20111108PAC to CAPAI 1-55.pdf

Mark C. Moench
Danel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Uta 84111
TelephoneNo. [phone]
Facsimile No. [phone]
mark.moench(qpacificorp.com
danel. solander(qpacificorp. com
R c r. i: l'",..",Jl- Vl.._
201 i ~JOV -8 AM 10= 06
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ROCKY)
MOUNTAIN POWER FOR)
APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE)
SCHEDULES AND A PRICE )
INCREASE OF $32.7 MILLION )
OR APPROXIMATELY 15.0)PERCENT )
CASE NO. PAC-E-11-12
DISCOVERY REQUESTS
ROCKY MOUNTAIN POWER'S FIRST SET OF DISCOVERY REQUESTS
TO THE COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO
COMES NOW, Rocky Mountain Power and hereby serves its first set of data requests on the
Communty Action Parership Association of Idaho ("CAP AI") regarding the above docketed
application of Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utilities
Commission's Rules of Procedure, ID AP A 31.01.01, as follows:
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DEFINITIONS AN INSTRUCTIONS
The following definitions and instrctions apply to each of the requests for production set
forth herein and are deemed to be incorporated therein.
(1) "Document" and "documentation" should be interpreted as broadly as possible
to include, but not be limited to, the original or any copy, regardless of origin or location, of any
book, pamphlet, periodical publication, letter, scrapbook, diar, calendar, canceled check;
photograph, form, memorandum, schedule, tax retu, telegram, telex, report, record, order or
notice of governental action of any kind, stdy, minutes, logs, graph, index, tape, disc" internal
operating manual, data sheet or data processing card, or any other written, recorded, transcribed,
punched, taped, filmed, graphic or retrevable matter or data of any kind, however produced or
reproduced, to which you have or have had access. This definition is intended to include, but not
be limited to, all documents which have been created and/or which reside in any tye of
electronic format and is to be constred in its most comprehensive sense as contemplated by the
Idaho Rules of Civil Procedure.
(2) "Person or Entity" should be interpreted to denote, uness otherwse specified,
any natual person, firm, corporation, association, group, individual or organzation of any type
whatsoever.
(3) Any request to "identify" or "provide" should be interpreted to mean:
a) With respect to a natual person, that person's full name, title, job
description, and business and home address. Where the identification pertins to a past period,
as to each person identified who is stil in your employ, or the employment of the group with
which such person is identified in response to any requests, provided, in addition, that person's
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title and job description as of the time of such past period. Where the person is no longer in your
employ or the employment of the group with which such person is identified in response to any
request, provide that person's affiliate, position, home and business address, if known, or if not
known, such person's last known affliation, position, home and business address, or portions
thereof as may be known.
b) With respect to an entity other than a natual person, that entity's name,
business, tye of entity, present status and present or last known address.
c) With respect to a document, that document's title, date, author (and, if
different, the signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general natue, and any amendments thereto, present location and custodian,
whether or not such document is in the respondent's possession, custody or control and whether
or not the document is claimed to be privileged. The final version and each draft of each
document should be identified and produced separately. Each original and each non-identical
copy (bearing marks or notations not found on the original) of each final version and draf of
each document should be identified and produced separately.
d) With respect to a physical facility, the location of the facility, the intended
purose of the facilty, the actual use of such facility, the operating dates of the facility, the
instalation date of the facility, the date utilization of the facility terminated if applicable, and
whether the facilty is subject to the jurisdiction of the Federal Energy Regulatory Commission,
the Idaho Public Utilities Commission, or any other reguatory body.
(4) "Communication" should be interpreted to include, but not be limited to, all
forms of communication, whether wrtten, printed, oral, pictorial, electronic or otherwse,
including testimony or sworn statement, or any means or type whatsoever.
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(5) "Relating To" or "Related To" means pertning to, presenting, discussing,
commenting on, analyzing, or mentioning in any way.
(6) The term "and" and "or" should be constred either disjunctively or
conjunctively whenever appropriate in order to brig within the scope of each request any
information or document which might otherwse be considered to be beyond its scope.
(7) The singular form of a word should be interpreted as plural, and the plural form of
a word should be interpreted as singuar, whenever appropriate in order to bring within the scope
of each request any information or document which might otherwse be considered to be beyond
its scope.
DATA REQUESTS
Rocky Mountain Power Data Requests:
1. For the past five years provide the Federal definition of low-income household.
2. For the past five years provide the definition CAP AI uses for the purose of qualifying
households as income eligible for low income weatherization services.
3. On page 2 of Ms. Ottens' testimony, she mentions testifying in numerous electrc and
water cases. Has Ms. Otens testified in cases related to utilities providing natual gas
service?
a. Please provide specifics as to the dates and subject of this testimony;
b. Has Ms. Ottens requested fuding from natual gas providers for low income
weatherization services and/or energy education? If so, please describe the
outcome of the request(s).
4. Please provide total low income weatherization program fuding used in Idaho durng
each of the last 5 years. Include the amount of fuds from each and every source
including but not limited to fuding from the U.S. Deparment of Energy, the U.S.
Deparent of Health and Human Services, Bonnevile Power Administration, the
American Recovery and Reinvestment Act, Avista, Idaho Power, Rocky Mountan Power
and Intermountain Gas.
5. Please provide the tota number of homes completed in Idaho through the low income
weatherization program durg each of the last 5 years.
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6. Please indicate the number of homes included in response #5 that were heated with an
electric heat source, natual gas heat source and other source for each of the last 5 years.
7. For the past five years provide the following information regarding low income
households served by Rocky Mountai Power:
a. Number of eligible customers requesting weatherization services from each
agency (Eastern Idao Community Action Parnership (EICAP) and Southastern
Idaho Communty Action Agency (SEICAA);
b. Number of cusomers that received weatherization services from EICAP and
SEICAA;
c. Total investment made in homes served by Rocky Mountain Power for
weatherization;
d. Total cost incured by CAPAI, EICAP and SEICAA for low-income energy
conservation education;
e. Tota cost incured by EICAP and SEICAA for adinistering the low-income
weatherization program; and
f. EICAP's and SEICAA's total weatherization program operating costs.
8. For the past five years provide the following information regarding low Income
customers served by Rocky Mountan Power:
a. Total utility fuding paid for weatherization services;
b. Total utility fuding paid for EICAP's and SEICAA's administration cost;
c. Tota utility fuding for energy education;
d. Tota federal (by fuding source) fudig for weatherization services;
e. Total state fuding (by fuding source) for weatherization services; and
f. Total fuding from all other fuding sources (by fuding source).
9. With respect to the administration and delivery of weatherization services to low-income
customers served by Rocky Mountain Power, for the last five years please provide
separately for CAP AI, EICAP and SEICAA:
a. Number of employees;
b. Number of employees involved in the adminstration of the low.,income
weatherization program; and
c. Number of employees involved in the instalation, delivery, inspection and
monitoring etc. of weatherization measures.
10. Please provide job descriptions for each employee included in the previous response that
was paricipating in the administration and/or delivery of low-income weatherization
servces to Rocky Mountain Power customers separately for CAP AI, EICAP and
SEICAA.
11. For the past five years provide the percent of total fuding received from federal sources
(by source) and used to provide weatherization services to low-income customers served
by Rocky Mountain Power where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primar source of space heating and water heating is gas;
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c. The customer's primar source of space heating is electrc and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
12. For the past five years provide the percent of total fudig received from the State of
Idaho (by source) and used to provide weatherization servces to low-income customers
served by Rocky Mountain Power where: '
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primary source of space heating and water heating is gas;
c. The customer's primar source of space heating is electric and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
13. For the past five years provide the percent of tota fuding received from Rocky
Mountain Power used to provide weatherization services to low-income customers served
by Rocky Mountain Power where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primar source of space heating and water heating is gas;
c. The customer's primary source of space heating is electrc and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
14. For the past five years provide the percent of total fuding received from other sources by
source (and identify the sources) and used to provide weatherization services to low-
income customers served by Rocky Mounta Power where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primar source of space heating and water heating is gas;
c. The customer's primar source of space heating is electrc and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
15. For the past five years provide the terms and conditions imposed by each fuding source
for low-income weatherization services provided to Rocky Mountain Power's customers.
16. Please provide details and any supporting data or calculations on how it was determined
that Rocky Mountan Power customers will have to wait for an average of 8 years to
obtain low income weatherization services.
17. How many Rocky Mountain Power customers are on the weatherization waiting list of
EICAP and SEICAA as of December 31, 201 O? How many are on the weatherization list
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of EICAP and SEICAA as of October 31, 2011? Of these homes, how many have an
electrc heating system, natural gas heating system, or other?
18. Please provide the board minutes, over the last five years, where the CAP AI Board of
Directors discussed CAP AI intervention in a Rocky Mountan Power regulatory
proceeding before the Idaho Public Utilty Commission.
19. With respect to CAPAI's intervention in Rocky Mounta Power's regulatory
proceedings before the Idaho Public Utilities Commission, for the past five years provide:
a. Total amount paid by CAP AI to intervene in Rocky Mountai Power regulatory
proceedings;
b. Tota amount paid by CAP AI to consultants employed to review filings and
testify before the Idaho Public Utility Commission; and
c. Total amount paid by CAPAI to attorney's employed to intervene in Rocky
Mountan Power's regulatory proceedings.
20. Please provide all material CAP AI, EICAP and SEICAA have utilzed over the last five
years to inform quaifying customers of the availability of low-income weatherization
services.
21. For the last 10 years please provide the percentage of Rocky Mountain Power's
customers who are income eligible for the low-income weatherization program and reside
in a home that requires these services. Include how this was determined, the percentage
of these customers requesting these services and the percentage of qualifying customers
who have received low-income weatherization services.
22. Please provide the percentage of qualifying customers receiving low-income
weatherization assistace where their residence is owned by a third par.
23. Please provide copies of studies conducted by the witness and/or under the direction of
the witness where the cost-effectiveness of a low-income weatherization program from
the perspective of the fuding agency was evaluated.
24. Please provide the witness' qualification with respect to the evaluation of the cost-
effectiveness of an energy effciency program from the fuding agency's perspective.
25. Please explain the witness' intent and/or meaning in stating on page 8 lines 13 - 15,
where it is stated that "(B)y characterizing its own program as not being cost-effective,
Rocky Mountain did not exactly do itself any favors."
26. Please provide all studies and analysis underten and/or reviewed by the witness
independently to support the statement that "had every revenue requirement issue
identified in ths case by Staff been litigated, the outcome might have been a lesser
revenue requirement and rate increase than settled upon."
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27. For the past five years provide the following information regarding low income
customers served by Idaho Power:
a. Number of eligible customers requesting weatherization services from local
weatherizing agencies; ,
b. Number of low-income customers that received weatherization services from
local weatherizing agencies;
c. Total investment made in homes for weatherization;
d. Tota cost incured by local agencies for low-income energy conservation
education;
e. Tota cost incured by local weatheriing agencies for administering the low-
income weatherization program; and
f. Local weatherizing agencies total weatherization program operating costs.
28. For the past five years provide the following information regarding low income
households served by Idaho Power:
a. Total utilty fuding paid for weatherization services;
b. Total utility fuding paid for local weatherizing agencies administration cost;
c. Total utility fuding for energy education;
d. Tota federal fuding (by fuding source) for weatherization services;
e. Tota state fuding (by fuding source) for weatherization services; and
f. Total fuding from all other fuding sources (by funding source).
29. With respect to the administration and delivery of weatherization services to low-income
customers served by Idaho Power, for the last five years please provide for CAP AI and
each local weatherizing agency:
a. Number of employees;
b. Number of employees involved in the administration of the low-income
weatherization program; and
c. Number of employees involved in the installation, delivery, inspection and
monitoring, etc. of weatherization measures.
30. Please provide job descriptions for each employee included in the previous response that
was paricipating in the administration and/or delivery of low-income weatherization
services to Idaho Power customers separately for CAP AI and each local weatherizing
agency.
31. For the past five years provide the percent of total fuding received from federal sources
(by source) for weatherization servces to low-income customers served by Idaho Power
where:
a. The customer's primary source of space heating and water heating is electric;
b. The customer's primary source of space heating and water heating is gas;
c. The customer's primar source of space heating is electric and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electrc.
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32. For the past five yéars provide the percent of total fuding received from the State of
Idaho (by source) for weatherization services to low-income customers served by Idaho
Power where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primar source of space heating and water heating is gas;
c. The customer's primar source of space heating is electrc and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electrc.
33. For the past five years provide the percent of total fuding received from Idaho Power for
weatherization services to low-income customers served by Idaho Power where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primar source of space heating and water heating is gas;
c. The customer's primar source of space heating is electric and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electrc.
34. For the past five years provide the percent of total funding received from other sources
(and identify the sources) and used to provide weatherization services to low-income
customers served by Idaho Power where:
a. The customer's primar source of space heating and water heatig is electric;
b. The customer's primar source of space heating and water heating is gas;
c. The customer's primar source of space heating is electrc and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
35. For the past five years provide the terms and conditions imposed by each fuding source
for low-income weatherization services provided Idaho Power customers.
36. For the past five years provide the following inormation regarding low income
households served by Avista separately for gas and electric service:
a. Number of eligible customers requesting weatherization services from local
weatherizing agencies;
b. Number of low-income customers that received weatherization services from
local weatherizing agencies;
c. Tota investment made in homes for weatherization;
d. Total cost incured by local agencies for low-income energy conservation
education;
e. Tota cost incured by local weatherizing agencies for administering the low-
income weatherization program;
f. Local weatherizing agencies total weatherization program operating costs.
9
37. For the past five years provide the following inormation regarding low Income
customers served by A vista separately for electric and gas service:
a. Total utility fuding paid for weatherization servces;
b. Total utility fuding paid for local weatherizing agencies administration cost;
c. Total utilty fuding for energy education;
d. Tota federal fuding (by fuding source) for weatheriation services;
e. Total state fuding (by fuding source) for weatherization services; and
f. Total fuding from all other fuding sources (by fuding source).
38. With respect to the administration and delivery of weatherization services to low-income
customers served by A vista, for the last five years please provide for CAP AI and each
local weatherizing agency:
a. Number of employees;
b. Number of employees involved in the administration of the low-income
weatherization program; and
c. Number of employees involved in the installation, delivery, inspection and
monitoring, etc. of weatherization measures.
39. Please provide job descriptions for each employee included in the previous response that
was paricipating in the admnistration and/or delivery of low-income weatherization
services to A vista customers separately for CAP AI and each local weatherizig agency.
40. For the past five years provide the percent of tota fuding received from federal sources
(by source) for weatherization services to low-income customers served by A vista where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primar source of space heating and water heating is gas;
c. The customer's priar source of space heating is electric and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
41. For the past five years provide the percent of tota fuding received from the State of
Idaho (by source) for weatherization services to low-income customers served by A vista
where:
a. The customer's priar source of space heating and water heating is electrc;
b. The customer's primar source of space heating and water heating is gas;
c. The customer's primar source of space heating is electric and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
42. For the past five years provide the percent of total fuding received from Avista for
weatherization services to low-income customers served by Avista where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's primar source of space heating and water heating is gas;
10
c. The customer's primary source of space heating is electrc and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
43. For the past five years provide the percent of total fuding received from other sources
(and identify the sources) and used to provide weatherization services to low-income
customers served by Avista where:
a. The customer's primar source of space heating and water heating is electric;
b. The customer's priar source of space heating and water heating is gas;
c. The customer's primar source of space heating is electric and water heating is
gas;
d. The customer's primar source of space heating is gas and water heating is
electric.
44. For the past five years provide the terms and conditions imposed by each fuding source
for low-income weatherization service provided A vista's customers.
45. Please provide all results from state, federal. and CAP AI audits and inspections related to
the low income weatherization services provided by EICAP and SEICAA to Rocky
Mountain Power customers for the last five years.
46. Ms. Ottens states on page 6 of her testimony that the number of general rate cases
combined with an evaluation case could well be unprecedented. Did she investigate to
determine if this is the case, or is this statement a speculation?
47. Does CAP AI receive intervener fuding to cover their costs in general rate cases?
48.. On page 17 of Ms. Ottens' testimony she provides details as to how she calculates low
income weatherization fuding per capita for A vista, Idaho Power and Rocky Mounta
Power. Does ths calculation include fuding for services directed to electric servce
only? If not, separate fuding per capita by energy source. In addition, please provide the
per capita fuding of low income weatherization services for each of the other home
energy providers throughout Idaho.
49. The issue of low income weatherization program fuding party is mentioned on page 18
of Ms. Ottens' testimony. Why is party only an issue between Avista, Idaho Power and
Rocky Mountan Power? Does the parity issue affect A vista differently because they
provide electric and gas service?
50. Regarding the termination of American Recovery and Reinvestment Act (AR)
funding mentioned on page 4 of Ms. Ottens' testimony, was the elimination of ths
fuding source unexpected? If not, why not?
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51. Please provide a detailed description of the low-income energy education programs
including but not limited to the contents of the energy efficiency kits, a description of the
curculum, outreach methods, the anua paricipant goal and number of households
served anually since the programs began as it pertns to:
a. Customers served by Rocky Mountain Power;
b. Customers served by Idaho Power; and
c. Customers served by A vista.
52. Please provide an anual breakdown of costs incured related to low income energy
education programs including but not limted to kit costs, curiculum costs incured by
the agencies and overall cost per paricipating household since the programs began as it
pertains to:
a. Customers served by Rocky Mountan Power;
b. Customers served by Idaho Power; and
c. Customers served by A vista.
53. Please provide the number of households completing the energy education
program fuded by Rocky Mountan Power by obtaig an energy efficiency kit and
receiving the education curculum by month though October 31, 2011.
54. Ms. Ottens states on page 22 that all kits will be distributed by year end. Wil the 500
households also be provided the energy education curculum by December 31, 2011 ?
55. How does the percent increase in Rocky Mountain Power residential rates since 1989
compare to the percent increase in low income weatherization fudig?
DATED ths 7th day of November 2011.
Respectfuly submitted,
ROCKY MOUNTAIN POWER
Mark C. Moench
Daniel E. Solander
201 South Main Street, Suite 2300
Salt Lake City, Uta 84111
Telephone No. [phone]
Facsimile No. [phone]
mark.moench~pacificorp.com
danel.solander~pacificorp.com
Attorneys for Rocky Mountain Power
12
CERTIFICATE OF SERVICE
I hereby certify that on this 7th of November, 2011, I caused to be served, via e-mail
and/or US mail, a tre and correct copy of the foregoing document in P AC-E-11-12 to the
following:
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Charered
201 E. Center
P.O. Box 1391
Pocatello, iD 83204-1391
E-Mail: elo(ßracinelaw.net
Tim Buller (E-mail Only)
Agrum, Inc./Nu- West Industres
3010 Conda Road
Soda Springs, ID 83276
E-Mail: tbulleræ&agrium.com
Neil Price
Deputy Attorney General
Idaho Public Utilities Commssion
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
E-Mail: nei1.price~uc.idaho.gov
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tonycmyane1.net
James R. Smith (E-mail Only)
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
E-Mail: jim.r.smith(ßmonsanto.com
Ronald L. Wiliams
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID,83702
E-mail: ronimwilliamsbradbur.com
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,Charered .
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: rcbimracine1aw.net
Brad Purdy
CAPAI
2019 N. 17th St.
Boise, ID. 83702
E-mail: bmpurdyæ&hotmai1.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
E-mail: bottoimidahoconservation.org
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-Mail: bcollns(gconsultbai.com
Don Schoenbeck
RCS, Inc.
900 Washington St, Suite 780
Vancouver W A, 98660
E-Mail: dwsimr-c-s-inc.com
lsi
Kaley McNay
Coordinator, Regulatory Operations