20241119Staff 11-15 to PAC.pdf

RECEIVED
Tuesday, November 19, 2024 1:22:54 PM
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 ) 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,
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 TUESDAY, DECEMBER 10, 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.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 NOVEMBER 19, 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. 11: Page 6 of the 2023 Annual Report states that the Company is
working to diversify program participation for the HVAC and Whole Building measure. Please
describe the updates that the Company is considering for these measures.
REQUEST NO. 12: Please describe any updates made to Engine Block Heater measure
described in the Company's 2023 Annual Report at 6.
REQUEST NO. 13: Please answer the following questions regarding the 2021-2022
Idaho Wattsmart Homes Program Evaluation Measurement&Verification Report on the Whole
Building and Whole Home programs:
a. Please describe the data source(s)used to provide the measure library reference
documents for each program.
b. Please describe the data source(s)used to provide program tracking data and claimed
savings for each program.
c. Please clarify how REM/Rate output files are used in each program and in the impact
evaluation as "Inputs to Evaluated Savings."
d. Please clarify how Ekotrope outputs are used in each program and in the impact
evaluation.
e. Please clarify if the evaluation utilized billing data to evaluate actual savings. If not,
why not?
f. Please provide a list detailing if and what amount(i.e., number of months) of billing
data was available at the time the evaluation was initiated for each Whole Building
and Whole Home participant who was issued an incentive in PY2021 and 2022.
g. Please explain if the Company has conducted any internal analysis of the Whole
Building and Whole Home programs using billing data from the incentivized
constructions. If yes,please provide analysis. If not, why not?
h. Please explain if the REM/Rate modeling documentation supporting the Whole
Building and Whole Home incentives provides details on what types of upgrades are
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 19, 2024

being selected to meet energy savings targets. If so, provide a breakdown of upgrade
types selected by participants for the 2021 and 2022 program years.
REQUEST NO. 14: On page 14 of its Annual Report, the Company explains that the
Company's Wattsmart batteries program passes the Utility Cost Test using a 20-year Net Present
Value ("NPV"). Please answer the following:
a. Please explain the minimum number of years that are needed before the cumulative
NPV of the program becomes cost-effective.
b. Please provide the first year in which the program is expected to become cost-
effective using a single year NPV.
c. Please describe the assumed measure life of the program.
d. Please describe the types of dispatch the program can call and the associated avoided
cost value streams captured by each dispatch type.
e. Please explain how many events of each dispatch type the program has experienced
year to date. If a dispatch type has had no events, please explain the conditions that
are expected to result in that type of event.
REQUEST NO. 15: Please provide copies of all invoices and other supporting
documentation, such as contracts, incentive requests, approvals, and calculations for the
expenses charged to the Demand Side Management listed on Confidential Attachment A.
DATED at Boise, Idaho, this 19th day of November 2024.
ayn H ie
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-10 PR#2.docx
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 19, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS jqi�DAY OF NOVEMBER
2024, SERVED THE FOREGOING SECOND 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.alderkpacificorp.com E-MAIL: joseph.dallasgpacificorp.com
michael.snowkpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestkl2acifi core.com
i
r
T ICIA JORDA SECRETARY
CERTIFICATE OF SERVICE