20140917Staff 1-20 to PAC.pdf

DONALD L. HOWELL, il
DAPHNE HUANG
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 r2t334-03 18
IDAHO BAR NOS .336618370
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-59t8
Attorneys for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER REQUESTING A
PRUDENCY DETERMINATION ON ITS
DEMAND.SIDE MANAGEMENT
EXPENDITURES FOR YEARS 2010.2013.
r."r ll /d\ r.ll r i / ,..
I l;V$-i | (. ..i
20lri SIP l7 Pl,f 2: l8
rh l I !,i. *,1: .:
lg, tl (v t !:--r, ./
uT iLlTl Is c$l,t |!.1 iss lci;
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.I4.O1
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Donald L. Howell and Daphne Huang, Deputy Attorneys General, that PacifiCorp dba
Rocky Mountain Power (Company; Rocky Mountain) provide the following documents and
information as soon as possible, by WEDNESDAY, OCTOBER 1,2014.
This Production Request is continuing, and the Company is 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.
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
person preparing the document, and the name, location and phone number of the record holder
STAFF COMMENTS SEPTEMBER 17,2014
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.0t.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please submit a list of all DSM measures offered, by year (2010-
2013) and program, and include individual measure level cost-effectiveness, incentive amount
offered, all inputs and assumptions, and how savings were determined. If an individual measure
was not cost-effective in any year (2010-2013), but the Company offered the incentive, please
explain why the Company offered that measure.
REQUEST NO.2: Please provide the cost-effectiveness workpapers and calculations
for all DSM programs, including demand response, by year (2010-2013) in excel format with
formulas intact and all assumptions clearly defined.
REQUEST NO.3: Please compare the Company's acquired annual class 2 DSM
savings by program and sector with its targets from the IRP and conservation potential
assessment (both technical and achievable technical potential) from 2010-2013. If the Company
did not achieve its targets, please explain why.
REQUEST NO. 4: Please provide the analysis used to determine that participation in
NEEA was not cost effective. If participation was cost effective, why did RMP choose not to
participate?
REQUEST NO. 5: Have any Office of Energy Resources projects been funded through
the Rider or claimed as annual savings from 2010-2013? Please explain.
REQUEST NO. 6: Please provide RMP's Idaho DSM marketing plans and budget for
2010-2013 for all programs fully or partially funded through the Rider.
STAFF COMMENTS SEPTEMBEP. 17 ,2014
REQUEST NO. 7: Please list all marketing expenses incurred by RMP for DSM
programs and measures booked to the fuder by year and program 2010-2013. Please include the
date, amount, vendor, and a brief description of the marketing materials. Please identify any of
these expenses that were not booked to the DSM tariff rider.
REQUEST NO. 8: Please provide copies of all Company-developed DSM marketing
and outreach materials funded by the Rider (by year and program) from 2010-2013 including,
but not limited to, print, bill stuffers, bill boards, TV advertisements, radio spots, digital ads,
YouTubeiVimeo videos, social media, etc. Electronic links are acceptable. How many
customers viewed or received the materials? Please include the frequency in which the
marketing materials ran.
REQUEST NO. 9: Please provide copies of any additional DSM marketing and
outreach materials that were not developed by the Company in-house, but were promoted to
RMP customers.
REQUEST NO. 10: For each year 2010-2013, please provide: a) an organization chart
showing all Rocky Mountain Power employees, by title and by name, for whom at least 5o/o of
their total Rocky Mountain Power compensation is paid with energy efficiency tariff rider funds
or who spend at least 5% of their work hours on DSM issues; b) complete job descriptions for all
employees identified above.
REQUEST NO. 1l: For each year 2010-2013, please provide a list of all contracted
services paid through the Rider by program. Please provide the contractor name and describe the
work completed, the amount paid and the contract dates.
REQUEST NO. 12: Please provide the total RMP employee training expenses charged
to the Rider for each year 2010-2013.
STAFF COMMENTS SEPTEMBER 17,2014
REQUEST NO. 13: Please provide a list of measures the Company offers in its Utah
service territory, but not Idaho in 2013. Please separate by residential, commercial, industrial,
and agricultural. Please explain why those measures, if any, are not offered in Idaho.
REQUEST NO. 14: For each energy efficiency program, please describe or provide the
Company's eligibility requirements to participate in each program. Please explain how the
Company verifies that participants are in compliance with each requirement.
REQUEST NO. 15: Please provide Company Exhibit No. 2 in an executable excel file
with formulas intact.
REQUEST NO. 16: Please describe the type, cost, content, and location of all
commercial/industrial DSM trainings offered for Idaho customers.
REQUEST NO. 17: Please explain the criteria and process used to qualify an approved
business for the FinAnswer Express and Energy FinAnswer programs.
REQUEST NO. 18: Please explain how the Company markets its Energy FinAnswer
program "through its Customer and Community Managers and network of trade allies in concert
with the FinAnswer Express program." (2010 DSM Annual Report, p.24.)
REQUEST NO. 19: In Appendix 4 of the 2012 DSM Report, the Company states 100%
of the pre- and post-installation site inspections for lighting and non-lighting projects were
completed on projects that had incentives over a specified dollar amount. Please provide the
minimum dollar amount and the number of projects. How many projects were not inspected?
REQUEST NO. 20: Please explain the purpose of an approved vendor list for the
Energy FinAnswer program when participants are not required to use it (2013 DSM Annual
Report, p. 33). Please provide the amount of projects completed by non-approved vendors
versus approved vendors by year.
STAFF COMMENTS SEPTEMBERIT,2OI4
Dated at Boise, Idaho, this [?yo^rof Septemb er2014.
Technical Staff: Nikki Karpavich
i:umisc:prodreq/pace l4.Tdhdjhnk prod req I
STAFF COMMENTS SEPTEMBER 17,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITTH DAY oF SEPTEMBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E.14-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
TED WESTON
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84I11
E-MAIL: ted.weston@pacifi corp.com
daniel. solander@pacifi com.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE TD 83702
E-MAIL: [e-mail]
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL : [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@paci fi com. com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX l39l
POCATELLO ID 83204
E-MAIL : [e-mail]
E.MAIL ONLY
JAMES R SMITH
MONSANTO COMPANY
i im.r. [e-mail]
CERTIFICATE OF SERVICE