20100513Staff 1-9 to PAC.pdf

KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEtVEO
2918 MAY 13 PM I: 52
iDAH:O F',\JE:Ltc;, ".t.."" ~_l
uTiUTiES COMMISS¡Oi~
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN ' )
POWER FOR AN INCREASE TO THE )
CUSTOMER EFFICIENCY SERVICES RATE. )
)
)
)
)
)
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CASE NO. PAC-E-I0-03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain
Power (Company; Rocky Mountain) provide the following documents and information on or
before THURSDAY, MAY 27, 2010.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil 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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MAY 13,2010
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.
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 provide the Company's rationale for exempting its special
contract customers from Schedule 191?
REQUEST NO.2: Does the Company currently offer programs fuded through
Schedule 191 that special contract customers cando paricipate in?
REQUEST NO.3: Are any customer classes that currently provide funding through
Schedule 191 unable to paricipate in the Company's program offerings? If so, why?
REQUEST NO.4: Do non-paricipants benefit from DSM programs? If so, should they
pay into the DSM rider fund? If not, please explain.
REQUEST NO.5: Please provide a breakdown of the operating expenditures associated
with the Irrigation Load Control Program that are being recovered through Schedule 191. Please
provide this information for 2008 and 2009 separately.
REQUEST NO.6: Does the Company believe it wil reach a plateau in paricipation for
the Irrgation Load Control Program, and if so, when does the Company anticipate this to occur?
REQUEST NO.7: Should the equipment and administrative costs associated with the
Irrigation Load Control Program decline from 2008 as participation reaches a saturation point
(given 2008 as the transition year to the dispatchable program)? Please explain.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 13,2010
REQUEST NO.8: Does the Company plan to add measures that were identified in the
Northwest Council's DRAFT 6th Power Plan? If yes, which measures will be included and how
wil that affect incentives and overall DSM budget?
REQUEST NO.9: For each year beginning in 2006, please provide a table showing
Schedule 191 revenues collected by customer schedule number and the corresponding dollar
amounts of Rocky Mountain's energy effciency costs and estimated demand and energy
savings. (Please note that Tables 16-21 in the Company's 2009 DSM Report do not show
specific rate schedules and have several ilegible components.)
Dated at Boise, Idaho, this /3!b day of May.
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Kri 1iA. Sasser
Deputy Attorney General
Technical Staff: Bryan Lanspery/l, 2, 3, 4, 6, 7
Gary Grayson/5, 8, 9
i:umisc:prodreq/pace I O.3ksblgg prod req I.doc
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MAY 13,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH OF MAY 2010, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-IO-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston(ßpacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datareguest(fpacificorp.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(ßyankel.net
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solander(ßpacificorp.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo(ßracinelaw.net
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
~~
SECRET iilY
CERTIFICATE OF SERVICE