20141016Staff 21-31 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 121334-0318
IDAHO BAR NOS .336618370
Street Address for Express Mail:
472 W. 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.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.I4-07
SECOND 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, request that
PacifiCorp dba Rocky Mountain Power (Company; Rocky Mountain) provide the following
documents and information as soon as possible, by THURSDAY, OCTOBER 30, 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, to augment the documents produced.
Please provide answers to each question, and 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
and if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER ocroBER t6,2014
In addition to the written copies provided in response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 21: Please explain why the number of Idaho homes receiving low
income weatherization services decreased by 28% when comparing calendar year 2013 to
calendar year 2012.
REQUEST NO. 22: For calendar yeus20l2 ard20l3, please provide: (a) the average
cost per Idaho home weatherized with CAP administrative fees included, (b) the average cost per
Idaho home weatherized without CAP administrative fees included; (c) the administrative fees
paid to EICAP and SEICAA for the weatherization of Idaho homes; and (d) total dollar amount
paid to EICAP and SEICAA for weatheization of Idaho homes.
REQUEST NO.23: For calendar year 2013, please provide: (a) the number of new
energy efficiency kits ordered for EICAP and SEICAA; (b) the cost of each new kit; and (c) how
many of the 500 kits ordered to start the program are still in stock.
REQUEST NO. 24: Are the contents of the energy efficiency kits the same for each
agency? If not, please explain the reason for the variation.
REQUEST NO. 25: Has EICAP distributed all of its allocation of kits from 2010
funding?
REQUEST NO. 26: For calendar year 2013, when describing SEICAA activities and
program specifics for the Low Income Energy Conservation Program in the Annual DSM Report
(page 29), the Company stated: (a) "Number of new measures distributed: shower timers = 27,
night lights :26"; and (b) "Cost of new measures: shower timers : $2.63 each, night lights :
$2.95 each, total cost incurred of new measures purchased : $7,681 .30."
(a) Please explain in greater detail how the new measures are being used, e.g., new items
for energy efficiency kits, add-ons to existing kits already in stock, stand-alone items
to be given away.
SECOND PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER ocToBER 16,20t4
(b) What criteria is used to determine whether someone should receive a kit, a night light,
and/or a shower timer?
REQUEST NO. 27: In Calendar Year 2013, SEICAA distributed $147.71on new
measures. Given the expenditures of $7,681 for the new measures, how long does the Company
believe it will take for SEICAA to distribute the remaining inventory of night lights and shower
timers?
REQUEST NO. 28: Please provide a listing of all expenses charged to the Company's
DSM tariff rider account for 2010, 2011,2012, and 2013. Please include date, vendor, amount,
type ofexpense, and a briefdescription ofthe expense. Please separate expenses by program so
that the total amount for each program ties to amounts reported in the Annual DSM reports.
REQUEST NO. 29: Please provide the monthly interest calculations for the balance in
the DSM tariff rider account for 2010-2013.
REQUEST NO.30: Please provide a listing of all legal and consulting fees, including
but not limited to EM&V, charged to the Idaho DSM tariff rider during 2010-2013. If any of the
fees were allocated among jurisdictions, please provide the calculation of the allocation,
REQUEST NO.3l: Please provide a listing of all projects in which an incentive of
greater than $10,000 was paid.
Dated at Boise, Idaho, this f bbb^rof October 2014.
Technical Staff: Curtis Thaden/21-27
Donn English/28-31
i :umisc:prodreq/pace I 4.Tdhdjhct prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER ocroBER 16,20t4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY oF OCTOBER 2014,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-14-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84I I1
E-MAIL: [e-mail]
daniel. solander@nacifi corp.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 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@pacifi corp. 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
j im.r. [e-mail]
CERTIFICATE OF SERVICE