20100910Staff 302-317 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
RECEI
2010 SEPI 0 PH 3: 38
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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 APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES. )
)
)
)
)
CASE NO. PAC-E-IO-07
ELEVENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information on or before
MONDAY, SEPTEMBER 20, 2010.
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER SEPTEMBER 10, 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
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
IDAP A 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 302: Please provide a spreadsheet containing the following information
for each customer and each measure incented under the Energy FinAswer and FinAnswer
Express programs for 2008 and 2009 program years: Customer ID #, Customer City, Measure(s)
implemented, Energy savings, Demand reduction, Method of energy savings and demand
reduction calculation, Incentive amount, Customer investment, Measure Implementation date,
Incentive date, Invoice Date, Installation verification date.
FOR QUESTIONS 303-307 - PLEASE EXPLAIN HOW THE IDENTIFIED EXPENSES
ARE ALLOCATED OR DIRECTLY ATTRIBUTED TO IDAHO.
REQUEST NO. 303: Please provide total Rocky Mountain Power personnel-related
expenses for the Company's DSM efforts in 2008 and in 2009 in Idaho.
REQUEST NO. 304: Please provide total Rocky Mountain Power office-related
expenses for the Company's DSM efforts in 2008 and in 2009 in Idaho.
REQUEST NO. 305: Please provide total Rocky Mountain Power travel-related
program expenses for the Company's DSM efforts in 2008 and in 2009 in Idaho.
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 10, 2010
REQUEST NO. 306: Please provide total Rocky Mountain Power employee training
expenses for the Company's DSM efforts in 2008 and in 2009 in Idaho.
REQUEST NO. 307: Please provide the following:
a) A current organization char showing all Rocky Mountain Power employees, by title
and by name, for whom at least 5% of their total Rocky Mountain Power compensation is paid
with energy efficiency tariff rider funds or who spend at least 5% of their work hours on DSM.
b) Complete job descriptions, required qualifications, salary ranges, bonus opportunities,
and total compensation ranges, including benefits, for all employees identified above.
REQUEST NO. 308: Please provide the following:
a) The organization chart in effect on July 1,2009, showing all Rocky Mountain Power
employees, by title and by name, for whom at least 5% of their total Rocky Mountain Power
compensation was being paid with energy efficiency tariff rider fuds or who were spending at
least 5% of their work hours on DSM.
b) Complete job descriptions, required qualifications, salary ranges, bonus opportunities,
and total compensation ranges, including benefits, in effect on July 1,2009, for all employees
identified above.
REQUEST NO. 309: Please identify the person or persons who ultimately decide
whether or not Rocky Mountain Power wil implement, change eliminate or add new DSM
programs or measures to existing programs after Rocky Mountain Power has determined such
programs or measures wil likely be cost-effective in Idaho.
REQUEST NO. 310: Please provide a matrix showing Rocky Mountain Power's
expenditures in 2008 and in 2009 for post-implementation DSM program evaluations of impacts,
processes, market effects and cost-effectiveness in Idaho.
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 10, 2010
REQUEST NO. 311: Please provide a detailed descriptionofall changes made to all
lighting measures' cost-effectiveness assumptions and calculations in consideration of federal
standards changes.
REQUEST NO. 312: Please explain why some customers pay into the tariff rider but
are not eligible to paricipate in Company DSM incentive programs.
REQUEST NO. 313: Please explain why all programs wil be evaluated by a third-party
vendor with the exception of the Irrigation Load Control program?
REQUEST NO. 314: Please explain why the field expenses for the Irrigation Load
control program have increased so significantly in 2009.
REQUEST NO. 315: Please provide all analysis completed by or on behalf ofthe
Company relative to the implementation ofDSM measures recommended in the NWPCC's 6th
Power Plan.
REQUEST NO. 316: Please explain why the Company has not included cost-
effectiveness evaluations at the measure levèl for 2009 DSM programs as specified in Section 4
of the December 2009 DSM Evaluation MOU.
REQUEST NO. 317: Please explain the measures taken to reduce the instance of "free
ridership" relating to your Irrigation Load Control program.
'r
DATED at Boise, Idaho, this It day of September 2010.
~:r~Soo t Woodbur
Deputy Attrney General
Technical Staff: Gary Grayson/302-317
i:umisc:prodreq/paceIO.7swgg prod reql I
ELEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 10, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF SEPTEMBER 2010,
SERVED THE FOREGOING ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-1O-07, 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(fpacificorp.com
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moench(fpacificorp.com
daniel.solander(fpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(fracinelaw.net
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(fmonsanto.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyanel.net
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
E-MAIL: phickey(fhickeyevans.com
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
E-MAIL: datareguest(fpacificorp.com
KATIE IVERSON
BRUBAKER & ASSOCIATES
17244 W CORDOVA CT
SURPRISE AZ 85387
E-MAIL: kiverson(fconsultbai.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo(fracinelaw.net
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbuller(fagrium.com
jaharis(fagrium.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
PO BOX 844
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
MELINDA J DA VISON
DAVISON VAN CLEVE, P.e.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E-MAIL: mjd(fdvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
10 15 W HAYS STREET
BOISE ID 83702
E-MAIL: ron(fwiliamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmaiL.com
~~SECRETARÝ ~
CERTIFICATE OF SERVICE