The URL can be used to link to this page

Home My WebLink About20061207CAPAI to PAC 1-10.pdfBrad M. Purdy Attorney at Law Bar No. 3472 2019 N. 1 th St. Boise, ID. 83702 (208) 384-1299 FAX: (208) 384-8511 bmpurdy~hotmail.com Attorney for Petitioner Community Action Partnership Association of Idaho ECEI\fr-1'\ . ',. lUnG DEC -1 PM 3: 46 IC,tHO PUBLiC .. UTIU hE8 COM\\~\SSIOI BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF P ACIFICORP TO DEERMINE THE APRO- PRIA TE PAYMENT STRUCTURE OF SCHEDULE 21 CASE NO. PAC-06- FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO (CAP AI) TO P ACIFICORP DBA ROCKY MOUNTAIN POWER CAP AI, by and through its attorney of record, Brad M. Purdy, requests that PacifiCorp provide the following documents and information as soon as possible, but no later than MONDAY, DECEMBER 11,2006. This Production Request is to be considered continuing in nature and PacifiCorp is requested to provide, by way of supplementation, additional documents or responses that it or any person acting on its behalf may later obtain that will augment the documents and responses already produced. For each item, please indicate the name ofthe person(s) preparing the answers along with the job title of such person(s) and the witness who can support the answer at hearing. PRODUCTION REQUEST TO P ACIFICORP REQUEST NO.Please list all United States Department of Energy ("DOE" measures that are eligible under the PacifiCorp low-income weatherization program for reimbursement and list those not eligible. REQUEST NO.What is the source document that PacifiCorp relies upon to determine which weatherization measures are eligible for Company funding under the low-income weatherization program? REQUEST NO.Please produce a copy of any source document identified in response to the preceding Production Request. REQUEST NO.For every weatherization measure approved by DOE but not approved by PacifiCorp, explain why the Company refuses to fund that measure? REQUEST NO.For each ofthe past ten years, please identify every year, if any, that the two eastern Idaho Community Action agencies involved in the Company low-income weatherization program fully exhausted the total annual amount of funding appropriated for that program? REQUEST NO.For each of the past ten years, please provide the percentage of low-income weatherization funds expended as a percentage of the total amount appropriated for that year? REQUEST NO.Please explain why PacifiCorp s percentage of funding for each low-income weatherization project should be lower than either Idaho Power Company or A VISTA? REQUEST NO.On page 7 of his direct testimony, Company witness Brian Dickman contends that an increase in the percentage of funding per project by PacifiCorp PRODUCTION REQUEST TO P ACIFICORP will actually reduce the total number of homes weatherized under the low-income weatherization program. Regarding this contention, please respond to each of the following questions: 1) does the contention rely on the assumption that PacifiCorp is currently funding 50% of all DOE approved weatherization measures actually installed on the project? 2) Does this contention assume that the eastern Idaho community action agencies exhaust all of the funding provided by PacifiCorp for any given fiscal year? REQUEST NO.On page 6, lines 19-, of his direct testimony, Company witness Brian Dickman states that the low-income weatherization program "narrowly passed the Utility Cost Test under the Integrated Resource Plan ("IRP") Decrement approach for quantifying the expected benefits. Regarding this contention, please answer the following questions: 1) Does this assume that PacifiCorp is actually funding 50% of all project costs? 2) Does this assume that actual project costs when the study was conducted was the $1 500.00 cap that has since been eliminated? REQUEST NO.I0: On page 6, line 23 through page 7 , line 3 , Company witness Brian Dickman testifies that "(aJn increase in the Company s reimbursement would mean a larger percentage of program costs would be covered from funds collected through Schedule 191 and a smaller percentage through federal tax funds. Please provide all proof, including the production of all documents or other physical evidence, supporting this contention. PRODUCTION REQUEST TO P ACIFICORP DATED, this 6th day of December, 2006. PRODUCTION REQUEST TO P ACIFICORP Isl Brad M. Purdy CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE ON THIS 6TH DAY OF DECEMBER 2006, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF COMMUNITY ACTION PARTNERSHIP OF IDAHO TO ROCKY MOUNTAIN POWER, DBA, PACIFICORP, IN CASE NO. PAC-06010 BY EMAILING A COpy THEREOF TO THE FOLLOWING: DEAN BROCKBANK PACIFICORP dean. brockbank~pacificorp.com DATA REQUEST RESPONSE CENTER PACIFICORP datarequest~pacifi corp. com BRIAN DICKMAN PACIFICORP brian. di ckman~pac ificorp. com DONALD L. HOWELL ASSISTANT ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION don. howell~puc. idaho. gov PRODUCTION REQUEST TO P ACIFICORP