20230825Staff 20-25 to IPC.pdf

CLAIRE SHARP
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-23-10
DETERMINATION OF 2022 DEMAND-SIDE )MANAGEMENT EXPENSES AS )PRUDENTLY INCURRED )THIRD 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 Attorney General,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than FRIDAY,SEPTEMBER 15,2023.
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
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 1 AUGUST 25,2023
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.20:In response to Production Request No.18,the Company provided
copies of advertisements it paid for during 2022.For the advertisements labeled
"2022CIAirportAd"and "2022CIAirportAd2",please provide total costs,including production
costs and placement costs,and the accounts to which they were booked.Please provide the basis
for any allocation between accounts and service jurisdictions.
REQUESTNO.21:For each recommendation provided by the NEEA evaluation"
Evaluation")please describe the Company's requested action,NEEA's corresponding response
(i.e.,accepted,contingent,etc),and if the action will be implemented in the 2025-2029 funding
cycle.
a.For any recommendations not accepted by NEEA,please explain why it was not
accepted.
REQUESTNO.22:Please explain if there are any incremental costs associated with
implementation of the NEEA Evaluation recommendations.
a.If yes,please provide the cost associated with each recommendation and explain
how those costs will be passed on to NEEA participants or the Company.
REQUESTNO.23:Please describe any changes made to the NEEA business plan in
response to the Evaluation recommendations.
REQUESTNO.24:Please provide any communication between the Company and
NEEA related to the Evaluation or implementation of Evaluation recommendations.
REQUESTNO.25:For NEEA's 2025-2029 Business Cycle,please provide the
expected cost for the Company and how that fundingamount was determined.Additionally,
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 25,2023
please identify any cost associated with ad hoc requests (i.e.,cost to implement
recommendations or measures for Idaho Power specifically)and provide a breakdown of costs
associated with the Business Plan to the greatest extent possible (i.e.,administration,codes,
standard changes,measure support,etc.).
DATED at Boise,Idaho,this day of August 2023.
Sh ,
Deputy Attorney General
i:umisc:prodreq/ipce23.10csjjt prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 3 AUGUST 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF AUGUST 2023,
SERVED THE FOREGOING THIRD 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] zthompson idahopower.com
[e-mail]
dockets idahopower.com
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 citvofboise.org
eiewell citvofboise.org
dearly citvofboise.org
SECRETARY
CERTIFICATE OF SERVICE