20140925Staff 1-11 to PAC.pdf

NEIL pRTcE fif {1il /ilf.i
DEPUTY ATTORNEY GENERAL
rDAHo ,UBLTC UrrLrrrES C9MMTSST9N ?0lh SEP 25 PH 3: 15
PO BOX 83720
BorsE, rDAHo 83720-0074 uTtl't?ils0c ii,riissrff*[phone]
ISB NO. 6864
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR ) CASE NO. PAC-E-I4-08
AUTHORITY TO CANCEL ELECTRIC )
SERVICE SCHEDULES 115, 125 AND 155 AND ) FIRST PRODUCTION REQUEST
REPLACE WITH NEW SCHEDULE 140 WITH ) OF THE COMMISSION STAFF
CHANGES.) TO ROCKY MOUNTATN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than THURSDAY, OCTOBER 9, 2014,
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 and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as 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.
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 1 SEPTEMBER25,2OI4
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identifr the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic hles on CD with formulas activated.
REQUEST NO. l: Please provide and describe the assumptions used in Exhibit 2 to
determine the portfolio costs for the Energy Project Manager Co-funding program.
REQUEST NO. 2: For the Energy Project Manager Co-funding program, will the
customer be paid $.025/kwh of savings in addition to 100% of the manager salary and overhead?
RBQUEST NO.3: For the Energy Project Manager Co-funding program, please explain
how the Company proposes to issue payment. Will payment be issued before, during or after
project completion?
REQUEST NO. 4: Should the Energy Project Manager miss milestones and savings
goals, please describe the Company's process and policy to terminate and recover funding due to
non-performance.
REQUEST NO. 5: For calculating cost-effectiveness, are the costs for the Energy
Project Manager program assigned at the nonresidential sector-level or with a specific program?
REQUEST NO. 6: For the Energy Project Manager Co-funding, please provide the
estimated number of projects by year 2015-2017.
REQUEST NO. 7: Did the Company assume spillover savings due to the Co-Manager
program? If so, please explain how the savings were quantified.
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 2 SEPTEMBER 25 , 2OI4
REQUEST NO. 8: Please provide the analysis used to determine an average of three
percent energy savings per customer site through the Energy Management program. (Hymas
Direct, p. 9.)
REQUEST NO. 9: Please explain how the Company will separate Energy Management
savings from capital equipment project savings to avoid double counting.
REQUEST NO. 10: For the Commercial Food Service Cost-Effectiveness in Exhibit 2,
please explain the assumptions used to obtain a TRC of 108.49 in 2015, 61.65 in 2016, and 3.94
in20l7. Please explain why the 2015 and 2016 cost-effectiveness are dramatically greater than
the2017 analysis even though the Company forecasts its greatest gross KWh savings in year 3.
REQUEST NO. 11: Please explain what "EF" means. (Exhibit 2,p.1.)
DATED at Boise,Idaho, this)of September 2014.+O dav
Neil Price
Deputy Attorney General
Technical Staff: Nikki Karpavich (1-11)
i : umisc:prodreq/pace I 4. 8npnk prod req I
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP SEPTEMBER2',2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY oF SEPTEMBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
C0MMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-14.08, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY, UT 84111
E-MAIL: [e-mail]
daniel. solander@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@racifi corp. com
CERTIFICATE OF SERVICE