20131202Staff 1-6 to PAC.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO.3283
Street Address for Express Mail:
472W. WASHNGTON
BOISE, IDAHO 83702.5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
oF ROCKY MOUNTATN POWER FOR ) CASE NO. PAC-E-13-15
APPROVAL OF A CUSTOMER CREDIT TO )
REX'UND OVER-COLLECTION OF )
CUSTOMER EFFICIENCY SERVICES RATE. ) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) ROCKY MOUNTAIN POWER
)
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Weldon Stutzman, Deputy Attorney General, that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, by MONDAY, DECEMBER 23,2013.
This Production Request is continuing, and the Company 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
person preparing the document, and the name, location and phone number of the record holder
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER2,2OI3
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01 .0t.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 retail customers who received service between
October 1,2012 through September 30,2013, but are no longer customers as of February 1,
2014, will not receive the one-time credit refund.
REQUEST NO.2: How many retail customers received service between October 1,
2012 through September 30, 2013, but were no longer customers of the Company as of
December 1,2013?
REQUEST NO. 3: What is the aggregate amount of Schedule 191 charges paid by those
customers indentified in response to Production Request No. 2?
REQUEST NO. 4: If all retail customers who received service between October 1,2012
through September 30,2013 (regardless of whether they are current customers), were issued a
credit, approximately what amount would each customer get?
REQUEST NO. 5: Will customers that moved from one location to another within the
Company's service territory between October 1,2012 through September 30,2013, receive a
refund based on all Schedule 191 charges that they paid during that time period? Please explain.
REQUEST NO. 6: Please explain why the Company requests to issue a new Electric
Service Schedule 95 rather than issue credits backed by a Commission Order.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBERZ,2OI3
Dated at Boise, Idaho, Uisrfiaay of December 2013.
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Curtis Thaden
i:umisc:prodreq/pace 13. I 5wsct prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER2,2OI3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY oF DECEMBER 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF' THE
CoMMISSION STArF TO ROCKY MOUNTAIN POWER, N CASE NO.
PAC-E-13.I5, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
TED WESTON DANIEL E SOLANDER
ID REGULATORY AFFAIRS MANAGER SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I11
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@fracifi corp. c om
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I11
E-MAIL : daniel. solander@J'acifi corp.com
CERTIFICATE OF SERVICE