20110811Staff 1-7 to PAC.pdf

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
Attorney for the Commission Staff
RECEIVED
1011 AUG II PM 12= 02
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAIN
POWER TO SUSPEND FUTURE PROGRAM
EVALUATIONS OF SCHEDULE 21, LOW
INCOME WEATHERIZATION SERVICES
OPTIONAL FOR INCOME QUALIFYING
CUSTOMERS
)
) CASE NO. PAC-E-l1-13
)
) FIRST 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,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information on or before
THURSDAY, SEPTEMBER 1,2011.
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 preparng the document, and the name, location and phone number of the record holder
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 1 AUGUST 11,2011
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.1: Please provide a narative explanation of the Company's cost-
effectiveness methodology.
REQUEST NO.2: Please provide an Excel spreadsheet that presents the Company's
cost effectiveness calculations for each measure in the Low Income Weatherization Program.
This Excel spreadsheet should include avoided cost dollar amounts and load shapes, as well as
all formulas and sources. In addition, it should include calculations and formulas for each of the
five cost-effectiveness tests referenced in the Application and correspond to the narative
referenced in Request NO.1 (above). The spreadsheet should be executable with formulas intact. '
REQUEST NO.3: Please explain how the cost-effectiveness ratios for each measure are
combined to achieve the total program cost-effectiveness for each of the five cost-effectiveness
tests referenced in the Application.
REQUEST NO.4: Please provide the energy savings and the method used to identify
those savings for each measure in the Low Income Weatherization Program.
REQUEST NO.5: Please describe in detail how the Company exercises oversight over
this program.
REQUEST NO.6: Does the Company independently verify installation of measures
through on-site audits? Does the Company independently verify pre-installation conditions
through on-side audits? Please explain.
REQUEST NO.7: Does the Company independently calculate the energy savings
associated with installation of each measure? If not, please explain.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 2 AUGUST 11,2011
DATED at Boise, Idaho, this \ \ & day of August 2011.
~o-.Nlfe
Deputy Attorney General
Technical Staff: Stacey Donohue/l-7
i:umisc:prodreq/pacel 1. 13npsd prod reqI
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 3 AUGUST 11,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF AUGUST 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-II-13, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MGR
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston(ipacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solander(ipacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datarequest(ipacificorp.com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ihotmail.com
, ~~~
SECRETAR
CERTIFICATE OF SERVICE