20120628Staff 1-5 to PAC.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 3283
RECEIVED
7012 JUN 28 1M 2 01
tDAHC' PUL
UTIIJTE5C,SSION
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 ROCKY MOUNTAIN POWER FOR
AUTHORITY TO DECREASE THE
CUSTOMER EFFICIENCY SERVICES RATE
CASE NO. PAC-E-12-11
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Weldon Stutzman, Deputy Attorney General, requests that Rocky Mountain Power (Company;
Rocky Mountain) provide the following documents and information on or before
THURSDAY, JULY 19, 2012.
This Production Request is continuing, and Rocky Mountain 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 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 JUNE 28, 2012
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 explain why Company expenditures for the residential Home
Energy Savings program dramatically increased by 120% from 2009-2010, then decreased by
53% from 2010-2011.
REQUEST NO. 2: Please report projected funding, participation, energy savings, and
cost effectiveness (yearly basis and program life) for each DSM program in 2012 and 2013.
Please provide the amount of incentives provided in each DSM program in 2011 and the amount
projected separately in 2012 and 2013.
REQUEST NO. 3: The Company states that "the projected residential program funding
of approximately $1.2 million is consistent with previous levels" (pg. 5). Please detail the
Company's projected expenditures for residential, commercial, industrial, and irrigation
programs separately for 2012 and 2013.
REQUEST NO. 4: Please provide all attachments and exhibits in electronic format with
all formulas intact.
REQUEST NO. 5: Please provide a copy of the most recent conservation potential
study performed for Rocky Mountain Power.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JUNE 28, 2012
Dated at Boise, Idaho, this day of June 2012.
We! on B. Stutzman
1) Deputy Attorney General
Technical Staff: Nikki Karpavich/1 -3
Donn English/4-5
i:umisc:prodreq/pacel2. 11 wsnkde prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JUNE 28, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF JUNE 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-12-11, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 SMAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83702
E-MAIL: botto(idahoconservation.org
u1 SECRETARY/
CERTIFICATE OF SERVICE