20240913Staff 1-10 to PAC.pdf

RECEIVED
Friday, September 13, 2024 10:17:48 AM
IDAHO PUBLIC
UTILITIES COMMISSION
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
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 )
POWER'S APPLICATION FOR A ) CASE NO. PAC-E-24-10
PRUDENCY DETERMINATION OF ITS )
DEMAND SIDE MANAGEMENT EXPENSES )
INCURRED IN 2022 AND 2023 ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power, a division of
PacifiCorp ("Company")provide the following documents and information as soon as possible,
but no later than FRIDAY, OCTOBER 4, 2024.
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
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 13, 2024

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. 1: Please provide a list of all expenses charged to the Company's
Demand Side Management("DSM") tariff rider account for years 2022 and 2023. Please
include date, vendor, amount, type of expense, and a brief description of the expense. Please
separate expenses by program so that the total amount for each program ties to the amounts
reported in the Annual DSM reports.
REQUEST NO. 2: Please provide the monthly interest calculations for the balance in
the DSM tariff rider account for 2022-2023.
REQUEST NO. 3: Please provide the tariff rider revenue by month and by customer
class for 2022-2023.
REQUEST NO. 4: Please provide a listing of all legal and consulting fees, including,
but not limited to Evaluation, Measurement and Verification(`BM&V"), charged to the Idaho
DSM tariff rider during 2022 and 2023. If any of the fees were allocated among jurisdictions,
please provide the calculation and explanation of the allocation.
REQUEST NO. 5: Please provide the amount of labor expense charged to the DSM
tariff rider for the years 2022 and 2023. For each of those years, please also include the number
of Full Time Equivalents funded by the rider. Please also provide the general wage adjustment
percentage for non-union personnel approved by the Compensation Committee of the Board of
Directors for each year.
REQUEST NO. 6: Please provide a current organizational chart by title and name
showing all Rocky Mountain Power and contract employees who charge time to the DSM rider.
Please include complete job descriptions, required qualifications, salary ranges,bonus
opportunities, and total compensation ranges, including benefits, for all employees identified in
this request.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 13, 2024

REQUEST NO. 7: Please provide copies of all internal audit reports referencing any of
the Company's DSM expenses and processes for 2022 to current date. If no reports were issued,
please provide the date and scope of the audit and all internal auditor workpapers.
REQUEST NO. 8: Please provide invoices for all third-party evaluators for 2022 and
2023. Please describe how those costs were allocated among jurisdictions.
REQUEST NO. 9: Please provide the cost-effectiveness workpapers and calculations
for all DSM programs for years 2022 and 2023 in Excel format.
REQUEST NO. 10: Please provide detailed dispatch data of each of the Company's
demand response programs for years 2022 and 2023. This includes, but is not limited to the
following:
a. the date and time for each initiated event;
b. the amount of demand saved in megawatts for each event hour;
c. the amount of energy saved in megawatt-hours for each event hour; the value of
demand saved in each event hour;
d. the program cost for demand saved in each event hour;
e. the value and cost of energy saved in each event hour;
f. the corresponding market price of energy for each event hour;
g. a breakdown of incentives paid to each participant by event;
h. any event adjustment for participant opt-outs; and
i. any event adjustments for non-participation.
DATED at Boise, Idaho, this 13t" day of September 2024.
Dayn Hardie
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-10 PR#l.docx
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 13, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF SEPTEMBER
2024, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
10, 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: mark.alder@,pacificorp.com E-MAIL: joseph.dallas&acificorp.com
michael.snow&acificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest()pacificorp.com
PA RICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE