20130619Staff 1-20 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 14
ISB NO. 6864
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION )
oF ROCKY MOUNTAIN POWER FOR )
AUTHORITY TO REYISE ELECTRIC SERVICE )
SCHEDULE 155 AGRICULTURAL ENERGY )SERVICES. )
)
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!fiI: tii,! tQairi. vL:a I i
ii! i,: .--
CASE NO. PAC-E.13-10
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than WEDNESDAY, JULY 3,2013.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the 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.
This Production Request is to be considered as continuing, and Rocky Mountain
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.
FIRST PRODUCTION REQUEST OF THE
STAFF TO ROCKY MOLINTAIN POWER JUNE I9,2OI3
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identifu the name, job title, location and telephone
number of the record holder. Please provide all Excel and electronic files on CD with formulas
activated.
REQUEST NO. 1: The majority of the incentive participants appear to utilize the nozzle
exchange program and the incentives for the pivot and linear equipment measures. How does
Rocky Mountain Power plan to shift the participation from these programs to the custom system
analysis program? Please provide specific details and supporting documents to explain.
REQUEST NO. 2: Please explain whether the customers that participated in the
customized system analysis had also previously participated in the prescriptive program. If so,
how many customers participated in both programs and what were the total respective incentive
payment amounts (i.e., for the prescriptive and for the custom system analysis)? Please explain.
REQUEST NO. 3: What are the current energy savings targets and inigation customer
participation goals for each of the respective programs (i.e., prescriptive and customized system
analysis)? If the requested tariff changes are approved, what would the revised irrigation energy
savings targets and customer participation goals for the customized system analysis be (i.e.,
going forward)? Please provide all relevant workpapers and calculations in Excel format with all
formulas intact.
REQUEST NO. 4: Please clarify and confirm that the list of pivot/linear upgrades and
equipment exchange elements included in Rocky Mountain Power's incentive program and
evaluated by Navigant are the same prescriptive irrigation efficiency measures that were
approved by the Regional Technical Forum (RTF) at the April 16, 2013 meeting. If these
measures are not the same, please identify and list the differences.
FIRST PRODUCTION REQUEST OF THE
STAFF TO ROCKY MOUNTAIN POWER JI.INE T9,2OI3
REQUEST NO. 5: Please describe the components included in the "sprinkler packages"
referenced on page 5 of the Application.
REQUEST NO. 6: Please provide the Idaho Irrigation Energy Savers program expenses
for 2009, 2010,2011, and2012. For each year, please provide the total expenditures, custom
project expenses, prescriptive program expenses, and evaluation expenses.
REQUEST NO. 7: Please identiff the third party contractor that administers the
Irrigation Energy Savers Program.
REQUEST NO. 8: Please provide the RFP (Request for Proposals) and all responses to
the RFP for the Idaho Irrigation Energy Savers impact evaluation.
REQUEST NO. 9: Before the publication of the Navigant impact evaluation, what was
the basis or source for the measure-level energy savings for this program?
REQUEST NO. l0: The Navigant evaluation used 1,100 as the hours of use for RMP's
irrigation efficiency measures. Please explain how the hours of use were established.
REQUEST NO. 11: Do the cost-effectiveness calculations for Rocky Mountain Power's
program include any non-energy benefits? Please explain why or why not.
REQUEST NO. 12: Does the Company believe that the evaluation expense damaged
the cost-effectiveness of the prescriptive measures? Please explain.
REQUEST NO. 13: Please explain how the evaluation costs were amortized over the
three-year study period for cost-effectiveness calculations. If the evaluation costs were
incorporated into single year's cost-effectiveness calculation, please identify the year and the
amount.
FIRST PRODUCTION REQUEST OF THE
STAFF TO ROCKY MOUNTAIN POWER JUNE I9,2OI3
REQUEST NO. 14: Please explain what caused the TRC and UCT to be much higher in
2009 than in any other year.
REQUEST NO. 15: Has the Company requested or is the Company planning to request
cancellation of the prescriptive part of its irrigation program in Utah? Please explain.
REQUEST NO. 16: Would the Company support keeping the prescriptive program
offerings based on the three-year UCT results (1.09)? Please fully explain the response.
REQUEST NO. 17: On page 8 of its evaluation, Navigant lists five recommendations
for program modification that could increase the likelihood of savings occurring as expected.
The Company's Application focuses on the recommendation to "Revise the program to... incent
only those measures which are determined to consistently reduce energy usage, and remove other
measures from the program." Did the Company consider adopting any of the other four
recommendations? Please explain which, if any, of the other recommendations the Company
will implement. If none of the other recommendations will be implemented, please explain why
not.
REQUEST NO. 18: One of Navigant's recommendations was to "Establish protocols to
ensure that installation dates are accurately captured." Please describe how the Company
currently records installation dates and how it could be improved to ensure installation dates are
accurately captured.
REQUEST NO. 19: On page 9 of its evaluation, Navigant recommended that all
measures be treated as custom (rather than prescriptive) until regionally deemed savings are back
in compliance. The Navigant evaluation was published on May 10, 2013, but the Regional
Technical Forum (RTF) approved regionally deemed savings a month earlier on April 16,2013.
Please explain why Rocky Mountain Power chose not to use the regionally deemed savings
estimates.
FIRST PRODUCTION REQUEST OF THE
STAFF TO ROCKY MOUNTAIN POWER 4 JUNE 79,2013
REQUEST NO.20: Mid-2010 progftrm changes modified energy saving estimates from
a straight prescriptive method to a semi-customized method (see page 11 of Navigant report).
Please explain what prompted this change and explain what affect this had on program cost-
effectiveness.
DATED at Boise, Idaho, tti, l4]day of June 2013.
Technical Staff: Johanna Bell: #l - 4
StaceyDonohue: #5 -20
i:umisc:prodreq/pacel3.lOnpjbsd prod reql
FIRST PRODUCTION REQUEST OF THE
STAFF TO ROCKY MOUNTAIN POWER
Deputy Attorney General
JUNE I9,2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISTH DAY oF JUNE 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-13.I0, BY E-MAILINGANDMAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWNG:
TED WESTON DANIEL E SOLANDER
ID REGULATORY AFFAIRS MANAGER SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL : ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I11
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE