20100518Staff 10-15 to PAC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEiVED
28\6 MAY l 8 AM 10: 22
IDAHO PUSL\G . -,
UTILITIES COMMISSiON
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR AN INCREASE TO THE )
CUSTOMER EFFICIENCY SERVICES RATE. )
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CASE NO. PAC-E-I0-03
SECOND PRODUCTION
REQUEST OFTHE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain
Power (Company; Rocky Mountain) provide the following documents and information on or
before TUESDAY, JUNE 1,2010.
This Production Request is to be considered as continuing, and 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 wil augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MAY 18,2010
person preparing the document, and the name, location and phone number of the record holder
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 10: Please explain the Company's intent to pursue all cost effective
demand side management (DSM) opportunities.
REQUEST NO. 11: Are all DSM programs currently offered expected to continue to be
cost-effective? Please explain.
REQUEST NO. 12: Please explain how customers would realize a long-term net benefit
if the Company were to terminate its contract with the Northwest Energy Effciency Allance
(NEEA) and eliminate its Irrigation Energy Services Program.
REQUEST NO. 13: Please explain Rocky Mountain's past and current active
paricipation in NEEA's cost-effectiveness advisory committee.
REQUEST NO. 14: Please explain Rocky Mountain's past and current active
participation in other NEEA advisory committees.
REQUEST NO. 15: The Company states in its Application that the cost-effectiveness of
the Irrigation Energy Services program in 2009 passed the utilty cost test (UCT), but did not
pass the Total Resource Cost test (TRC). The Application lists the following as primar
contributing factors: 1) transition costs associated with changing pr~gram administrators and 2)
customer specific costs associated with equipment investments that delivered operational
efficiencies in addition to energy efficiency benefits, i. e. "the additional customer costs from
these seven projects had a negative impact on the TRC test from a strictly electric energy savings
perspective." Application at 11. Please answer the following questions regarding these issues:
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 18,2010
a) What were the specific costs associated with the transition of program
administration?
b) Were the transition costs included in calculating cost-effectiveness from both
the total resource cost (TRC) and the utilty cost (UCT) perspectives? Please
explain.
c) Does the Company typically include non-electricity benefits in its TRC cost-
effectiveness calculations? Explain why or why not.
d) Does the Company typically include non-electricity benefits in its Paricipant
cost-effectiveness calculations? Explain why or why not.
e) Are the "additional customer costs" from the seven projects with long simple
paybacks separately identifiable from the costs incured for energy effcient
equipment? Please explain.
f) What action has the Company taken to ensure that all measures associated
with the Irrigation Energy Services program wil be cost effective from the
TRC, UCT and Paricipant perspectives in the future?
g) The Company's 2009 DSM Annual Report lists a process and impact
evaluation for the Irrigation Energy Services as being "In Process." When is
that evaluation expected to be completed?
h) Has the Company (or contractors for it) previously completed any formal
evaluations of irrigation efficiency? If so, please provide a copy of any such
evaluation(s).
Dated at Boise, Idaho, this jt6Ilday of May.
~i:';a. t2 ~AJA..
Krnr A. Sasser
Deputy Attorney General
Technical Staff: Gar Grayson/l 0-15
i:umik:prodreq/pace lO.3ksgg prod req2.doc
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MAY 18,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH OF MAY 2010, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-1O-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.westonCipacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datarequest(fpacificorp.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyanel.net
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: danie1.solander(fpacificorp.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloCiracinelaw.net
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
J;/~
SECRETA
CERTIFICATE OF SERVICE