20111125CAPAI to PAC 1-55pdf.pdf

CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 1

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN ) CASE NO. PAC-E-11-12
POWER FOR APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES ) COMMUNITY ACTION
) PARTNERSHIP ASSOCIA-
) TION’S RESPONSE TO
) ROCKY MOUNTAIN'S FIRST
) PRODUCTION REQUESTS
__________________________________________)
The Community Action Partnership Association of Idaho (CAPAI) hereby responds to
Rocky Mountain Power's (RMP) First Production Requests to CAPAI as follows:
Initial Objection of CAPAI to Production Requests:
CAPAI hereby asserts the following objection that applies to all production requests
responded to herein unless otherwise stated.
CAPAI objects to RMP's production requests on the basis that they are unduly
burdensome. These production requests include approximately 158 questions, some of which are
compound. Even multiple part requests contain questions within questions thereby increasing
the total number of requests numbering in the hundreds. Many questions seek specific
information regarding data pertinent only to other utilities and, therefore, not reasonably likely to
lead to admissible evidence and irrelevant. A majority of the requests seek information already
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 2

in the possession of RMP and the Company is the best source for that information thereby
making the requests unreasonable. Many of the requests are nothing but re-worded repetitions of
previous requests making them unreasonably compound and complex. Further, CAPAI notes
that these production requests were filed during the holidays and during the busiest time of the
year for CAPAI and the Community Action Agencies it represents as they hurriedly attempt to
process requests for bill assistance as the heating season approaches. Because CAPAI and the
agencies are non-profit entities operating on extremely limited budget, and because their
resources are already being taxed beyond their limits, RMP's requests are unduly burdensome.
Finally, CAPAI notes that RMP objected and simply refused to respond to many of CAPAI's
First Discovery Requests to RMP without a legitimate reason.
Notwithstanding the foregoing and objection, CAPAI states that it has endeavored to
respond in good faith to RMP's requests and by the date requested by the Company. Further,
CAPAI will supplement responses as soon as possible, to the extent reasonable and necessary.
Rocky Mountain Power Data Requests:
1. For the past five years provide the Federal definition of low-income household.

RESPONSE: The table below sets forth the poverty guidelines which CAPAI relies upon in defining
low-income.

Table 1. Federal Poverty Guidelines by Household Size (2007 – 2011)
HH Size 2007 2008 2009 2010 2011
1 $10,210 $10,400 $10,830 $10,830 $10,890
2 $13,690 $14,000 $14,570 $14,570 $14,710
3 $17,170 $17,600 $18,310 $18,310 $18,530
4 $20,650 $21,200 $22,050 $22,050 $22,350
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 3

5 $24,130 $24,800 $25,790 $25,790 $26,170
6 $27,610 $28,400 $29,530 $29,530 $29,990

For each additional person, add:
2007: $3,480
2008: $3,600
2009: $3,740
2010: $1,740
2011: $3,820

Low income definitions vary depending upon the program. LIHEAP was at 150% of the
federal poverty level and changed to 60% of state medium income level in July, 2009. For
weatherization programs the definitions of low income was 150% of the Federal Poverty Level,
and was increased to 200% of the federal poverty level effective 2009. Details of actual income
levels can be found on the Idaho PUC website.
2. For the past five years provide the definition CAPAI uses for the purpose of
qualifying households as income eligible for low income weatherization services.

RESPONSE: See response to request No. 1.

3. On page 2 of Ms. Ottens’ testimony, she mentions testifying in numerous electric
and water cases. Has Ms. Ottens testified in cases related to utilities providing
natural gas service?

a. Please provide specifics as to the dates and subject of this testimony;
b. Has Ms. Ottens requested funding from natural gas providers for low income
weatherization services and/or energy education? If so, please describe the
outcome of the request(s).

RESPONSE: CAPAI objects to this request on the basis of relevance and confidentiality.
Without waiving this objection, CAPAI notes that, as RMP is well aware, the gas industry has
largely been deregulated in comparison to the electric industry for many years. Thus,
proceedings before the Idaho Public Utilities Commission involving applications by gas utilities
typically do not involve the same type of intervention and involvement by Staff or intervenors.
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 4

Regarding CAPAI requests for low-income weatherization and education funding from
natural gas providers CAPAI, CAPAI has previously intervened in gas proceedings before the
Commission and participated in discussions with gas providers regarding low-income
weatherization program funding. Thus far, most natural gas providers have been reluctant to
fund low-income weatherization program. CAPAI notes, however, that AVISTA's low-income
weatherization program provides funding to all electric customers, including those whose
primary heat source is gas, also obtained from AVISTA.
4. Please provide total low income weatherization program funding used in Idaho
during each of the last 5 years. Include the amount of funds from each and every
source including but not limited to funding from the U.S. Department of Energy, the
U.S. Department of Health and Human Services, Bonneville Power Administration,
the American Recovery and Reinvestment Act, Avista, Idaho Power, Rocky
Mountain Power and Intermountain Gas.

RESPONSE: CAPAI objects to the vagueness of this request, specifically what the term
"funding used" means. Without waiving this objection, CAPAI states as follows:
2006 2007 2008 2009 2010

DOE $ 2,096,325
$
2,049,324 $ 1,909,493 $ 3,309,826 $ 1,527,849
HHS $ 1,961,577
$
2,445,646 $ 2,009,734 $ 4,476,820 $ 9,928,922
BPA $ 508,683
$
509,790 $ 930,600 $ 639,585
$
518,200
ARRA $ 30,254,219
IPC $ 1,310,222
RMP $ 150,000
PVE $ 123,607 $0 $0 $0 $0
Total $ 6,150,414
$
5,004,760 $ 4,849,827 $ 38,680,450 $ 11,974,971

The funding amounts above do not include funding retained by the Idaho Department of
Health and Welfare from the U.S. Department of Energy, U.S. Department of Health and Human
Services, Bonneville Power Administration, or the American Recovery and Reinvestment Act.
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 5

Due to lack of visibility into totals for utility contracts, the associated amounts for 2007 through
2010 are not available.
5. Please provide the total number of homes completed in Idaho through the low
income weatherization program during each of the last 5 years.

RESPONSE: CAPAI objects to this request on the basis that it is too vague to answer. RMP
provides no clue what it is referring to when it refers to "the low income weatherization
program." The request seems to seek information statewide, outside the service territory of
RMP. To the extent that this request seeks information regarding RMP's low-income
weatherization program, the Company can obtain this information from agency invoices.
6. Please indicate the number of homes included in response #5 that were heated with
an electric heat source, natural gas heat source and other source for each of the last
5 years.

RESPONSE: As RMP well knows, customers who use a primary heat source other than
electricity are not eligible for participation in RMP's LIWA program.
7. For the past five years provide the following information regarding low income
households served by Rocky Mountain Power:
a. Number of eligible customers requesting weatherization services from each
agency (Eastern Idaho Community Action Partnership (EICAP) and
SouthEastern Idaho Community Action Agency (SEICAA);
b. Number of customers that received weatherization services from EICAP and
SEICAA;
c. Total investment made in homes served by Rocky Mountain Power for
weatherization;
d. Total cost incurred by CAPAI, EICAP and SEICAA for low-income energy
conservation education;
e. Total cost incurred by EICAP and SEICAA for administering the low-
income weatherization program; and
f. EICAP’s and SEICAA’s total weatherization program operating costs.

RESPONSE: CAPAI objects to this request on the basis that RMP is already in possession of
this information, seeks information that is irrelevant or confidential, and the request is unduly
burdensome. Without waiving this objection, CAPAI responds as follows:
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 6

For SEICAA, the response is:

a. Less than 10% of eligible customers request weatherization services.
b. Less than 15% of customers that received weatherization services.
c. Object on the basis that RMP has this information and is the best source
for the same.
d. A response to this request will be provided through supplementation as
soon as possible.

CAPAI is in the process of obtaining data from EICAP and will provide it as soon as
possible.
8. For the past five years provide the following information regarding low income
customers served by Rocky Mountain Power:
a. Total utility funding paid for weatherization services;
b. Total utility funding paid for EICAP’s and SEICAA’s administration cost;
c. Total utility funding for energy education;
d. Total federal ( by funding source) funding for weatherization services;
e. Total state funding (by funding source) for weatherization services; and
f. Total funding from all other funding sources (by funding source).

RESPONSE: CAPAI repeats its objections to Request Nos. 5-7. Without waiving, the relevant
responses for SEICAA are as follows:
For SEICAA, RMP will pay 85% of total electric homes if a major measure (including
window replacement, ceiling, wall, floor insulation) before it will pay for supplemental measures
(such as attic ventilation, vapor barriers, duct insulation and sealing, weather-stripping,
replacement doors, thermostats, pipe insulation, cfls, and refrigerators). On all other homes RMP
will only pay 85% of cfls, pipewrap, and refrigerator replacements.
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 CAPAI, EICAP and SEICAA:
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.

CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 7

RESPONSE: CAPAI objects to this request on the basis of vagueness. It is not clear precisely
which employees RMP seeks information for and whether the weatherization services to which
the request applies include non-RMP measures and funding sources (e.g., DOE). Without
waiving, CAPAI states as follows:
a. Rocky Mountain Power contracts directly with EICAP and SEICAA to provide
administration and delivery of weatherization services to low income customers
served by Rocky Mountain Power. CAPAI staff does not provide administration
or delivery of this program.
b. Rocky Mountain Power contracts directly with EICAP and SEICAA. CAPAI
staff is not involved in the administration of the Rocky Mountain Power low
income weatherization program.
c. Rocky Mountain Power contracts directly with EICAP and SEICAA for the
installation, delivery, and inspection of weatherization measures. CAPAI staff
only provides monitoring for Rocky Mountain Power funded weatherization
measures when the dwellings are cost-shared with federal funding. Rocky
Mountain Power funded units are not targeted for the random sampling used to
determine which completed units will be reviewed during annual on-site
monitoring.

CAPAI's response will be supplemented as soon as additional information is available.

10. Please provide job descriptions for each employee included in the previous response
that was participating in the administration and/or delivery of low-income
weatherization services to Rocky Mountain Power customers separately for CAPAI,
EICAP and SEICAA.

RESPONSE: CAPAI restates its objection to request No. 9 and objects on the basis that this
request is unreasonably burdensome. Without waiving, CAPAI will supplement this response as
soon as possible.
11. For the past five years provide the percent of total funding 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 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 8

RESPONSE: CAPAI restates its objections to requests 4 through 9. Without waiving, CAPAI
states as follows:
The following chart shows the primary source of space heating of units completed with
federal funding, by source, for the past 5 years:
DOE
2006 2007 2008 2009 2010 Total
Electric 876 816 868 1278 1409 5247
Natural Gas 381 425 458 1195 1490 3949
Oil 60 49 62 97 106 374
Propane 67 71 70 181 210 599
Wood 43 40 46 99 66 294
Other 19 3 4 3 2 31
Total 1446 1404 1508 2853 3283 10494

LPW
2006 2007 2008 2009 2010 Total
Electric 896 899 734 780 810 4118
Natural Gas 681 683 558 592 615 3129
Oil 72 72 59 62 65 329
Propane 90 90 73 78 81 412
Wood 54 54 44 47 49 247
Other
Total 1791 1798 1468 1559 1619 8235

The numbers above are totals for all agencies, not limited to RMP service territory. See
response to request No. 5.
12. For the past five years provide the percent of total funding received from the State
of Idaho (by source) and used to provide weatherization services to low-income
customers served by Rocky Mountain 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 9

RESPONSE: CAPAI restates its objections to request No. 11. Without waiving, CAPAI states
as follows:
The State of Idaho provides pass-through funding from the following funding sources:
U.S. Department of Energy, U. S. Department of Health and Human Services, and Bonneville
Power Administration. The State does not provide general funding to provide weatherization
services to low-income customers served by Rocky Mountain Power.
Otherwise, see response to request No. 11.
13. For the past five years provide the percent of total funding received from Rocky
Mountain Power used to provide weatherization services to low-income customers
served by Rocky Mountain 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI objects to this request on the basis that RMP is already in possession.
Without waiving, additional information will be provided when available.
14. For the past five years provide the percent of total funding received from other
sources by source (and identify the sources) and used to provide weatherization
services to low-income customers served by Rocky Mountain 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI objects to this request on the basis that it has been repeatedly asked and
answered and is unduly burdensome. Without waiving, CAPAI states as follows:
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 10

The only sources used to provide weatherization services to low income customers served
by Rocky Mountain Power are U.S. Department of Energy and U.S. Department of Health and
Human Services. The BPA only provides low-income weatherization funding to customers of its
member, non-profit providers. See response to Request No. 11 above.
15. For the past five years provide the terms and conditions imposed by each funding
source for low-income weatherization services provided to Rocky Mountain Power’s
customers.

RESPONSE: CAPAI objects to this request, in part, on the basis that RMP is well aware of the
"terms and conditions" of its own LIWA program. Furthermore, with respect to other funding
sources and programs, CAPAI objects on the basis that the term "terms and conditions" is
undefined. Without waiving, CAPAI states as follows:
The terms and conditions of the weatherization program follow U.S. Department of
Energy guidance regarding eligible dwellings and allowable measures. The terms and conditions
imposed by the U.S. Department of Health and Human Services defer to the U.S. Department of
Energy guidance, with the exception of weatherization of shelters as a disallowed cost.
Bonneville Power Administration also defers to U.S. Department of Energy guidance with the
exception of allowance of providing clothes washers and microwaves and an increased
percentage allowance for Health and Safety measures, no per unit expenditure cap, and
allowance of re-weatherization of units.
16. Please provide details and any supporting data or calculations on how it was
determined that Rocky Mountain Power customers will have to wait for an average
of 8 years to obtain low income weatherization services.

RESPONSE: CAPAI objects to this request on the basis of vagueness. Without waiving,
CAPAI assumes that RMP is referring to the testimony of Ms. Teri Ottens previously filed in this
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 11

case on behalf of CAPAI. That testimony speaks for itself. Without waiving, CAPAI responds
as follows:
CAPAI simply took the current homes on the Weatherization waiting lists for SEICCA
and EICAP and divided that number by the average number of homes the agencies weatherized
in 2008. CAPAI used 2008 as our sample year because this year represented the average prior to
the American Reinvestment and Recovery Act (ARRA) which increased funding significantly
from 2009 through 2011. These funds are no longer available and should not be used for the
purpose of calculating an average waiting time for LIWA services. In addition it should be noted
that recent notification from the Department of Energy concerning funding levels for 2012 will
be below that received in 2008, which will have the effect of lowering the number of homes that
can be completed within a year.
CAPAI took the average number for EICAP (3.35 years) and added it to the average
waiting period for SEICCA (11.98 years) and divided that number by two to come up with a 7.66
year (rounded up to 8) average waiting period for the region.
17. How many Rocky Mountain Power customers are on the weatherization waiting list
of EICAP and SEICAA as of December 31, 2010? How many are on the
weatherization list of EICAP and SEICAA as of October 31, 2011? Of these homes,
how many have an electric heating system, natural gas heating system, or other?

RESPONSE: CAPAI restates its responses and objections to requests Nos. 6 and 11 through 14.
Without waiving, CAPAI states as follows:
The number of eligible customers on the waiting list changes constantly. It is not known
what the exact number of customers on the waiting list was on December 31, 2010 without
unreasonable effort and recalculation of data no longer current.
18. Please provide the board minutes, over the last five years, where the CAPAI Board
of Directors discussed CAPAI intervention in a Rocky Mountain Power regulatory
proceeding before the Idaho Public Utility Commission.
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 12

RESPONSE: CAPAI objects to this request on the basis that it seeks information that is not
reasonably likely to lead to admissible evidence, not relevant, confidential, and constitutes
attorney-client privilege.
19. With respect to CAPAI’s intervention in Rocky Mountain Power’s regulatory
proceedings before the Idaho Public Utilities Commission, for the past five years
provide:
a. Total amount paid by CAPAI to intervene in Rocky Mountain Power
regulatory proceedings;
b. Total amount paid by CAPAI 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
Mountain Power’s regulatory proceedings.

RESPONSE: CAPAI objects to this request on the basis that it seeks information that is in
RMP's possession and viewable by the general public by visiting the Idaho Public Utilities
Commission website. RMP is the best source for the amount(s) it has paid to CAPAI for
intervention.
20. Please provide all material CAPAI, EICAP and SEICAA have utilized over the last
five years to inform qualifying customers of the availability of low-income
weatherization services.

RESPONSE: CAPAI objects to this request on the basis of vagueness and unduly burdensome.
The terms "all material" and "qualifying customers" are undefined. Without waiving, CAPAI
states as follows:
Information about the availability of low-income weatherization services is provided
during the intake process when the agencies meet personally with potential applicants.
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.

CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 13

RESPONSE: CAPAI objects to this request on vagueness. The request is nonsensical and
cannot be responded to as it is stated. Without waiving, CAPAI states as follows:
CAPAI does not how many RMP customers are income eligible and reside in a home that
requires these services. CAPAI does know how many RMP customers qualified for LIHEAP
and can determine how many of those people are renters but the difference in income guidelines
between low-income weatherization and LIHEAP will create a gap making an accurate response
impossible.
22. Please provide the percentage of qualifying customers receiving low-income
weatherization assistance where their residence is owned by a third party.

RESPONSE: CAPAI objects on the basis of vagueness. It is unclear to CAPAI what time
frame this request refers to. Without waiving, CAPAI states as follows:
The average percentage of households provided weatherization services whose residence
is owned by a third party is 28%. This percentage reflects all of the dwellings provided
weatherization services and is not limited to households in RMP service territory.
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 funding agency was evaluated.

RESPONSE: CAPAI objects to this request on vagueness. CAPAI has no way of knowing who
"the witness" RMP refers to is, what proceeding that person was a witness in, and what "studies
conducted by the witness" RMP is referring to. Without waiving, RMP is already aware that
CAPAI has recently retained Mr. Roger Colton who prepared an analysis that was filed in Case
No. PAC-E-11-13. RMP is already in possession of that analysis.
24. Please provide the witness’ qualification with respect to the evaluation of the cost-
effectiveness of an energy efficiency program from the funding agency’s perspective.

CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 14

RESPONSE: See response to the preceding request. Mr. Colton's resume was attached to and
filed with CAPAI's comments in Case No. PAC-E-11-13.
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.”

RESPONSE: CAPAI objects to this request on the basis that, once again, the request fails to
identify who "the witness" it refers to is and in what proceeding. For purposes of this request
and response alone, CAPAI assumes that this request refers to the testimony of Ms. Teri Ottens
previously filed in this proceeding. If this assumption is correct, the meaning of the excerpt
contained in the preceding request is self-evident when viewed in the context of the entirety of
Ms. Ottens' testimony.
26. Please provide all studies and analysis undertaken and/or reviewed by the witness
independently to support the statement that “had every revenue requirement issue
identified in this case by Staff been litigated, the outcome might have been a lesser
revenue requirement and rate increase than settled upon.”

RESPONSE: CAPAI restates its objection to request Nos. 23 through 25.

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. Total cost incurred by local agencies for low-income energy conservation
education;
e. Total cost incurred by local weatherizing agencies for administering the low-
income weatherization program; and
f. Local weatherizing agencies total weatherization program operating costs.

RESPONSE: CAPAI objects to this request on the basis that it will not likely lead to admissible
evidence due to irrelevance. Without waiving, CAPAI states as follows:
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 15

For SEICAA: a) 1129 customers; b) approximately 172 homes; c) $511,514; d) Cost
incurred is 1 hour split between energy auditor and crews; e) approximately $47,000; f) Not
known at this time.
28. For the past five years provide the following information regarding low income
households served by Idaho Power:
a. Total utility funding paid for weatherization services;
b. Total utility funding paid for local weatherizing agencies administration cost;
c. Total utility funding for energy education;
d. Total federal funding (by funding source) for weatherization services;
e. Total state funding (by funding source) for weatherization services; and
f. Total funding from all other funding sources (by funding source).

RESPONSE: CAPAI objects to this request on the basis of relevance and/or that it seeks
information in the sole possession of Idaho Power.
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
CAPAI 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.

RESPONSE: CAPAI objects to this request on the basis that it is irrelevant, not reasonably
likely to lead to admissible evidence and is unduly burdensome. This is an RMP rate case, not
Idaho Power. Without waiving, CAPAI refers RMP to its response to request No. 9.
30. Please provide job descriptions for each employee included in the previous response
that was participating in the administration and/or delivery of low-income
weatherization services to Idaho Power customers separately for CAPAI and each
local weatherizing agency.

RESPONSE: See response to the preceding objection.

31. For the past five years provide the percent of total funding received from federal
sources (by source) for weatherization services to low-income customers served by
Idaho Power where:
a. The customer’s primary source of space heating and water heating is
electric;
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 16

b. The customer’s primary source of space heating and water heating is gas;
c. The customer’s primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI restates its objection to the preceding request and on the basis that it has
been repeatedly asked and answered. Without waiving this objection, CAPAI notes that Idaho
Power, like RMP, requires that only homes with a primary heat source of electricity are eligible
for low-income weatherization services funded by Idaho Power. Also, see response to request
No. 11.
32. For the past five years provide the percent of total funding received from the State
of Idaho (by source) for weatherization services 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: See response to the preceding objection. Without waiving, CAPAI states as
follows:
The State of Idaho provides pass-through funding from the following funding sources:
U.S. Department of Energy, U. S. Department of Health and Human Services, and Bonneville
Power Administration. The State does not provide general funding to provide weatherization
services to low-income customers served by Idaho Power.
See response to request No. 12.
33. For the past five years provide the percent of total funding received from Idaho
Power for weatherization services to low-income customers served by Idaho Power
where:
a. The customer’s primary source of space heating and water heating is
electric;
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 17

b. The customer’s primary source of space heating and water heating is gas;
c. The customer’s primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI objects to this request on the basis that it pertains to another proceeding
involving a different utility and is, therefore, irrelevant and not likely to lead to admissible
evidence.
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 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI restates its objection to request No. 33. Without waiving, CAPAI notes
that, aside from utility funds, the only other sources for low-income weatherization funding are
the U.S. Department of Energy and U.S. Department of Health and Human Services. BPA does
not provide funding for Idaho Power customers.
35. For the past five years provide the terms and conditions imposed by each funding
source for low-income weatherization services provided Idaho Power customers.

RESPONSE: CAPAI restates its objection to request Nos. 15 and 27-34.
36. For the past five years provide the following information 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. Total investment made in homes for weatherization;
d. Total cost incurred by local agencies for low-income energy conservation
education;
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 18

e. Total cost incurred by local weatherizing agencies for administering the low-
income weatherization program;
f. Local weatherizing agencies total weatherization program operating costs.

RESPONSE: See CAPAI's objections to requests 27 through 35.

37. For the past five years provide the following information regarding low income
customers served by Avista separately for electric and gas service:
a. Total utility funding paid for weatherization services;
b. Total utility funding paid for local weatherizing agencies administration cost;
c. Total utility funding for energy education;
d. Total federal funding (by funding source) for weatherization services;
e. Total state funding (by funding source) for weatherization services; and
f. Total funding from all other funding sources (by funding source).

RESPONSE: See objection to preceding request.

38. With respect to the administration and delivery of weatherization services to low-
income customers served by Avista, for the last five years please provide for CAPAI
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.

RESPONSE: CAPAI restates its objections to requests, 9, 10, 28-30, 38 and 39. Without
waiving, CAPAI states as follows:
a. Avista contracts directly with CAP to provide administration and delivery of
weatherization services to low income customers served by Rocky Mountain
Power. CAPAI staff does not provide administration or delivery of this program.
b. Avista contracts directly with CAP. CAPAI staff is not involved in the
administration of the Rocky Mountain Power low income weatherization
program.
c. Avista contracts directly with CAP for the installation, delivery, and inspection of
weatherization measures. CAPAI staff only provides monitoring for Avista
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 19

funded weatherization measures when the dwellings are cost-shared with federal
funding. Avista funded units are not targeted for the random sampling used to
determine which completed units will be reviewed during annual on-site
monitoring.
39. Please provide job descriptions for each employee included in the previous response
that was participating in the administration and/or delivery of low-income
weatherization services to Avista customers separately for CAPAI and each local
weatherizing agency.

RESPONSE: CAPAI restates its objections set forth in the response to the preceding request.

40. For the past five years provide the percent of total funding received from federal
sources (by source) for weatherization services to low-income customers served by
Avista 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI restates its objections to the preceding request.

41. For the past five years provide the percent of total funding received from the State
of Idaho (by source) for weatherization services to low-income customers served by
Avista 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI restates its objections to the preceding request.

42. For the past five years provide the percent of total funding received from Avista for
weatherization services to low-income customers served by Avista 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;
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 20

c. The customer’s primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI restates its objections to the preceding request.

43. 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 Avista 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 primary source of space heating is electric and water heating
is gas;
d. The customer’s primary source of space heating is gas and water heating is
electric.

RESPONSE: CAPAI restates its objections to the preceding request.

44. For the past five years provide the terms and conditions imposed by each funding
source for low-income weatherization service provided Avista’s customers.

RESPONSE: CAPAI restates its objections to the preceding request.

45. Please provide all results from state, federal and CAPAI 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.

RESPONSE: CAPAI objects to this on the basis that it is unduly burdensome and lacks
relevance. Without waiving, CAPAI responds that it is in the process of obtaining the requested
information but to do so will require additional time. This response will be supplemented as
soon as possible.
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?

RESPONSE: Ms. Ottens' testimony in this regard is based on her direct personal knowledge
and experience as well as research of past Commission cases. Her testimony is not based on
speculation.
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 21

47. Does CAPAI receive intervener funding to cover their costs in general rate cases?

RESPONSE: CAPAI objects to this request on the basis that it is not reasonably likely to lead to
admissible evidence, is information readily available to the general public and in the possession
of RMP, and is irrelevant. Without waiving, the entirety of CAPAI's costs incurred in
participating in cases before the Commission are not always "cover[ed]" by intervenor funding
awards. This is not the result of Commission rulings, but stems from the desire of CAPAI to
keep its requests extremely reasonable and with numerous factors in mind including the statutory
limits of available funding and the number of other intervenors in any case and their respective
levels of participation. CAPAI certainly never recovers more than its actual costs incurred by
participating in proceedings before the Commission.
48. On page 17 of Ms. Ottens’ testimony she provides details as to how she calculates
low income weatherization funding per capita for Avista, Idaho Power and Rocky
Mountain Power. Does this calculation include funding for services directed to
electric service only? If not, separate funding per capita by energy source. In
addition, please provide the per capita funding of low income weatherization
services for each of the other home energy providers throughout Idaho.

RESPONSE: CAPAI objects to this request on the basis that it seeks information already asked
and answered. In addition, the testimony of Ms. Ottens speaks for itself. Without waiving,
CAPAI states as follows:
Ms. Ottens does explain her per capita calculation of per capita funding on p. 17, line 7 of
her testimony in this proceeding. In addition, see response to request No. 49 below.
49. The issue of low income weatherization program funding parity is mentioned on
page 18 of Ms. Ottens’ testimony. Why is parity only an issue between Avista,
Idaho Power and Rocky Mountain Power? Does the parity issue affect Avista
differently because they provide electric and gas service?

RESPONSE: CAPAI objects to this request on the basis that it is vague and confusing and
assumes facts not in evidence and/or misstates testimony. Without waiving, CAPAI notes the
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 22

obvious; AVISTA, Idaho Power and RMP are the three largest electric investor-owned public
utilities in the state. Ms. Ottens' testimony speaks for itself and obviously relates to parity of
low-income weatherization program funding by utilities and benefits received by their respective
customers. CAPAI did not believe that including utilities such as Atlanta Power would provide
the Commission with meaningful, relevant information. Beyond that, CAPAI does not
understand the point of this request.
50. Regarding the termination of American Recovery and Reinvestment Act (ARRA)
funding mentioned on page 4 of Ms. Ottens’ testimony, was the elimination of this
funding source unexpected? If not, why not?

RESPONSE: CAPAI was aware that ARRA was effective for a stated period of time. CAPAI
could not have predicted whether Congress might extend the act or take other action to continue
the benefits it provided. CAPAI also could not anticipate the severity of the economic decline
that has taken place in this country and that increases the need for low-income weatherization
assistance programs.
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 curriculum, outreach methods, the annual participant goal and number of
households served annually since the programs began as it pertains to:
a. Customers served by Rocky Mountain Power;
b. Customers served by Idaho Power; and
c. Customers served by Avista.

RESPONSE: CAPAI objects to this request on the basis that the low-income energy education
programs of Idaho Power and AVISTA are not issues or in any way relevant to this proceeding.
Without waiving, both Idaho Power and AVISTA have agreed to fund their respective low-
income energy education programs on an ongoing basis. Rocky Mountain has steadfastly
refused to do the same.
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 23

Regarding the remainder of the request, CAPAI will supplement this response as soon as
possible.
52. Please provide an annual breakdown of costs incurred related to low income energy
education programs including but not limited to kit costs, curriculum costs incurred
by the agencies and overall cost per participating household since the programs
began as it pertains to:
a. Customers served by Rocky Mountain Power;
b. Customers served by Idaho Power; and
c. Customers served by Avista.

RESPONSE: CAPAI restates its objections and response to the preceding request. CAPAI will
supplement this response as soon as possible.
53. Please provide the number of households completing the energy education
program funded by Rocky Mountain Power by obtaining an energy efficiency kit
and receiving the education curriculum by month through October 31, 2011.

RESPONSE: CAPAI restates its response to the preceding request.

54. Ms. Ottens states on page 22 that all kits will be distributed by year end. Will the
500 households also be provided the energy education curriculum by December 31,
2011?

RESPONSE: CAPAI is in the process of obtaining information to respond to this request and
will supplement as soon as possible.
55. How does the percent increase in Rocky Mountain Power residential rates since
1989 compare to the percent increase in low income weatherization funding?

RESPONSE: CAPAI objects to this request on the basis that RMP obviously has the requested
information.
DATED, this 25th day of November, 2011.

_______________/s/___________________
Brad M. Purdy

CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 24

CERTIFICATE OF SERVICE

I, the undersigned, hereby certify that on the 25th day of November, 2011, I served a
copy of the foregoing document on the following by electronic mail.

Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
[e-mail]

Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
[e-mail]

Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]

Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W, Washington (83702)
P0 Box 83720
Boise, ID 83720-0074
[e-mail]

Randall C. Budge
Racine, Olson, Nyc, Budge & Bailey
201 E. Center
P0 Box 1391
Pocatello, ID 83204-1391
E-Mail: [e-mail]

Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]

James R. Smith
Monsanto Company
P.O. Box 816
CAPAI RESPONSE TO ROCKY MOUNTAIN FIRST PRODUCTION REQUESTS 25

Soda Springs, ID 83276
[e-mail]

Eric L. Olsen
ASSOCIATION, INC: Racine, Olson, Nye, Budge & Bailey
(Exhibit Nos. 30 1-400) 201 E. Center
P0 Box 1391
Pocatello, ID 83204-1391
[e-mail]

Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
tony@,yankel.net

Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
[e-mail]

Ronald Williams
Williams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83702
[e-mail]

Don Schoenbeck
RCS, Inc.
900 Washington St., Suite 780
Vancouver, WA 98660
[e-mail]

Tim Buller
Agrium, Inc.
3010 Conda Rd.
Soda Springs, ID 83276
[e-mail]

DATED, this 25th day of November, 2011.

______________/s/___________________
Brad M. Purdy