20240329Staff 19-23 to PAC.pdf

RBCHtED
Friday,Nkdi 29,20242.28:55 PM
IDAHOPUB IC
UTILITIES C T\/MSRON
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN ) CASE NO. PAC-E-24-02
POWER'S APPLICATION FOR APPROVAL )
OF ADJUSTMENTS TO THE IRRIGATION )
LOAD CONTROL PROGRAM ) SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Rocky Mountain Power("Company")
provide the following documents and information as soon as possible, but no later than
FRIDAY, APRIL 12, 2024.1
This Production Request is to be considered as 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 or information produced.
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
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0318.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MARCH 29, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 19: In response to Production Request No. 1, the Company states that
the Base and Bonus Incentive Rates are increased by 2.5% each year to reflect inflation. Within
the same response, the Company doubles the Voluntary Event Energy Reduction Payment
("ERP") for inflationary reasons and maintains the Mandatory Event ERP from the previous
contract value. Please answer the following:
a. Please explain why it is not appropriate to account for inflation in the Mandatory
Event ERP; and
b. Please explain the rationale supporting the difference in methods of accounting
for inflation between the Base and Bonus Incentive Rate and the Voluntary Event
ERP.
REQUEST NO. 20: Please explain why the Company uses 2.5% as the inflation
adjustment factor when the 2023 IRP suggests an inflation factor of 2.27%.
REQUEST NO. 21: Please describe any other energy efficiency and demand response
incentives the Company offers that are incremented annually or in a manner similar to the
proposed incentive structure.
REQUEST NO. 22: In response to regular IRP updates to avoided costs, please explain
if the Company expects to update the Irrigation Load Control program benefit value, incentives,
and cost-effectiveness calculations.
REQUEST NO. 23: Please provide Excel workpapers supporting the estimates provided
in Table 3 of the Application. Specifically,please show how the calculations are based on the
proposed contract pricing shown in Exhibit B and detail the assumed Weekly Average Available
Load Reduction.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MARCH 29, 2024

DATED at Boise, Idaho, this 29"'day of March 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-02 PR#2.docx
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MARCH 29, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS Zy�DAY OF 2024,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-
24-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
MICHAEL SNOW ROCKY MOUNTAIN POWER
ROCKY MOUNTAIN POWER 825 NE MULTNOMAH ST
1407 WEST NORTH TEMPLE STE 330 STE 2000
SALT LAKE CITY UT 84116 PORTLAND OR 97232
E-MAIL: [e-mail] E-MAIL: joseph.dallas ,pacificorp.com
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance(-,ae iisinsi t.com
E-MAIL: elo(a),echohawk.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE