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Home My WebLink About20061124Staff to PacifiCorp 1-7.pdfDONALD L. HOWELL, II DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 3366 CEI lro . ~- ' ZOOn NaV 22 Pi'1 2: ! D/~-j q)~~)ii~t I;~" .' ! Ul1U11ES 0urv'did;:;uIO." Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF PACIFICORP DBA ROCKY MOUNTAIN POWER TO DETERMINE THE APPROPRIATE FUNDING STRUCTURE OF ITS SCHEDULE 21 (LOW INCOME WEATHERIZATION PROGRAM). CASE NO. PAC-06- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO ACIFICORP DBA ROCKY MOUNTAIN POWER The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Donald L. Howell, II, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power (Company; Rocky Mountain Power) provide the following documents and information as soon as possible, but no later than THURSDAY, DECEMBER 7,2006. This Production Request is to be considered as continuing, and PacifiCorp dba Rocky Mountain Power 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 produced. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. PRODUCTION REQUEST TO ACIFICORP DBA ROCKY MOUNTAIN NOVEMBER 22, 2006 REQUEST NO.1: Please identify the total average energy savings estimated from all measures eligible for Rocky Mountain funding per unit weatherized in the area served by Rocky Mountain Power that were weatherized in calendar year 2005 and also for the most recently available information for 2006. (Please use the same time period for all responses requesting information for 2006.) Please break this information down by single and multi-family units. REQUEST NO.2: How does the Company calculate energy savings for a house where energy efficiency measures not covered under Schedule 21 , but approved by a DOE energy audit, are installed under DOE guidelines? Are the energy savings associated with measures not covered under Schedule 21 excluded from projected total energy savings? REQUEST NO.3: Please explain the Company s decision to not include under Schedule 21 all energy efficient measures recommended by a DOE approved energy audit for an electrically heated home. What specific objection does the Company have to covering expenditures for furnace tune-up, repair, or replacement where the Savings to Investment Ratio (SIR) is :2: 1.0; or incidental home repairs that support weatherization measures, e., minor repair of roofs, walls or ceilings, when the overall measure SIR:2: 1.0? REQUEST NO.4: Schedule 21 covers 100% of cost of eligible energy conservation measures after participating agencies exhaust federal weatherization funds. Please explain how the Company determines when federal funds are exhausted. Does the fact that DOE weatherization funds are allocated based on the poverty population of each county playa role in determining when federal funds are exhausted? REQUEST NO.5: Please provide descriptions of the relevant terms and conditions of any low income weatherization efforts operated or funded, in whole or in part, by Rocky Mountain Power or Pacific Power in Utah, Oregon and Washington. In particular, what measures are eligible for utility funding and what are the limitations, if any, on the use of utility funds for completing measures that are eligible for funding through the Department of Energy? PRODUCTION REQUEST TO ACIFICORP DBA ROCKY MOUNTAIN NOVEMBER 22, 2006 REQUEST NO.6: Please provide copies of any analyses or studies of energy savings or cost effectiveness that have been completed within the past three years for any low income weatherization programs operated or funded, in whole or in part, by Rocky Mountain Power or Pacific Power. If any specific program has had more than one analysis in the past three years the most recent analysis will be sufficient. REQUEST NO.7: Does Rocky Mountain Power and/or PacifiCorp realize any tax benefits, at either the federal or state level, for the conservation investments made in Idaho through the low income weatherization efforts. If so, please quantify such benefits. DATED at Boise, Idaho, this z-Z day of November 2006. Donald L. Ho ll, II Deputy Attorney General Technical Staff: Wayne Hart Chris Hecht i:umisc:prodreq/paceO6,j Odhwhchecht pr j to RMP PRODUCTION REQUEST TO ACIFICORP DBA ROCKY MOUNTAIN NOVEMBER 22 , 2006 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF NOVEMBER 2006 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC- 06-, BY E-MAILING A COpy THEREOF, TO THE FOLLOWING: DEAN BROCKBANK ACIFICORP DBA ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2200 SALT LAKE CITY UT 84111 BRIAN DICKMAN ACIFICORP DBA ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 DATA REQUEST RESPONSE CENTER ACIFICORP 825 NE MUL TNOMAH STE 800 PORTLAND OR 97232 BRAD M PURDY ATTORNEY AT LAW 2019 N 17TH ST BOISE ill 83702 I ~~.ktJL RETARY CERTIFICATE OF SERVICE