
identify the equipment or materials creating the supply chain delays.
REQUESTNO.15:Please explain the differences and trends between the 2021 and
2022 new construction projects that contributed to the 57%increase in savings between years.
REQUESTNO.16:Please provide a breakdown of new construction participation in
each of the TRM measures for 2021 and 2022.Please note the 2021 participation before and
after the TRM updates on June 15,2021.
REQUESTNO.17:Please provide the amount of labor expenses charged to the Idaho
DSM tariff rider for 2022.Please include the number of Full Time Equivalent positions funded
by the rider.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 22,2023
REQUESTNO.18:For promotional and marketing items in 2022,please answer the
following:
a.Please explain what items the Company claims energy efficiency savings on.
b.Please explain sources the Company used to quantifythese savings.
c.Please send copies of all advertisements the Company paid for in 2022.
Including,but not limited to,the 2022 Boise Hawks Sponsorship Package (Audit
Selection 60 in AR #2),and the Program Advertisement for the Idaho
Shakespeare Festival (Audit Selection 61 in AR #2),and any radio or
magazine/newspaper advertisements.
REQUESTNO.19:Please provide a numbered list of all custom projects completed in
2022 with a brief description of the project,the project costs,and the project savings.
DATED at Boise,Idaho,this
d4ay
of June 2023.
Claire Sharp,
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.10csät prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 3 JUNE 22,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF JUNE 2023,SERVED
THE FOREGOING SECOND 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]
ED JEWELL WIL GEHL
DEPUTY CITY ATTORNEY ENERGY PROGRAM MGR
BOISE CITY ATTORNEY'S OFFICE BOISE CITY DEPT PUBLIC WORKS
150 N CAPITOL BLVD.150 N CAPITOL BLVD.
PO BOX 500 PO BOX 500
BOISE ID 83701-0500 BOISE ID 83701-0500
E-MAIL:[e-mail] E-MAIL:wgehl cityofboise.ore
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE