20101021CAPAI 1-5 to PAC.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdyßhotmail.com
Attorney for Petitioner
Community Action Parnership
Association of Idaho
RECEl\1
2018 OCT 2 I AM II: 31;
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
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) CASE NO. PAC-E-IO-07
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COMMUNITY ACTION
PARTNERSHIP ASSOCIA-
TION'S FIRST PRODUCTION
REQUESTS TO ROCKY
MOUNTAIN POWER
The Community Action Parnership Association of Idaho (CAP AI), by and through its
attorney of record, Brad M. Purdy, requests that Rocky Mountain Power provide the following
documents and information pursuant to the Commission's scheduling order previously issued in
this case.
Pursuant to IDAPA 31.01.01.228, please include the name(s) ofthe person(s) who wil be
able to answer questions about or sponsor the Company's responses to these Requests at hearng.
As a courtesy, Rocky Mountain Power is requested to fuher provide the job title of said
person(s).
This Production Request is to be considered as continuing, and Rocky Mountain Power is
hereby requested to provide, by way of supplementar responses, additional documents that it or
any person acting on its behalf may later obtain that wil augment the documents produced.
1
CAP AI FIRST PRODUCTION REQUEST TO ROCKY MOUNTAI POWER
REQUEST NO.1: Regarding Rocky Mountain Power's (RM) proposal to increase
Schedule 36 residential time of use rates more than the proposed increase to the general
residential class, Schedule 1, what does RM believe is the reason that its cost of service study
justifies a need to increase Schedule 36 rates more than Schedule 1?
In responding to the foregoing request, please explain all cost "drvers" that RM
believes causes the cost of service model to conclude that Schedule 36 rates
should receive a proportionately higher rate increase.
REQUEST NO.2: Does RMP possess data showing what proportion of Schedule 36
customers are "low-income" as that term is defined under LllEAP, for puroses ofthe
Company's Low-Income Weatherization Assistance Program, or any other definition the
Company relies upon? In answering this request, please indicate what definition of "low-
income" you are utilizing, identify what said "data" is, how the Company came to possess it, and
what percentage of Schedule 36 customers are "low-income?"
REQUEST NO.3: Regarding Rocky Mountain Power's Low-Income Weatherization
Assistance program, it appears that the Company is not proposing any increase to funding for
this program. Is there a specific rationale for not proposing such an increase in fuding and, if
so, what is that rationale?
REQUEST NO.4: Please provide the level of funding ofRM's Low-Income
Weatherization Assistance program for each of the past twelve (12) years and the percentage of
rate increases granted by the Idaho Public Utilities Commission to RMP, as the result of a
general rate case filing, during that same twelve (12) year period.
2
CAP AI FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER
REQUEST NO.5: It appears that RMP is not proposing an increase to its existing
Conservation Education Program. Is there a specific rationale for not proposing such an increas~
in funding and, if so, please state what that rationale is.
DATED, this 8th day of October, 2010,
Brad M. Purdy
3
CAP AI FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on the 8th day of October, 2010, I served a copy of
the foregoing document on the following by email and U.S. mail, first class postage.
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
ted. westonßYacificorp .com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Ave., Suite 700
Box 467
Cheyenne, Wyoming, 82003
Mark Moench
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
danieL. solanderßYacificorp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Tim Buller
Agrum, Inc.
3010 Conda Rd.
Soda Springs, ID 83276
TBuller(fagrum.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
botto(fidahoconservation.org
Don Reading
6070 Hil Rd.
Boise, ID 83703
dreadingêmindspring.com
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CAPAI FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER
Melinda J. Davison
Davison Van Cleve, P.C.
333 S.W. Taylor, Suite 400
Portland, OR 97204
Ronald L. Wiliams
Wiliams Bradbur, P.C.
1015 Hays St.
Boise, ID 83702
Eric L. Olsen
Racine, Olson, et al
201 E. Center
Pocatello, ID 83201
eloßYracinelaw.net
Anthony Yanel
29814 Lake Rd.
. Bay Village, OH 44140
tonyßYyanel.net
Randall C. Budge
Racine, Olson, et al
201 E. Center
Pocatello, ID 83201
rcbtfracinelaw.net
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, ID 83276
Jim.r.smithtfmonsanto.com
DATED, this 8th day of October, 2010
Brad M. Purdy
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CAP AI FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER