20230713IPC to Staff 12-19.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

July 13, 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 Second
Production Request of the Commission Staff in the above matter. A confidential
attachment will be sent via encrypted email to the parties who have signed the Protective
Agreement. Please treat the confidential documents in accordance with the Protective
Agreement.

Due to the voluminous nature of non-confidential information provided in response to
data requests in this case, the Company is posting the attachments to these requests to
the secure FTP site to allow parties to view the requested information remotely. The login
information for the FTP site will be provided to all parties, through email.

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

Sincerely,

Megan Goicoechea Allen
MGA:cd
Enclosures
RECEIVED
Thursday, July 13, 2023 2:09:12 PM
IDAHO PUBLIC
UTILITIES COMMISSION

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 attachment in response to Request No. 19 to Idaho Power Company’s
Response to the Second Production Request of the Commission Staff to Idaho Power
Company, dated July 13, 2023, may contain information that Idaho Power Company or a
third party claims constitutes trade secrets and/or confidential business records of a
private enterprise required by law to be submitted to or inspected by a public agency 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 13th day of July 2023.

Megan Goicoechea Allen
Counsel for Idaho Power Company

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated June 22, 2023, herewith submits the following
information:

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 12: Please provide a breakdown of
the Education Distributions costs and savings by offering (i.e., nightlight giveaways,
student energy efficiency kits, welcome kits). If applicable, please describe the factor or
factors driving the $627,935 increase in education distribution expenses between 2021
and 2022.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 12:
The following table is a breakdown of the Educational Distribution costs and
kilowatt-hour (“kWh”) savings by offering for 2022.

Offering Savings Expenses
Admin N/A $15,516
Nightlights 71,040 kWh $9,683
Student Energy Efficiency Kits 2,349,312 kWh $601,074
Welcome Kits 1,321,602 kWh $460,540
Total 3,741,954 kWh $1,086,813

The difference in the Educational Distribution costs between 2021 and 2022 are
largely due to the timing of when expenses were incurred as well as increased
participation in the program.
The expenses associated with Student Energy Efficiency Kit (“SEEK”) increased
by approximately $434,500 between program years 2021 and 2022. For school year
2021-2022, Idaho Power selected a new kit vendor, and it took additional time to develop
the new curriculum, materials, communications with the teachers, and marketing
materials for the offering. This resulted in the offering for the 2021-2022 school year
beginning 6 to 8 weeks later than usual and nearly 86 percent of the total charges for the
2021-2022 school year being incurred in the 2022 budget year since many activities were
pushed to the spring of 2022. Also, the 2021-2022 school year was a school year with

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
increased classroom activities coming out of the COVID-19 pandemic which resulted in
increased SEEK participation. With the 2022-2023 school year, teachers were more
familiar with the new vendor and processes and kits began shipping early in September
2022. This resulted in 60 percent of the total expenses for the 2022-2023 school year
falling into the 2022 budget year, which is more in line with previous years under the old
vendor.
The expenses associated with the Welcome Kits increased by approximately
$170,400 between program years 2021 and 2022. In 2022, the Welcome Kits were
modified to include four 1100- lumen light-emitting diode (“LED”) bulbs and two LED
nightlights. This was a change from the previous kit configuration of four 800-lumen LED
bulbs and one LED nightlight. In August and November 2021, Idaho Power presented the
Energy Efficiency Advisory Group (“EEAG”) four different kit configuration options. The
priorities considered were maximizing customer experience, minimizing annual costs,
maximizing savings, and maximizing cost-effectiveness. Due to feedback from EEAG and
the higher savings associated with the 1100-lumen bulb (4.8 kWh) versus the 800-lumen
bulb (0.85 kWh), the Welcome Kits were modified for 2022. With higher savings
associated with each kit, more dollars were assigned to the Educational Distribution
program while the remaining dollars were assigned to the Residential Energy Efficiency
Education Initiative.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 13: Please provide the following for
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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 13:
a. The contract end date for the Commercial Energy Saving Kit vendor was June 30,
2023.
b. Of the nine hundred and six (906) customers who received a kit in 2021, forty-nine
(49) participated in another Commercial Energy Efficiency program in 2021 or
2022.
c. Of the three hundred and thirty-four (334) customers who received a kit in 2022,
eleven (11) participated in another Commercial Energy Efficiency program in 2022
or year-to-date 2023.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
STAFF REQUEST FOR PRODUCTION NO. 14: Of the 88 new construction
projects in 2022, please provide a breakdown of projects delayed by labor shortages or
supply chain issues. If possible, please identify the equipment or materials creating the
supply chain delays.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 14:
Architects, engineers, construction managers, and owners often discussed in
general their experience with labor shortages and supply chain delays, however the New
Construction program does not track the reasons for project delays. Projects that have
significant delays are likely not represented in the eighty-eight (88) projects paid in 2022
due to the long design and construction phases that can encompass multiple years.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
STAFF REQUEST FOR PRODUCTION NO. 15: Please explain the differences
and trends between the 2021 and 2022 new construction projects that contributed to the
57 percent increase in savings between years.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 15:
New construction projects have long design and construction phases that can
encompass multiple years from initial design to final construction completion. Total
savings reported for new construction projects can vary significantly year over year
because savings are only reported once the project is completed and the final application
and supporting documentation are received, reviewed, approved, and the incentive is
paid. One or two large projects completed in a specific reporting year can result in a much
higher savings amount that particular year compared to another year when there are
fewer large projects completed. The five largest projects in the 2022 reporting year had a
total savings amount of 20,895 megawatt-hours (“MWh”). The five largest projects in the
2021 reporting year had a savings total of 10,138 MWh, which is about half the amount
compared to 2022. It is typical to have some reporting years that are larger than others
due to the long design and construction phases of new construction projects.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
. STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 16:
The table below shows a breakdown of the new construction participation in each
of the TRM measures for 2021 and 2022. Additionally, new construction projects may
have long construction timelines and take years to complete. Each project must submit a
preliminary application prior to project completion and a final payment application after
project completion. The counts below illustrate the number of measures that qualified for
an incentive under the current program design launched on June 15, 2021 and the
number of measures under the previous program design.
Program Year 2021 Program Year 2022
Measure
Pre App
Submitted
before June
15, 2021
Pre App
Submitted
after June
15, 2021
2021
Total
Pre App
Submitted
before
June 15,
2021
Pre App
Submitted
after June
15, 2021
2022
Total
Air Compressor Variable
Speed Drives 15 0 15 2 11 13
Air Side Economizer 3 0 3 7 2 9
Dairy Vacuum Pump
Variable Speed Drive 1 0 1 0 1 1
Daylight Photo Controls 1 0 1 3 0 3
Direct Evaporative
Coolers 1 0 1 0 0 0
Efficient AC & HP Units 26 2 28 6 4 10
Efficient Chillers 3 0 3 0 1 1
Efficient Condensers 0 0 0 0 1 1
Efficient Laundry
Machines 0 0 0 1 0 1
Efficient VRF Units 3 0 3 3 1 4
Energy Management
Control Systems 5 0 5 4 1 5
Energy Star Commercial
Dishwasher 1 0 1 1 1
ENERGY STAR Ice
Machine >=200 lbs/day 0 0 0 0 1 1

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8

Continued Program Year 2021 Program Year 2022
Measure
Pre App
Submitted
before June
15, 2021
Pre App
Submitted
after June
15, 2021
2021
Total
Pre App
Submitted
before
June 15,
2021
Pre App
Submitted
after June
15, 2021
2022
Total
Energy Star U/C
Dishwasher 1 0 1 0 0 0
Evaporative Pre-coolers
on air cooled condensers
(refrig) 0 0 0 0 1 1
Exterior Light Load
Reduction 38 2 40 21 15 36
High Efficiency Battery
Charger 0 0 0 0 1 1
High Efficiency Exit Signs 30 3 33 14 13 27
High Volume Low Speed
Fan 4 0 4 0 1 1
HVAC Variable Speed
Drives 5 0 5 5 1 6
Interior Light Load
Reduction 61 8 69 30 25 55
Kitchen Hood VSD 2 0 2 3 0 3
Low Pressure Drop Filter 0 0 0 2 2 4
Network Lighting Controls
(Interior) 0 0 0 0 3 3
No Loss Condensate
Drain 4 0 4 1 5 6
Occupancy Sensors 12 1 13 5 6 11
Onion/Potato Shed VSD 4 3 7 3 9 12
Reflective Roof Treatment 9 0 9 12 6 18
Refrigerated Compressed
Air Dryer 5 0 5 2 9 11
Refrigerator Strip Curtains 1 0 1 0 0 0
Grand Total 235 19 254 125 120 245

The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 17:
Please see the table below for the 2022 Idaho Power demand-side management
(“DSM”) labor expenses and full-time equivalent employees:

The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
Year DSM
FTEs
Maximum
Allowed Labor
Expense
Actual Labor
Expense
Labor Expense
(Over)/Under the 2
percent Cap
Labor Expense
Charged to Tariff
Rider
2022 24.14 $3,831,085 $3,392,286 ($11,201) $3,381,085

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
STAFF REQUEST FOR PRODUCTION NO. 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 quantify these 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 18:
a. Idaho Power does not claim energy savings on promotional and marketing
items. Giveaway items for which the Company does claim energy savings fall under the
Educational Distributions program. These giveaway items include LED night lights,
Welcome Kits, and Student Energy Efficiency Kits.
b. As described on pages 44-45 of the Demand-Side Management 2022 Annual
Report, Idaho Power uses a variety of savings sources for the giveaway items such as
the Regional Technical Forum, third party evaluators, and calculated savings based on
survey information. The specific source of savings information can be found on page 16
of Supplement 1: Cost-Effectiveness.
c. Please see the attachments provided for this response for copies of all
advertisements, along with copies of the Boise Hawks Sponsorship ads and the Idaho
Shakespeare Festival print ad. Due to the voluminous nature of the request, the
advertisements/attachments have been provided through the Company’s FTP site.
Please note there are numerous copies of print and digital ads as many different

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
sizes are needed for various publications.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
STAFF REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 19:
Please see the Confidential 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 13th day of July 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 13th day of July 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Second 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
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Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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Overnight Mail
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[e-mail]
[e-mail]

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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U.S. Mail
Overnight Mail
FAX
FTP Site
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Christy Davenport
Legal Administrative Assistant