20120706ICL 1-5 to PAC.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6 th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
RECEIVED
2112 Jul -6 AM 10:
iDAHO FUBU UTILITIES COMMISION
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. PAC-E-12-11
APPLICATION OF ROCKY )
MOUNTAIN POWER FOR ) FIRST PRODUCTION REQUEST OF
AUTHORITY TO DECREASE THE ) THE IDAHO CONSERVATION
CUSTOMER EFFICIENCY SERVICES ) LEAGUE TO ROCKY MOUNTAIN
RATE ) POWER
The Idaho Conservation League (ICL) through its attorney of record, Benjamin J. Otto,
requests that Rocky Mountain Power (RMP) provide the following information. On July 3, 2012,
in Order 32587, the Idaho Commission established a comment deadline of July 24, 2012. To
meet the deadline and avoid any extensions, ICL requests RMP respond by July 19, 2012.
Please provide any supporting documents, workpapers, calculations, or information
sources RIvIP relies upon to support the answers to these requests. If any responses include Excel
spreadsheets or other electronic files, please provide them with all formulas intact and activated.
This production request is ongoing and we respectfully ask RIvIP to provide additional
documents and information that may supplement any initial responses. As required by IDAPA
31.01.01.228.02, please indicate the name and phone number of the person who prepares the
response, the record holder, and the witness who can sponsor the answer at hearing if needed.
REQUEST NO. 1: Please reference Action Item 6 in Rocky Mountain Power's 2011
Integrated Resource Plan Update, submitted to the Idaho PUC on April 2, 2012.
a. Please provide all analysis or other documentation that demonstrates RMP's proposed
reduction to Schedule 191 will provide sufficient funding to acquire all cost effective energy
efficiency resources available in Idaho that may be identified by the "system-wide RFP for
residential and small commercial sector savings issued in March 2012."
ICL First Production Request to RMP 1 July 6, 2012
b.Please provide all analysis or other documentation that demonstrates RMP's proposed
reduction to Schedule 191 will provide sufficient funding to acquire all cost effective energy
efficiency resources available from special contract customers in Idaho the Company expects to
be included in the plan identified in this action item.
c.Please provide all analysis or other documentation that demonstrates RMP's proposed
reduction to Schedule 191 will provide sufficient funding to meet the "staffing levels to achieve
programmatic cost effective energy efficiency targets established in this plan."
d.Please provide all analysis or other documentation that demonstrates RMP's proposed
reduction to Schedule 191 will provide sufficient funding for the Idaho portion of the Company's
commitment to to "preform the high-level screening of 40 percent of its distribution circuits in
each of the states to identify circuits where cost effective energy savings appears viable. . . ."
REQUEST NO. 2: Please provide any analysis and documentation that demonstrates
RMP's proposed reduction to Schedule 191 will provide sufficient funding to meet the DSM
Class 2, Idaho acquisition goals indicated in Table 5.5 in Rocky Mountain Power's 2011
Integrated Resource Plan Update, submitted to the Idaho PUC on April 2, 2012.
REQUEST NO. 3.: Please provide any analysis and documentation that demonstrates
RMP's proposed reduction to Schedule 191 will provide sufficient funding to meet the DSM
action items and acquisition targets described above while reducing or eliminating the current
account back balance shown in Attachment 3 of the Application.
REQUEST NO. 4.: Please provide any analysis and documentation - including
calculations, assumptions, and any third party evaluations - that demonstrates whether RMP's
current energy efficiency programs in Idaho will remain cost effective in 2012 and 2013.
REQUEST NO 5.: Please explain, and provide any supporting analysis and
documentation, how RIvIP projects future participation levels for each energy efficiency program
available in Idaho.
Submitted this 6th day of July, 2012.
Benjamin J. Otto
Idaho Conservation League
ICL First Production Request to RMP 2 July 6, 2012
CERTIFICATE OF SERVICE
I hereby certify that on this 6th day of July, 2012, I delivered true and correct
copies of the foregoing FIRST PRODUCTION REQUEST OF ICL to the following
persons via the method of service noted:
Hand delivery:
Jean Jewell
Commission Secretary (Original and three copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Ted Weston, Manager of Idaho Regulatory Affairs
Daniel E. Solander, Senior Counsel
PacifiCorp/dba Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
[e-mail]
[e-mail] .rp..c.om
Pacificorp
Data Request Center
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]
Benjamin J. Otto
CERTIFICATE OF SERVICE 1 July 5, 2012