20151209Staff 1-11 to PAC.pdf

DAPHNE HUANG !19 c li i \' li D
DEPUTY ATTORNEYS GENERAL
rDAHo puBlrc urrlrrrEs coMMrssroN ?0li OtC -9 pll l: 06
PO BOX 83720 lllAt"{ri irii;,j"ii.}BOISE, IDAHO 83720-0074 UTILITIE$ COI,{MISSIOI'J
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER COMPANY'S ) CASE NO. PAC-E-15-14
APPLICATION FOR AUTHORITY TO CANCEL)
ELECTRTC SERVICE SCHEDULE NO. 71 - ) FIRST PRODUCTION
ENERGY EXCHANGE PROGRAM. ) REQUEST OF THE) coMMrssroN STAFF To
) ROCKY MOUNTAIN POWER
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Rocky Mountain Power (Company;
Rocky Mountain; PacifiCorp) provide the following documents and information as soon as
possible, by FRIDAY, DECEMBER 18,2015.r
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
t Staff is requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at (208) 334-03 I 8.
FIRST PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER I DECEMBER 9,2015
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: If Schedule 71 is canceled, are there other emergency demand
reduction programs in place in the event of a future crisis? Please explain.
REQUEST NO. 2: How many customers currently qualify to participate in Schedule
7t?
REQUEST NO.3: Page 3 of the Company's Application says, "since 2010 there have
been no curtailment events offered." It also says there was no one signed up for the program
since 2008. Please explain why no events were offered since 2010.
REQUEST NO. 4: When was the last curtailment event offered where customers
participated? What was the system savings on a per participant basis? How many similar events
could have been offered since 2008 if participants were enrolled in the program?
REQUEST NO. 5: Please provide a table showing the Hourly Credit Rate, Hourly
Credit, and the Exchange Credit to each customer for each curtailment exchange event.
REQUEST NO. 6: Please explain how customers were solicited for participation in
Schedule 71.
REQUEST NO. 7: Please provide the annual cost of the curtailment module and Energy
Profiler Online energy management product.
REQUEST NO. 8: Please provide the cost of the new Energy Profiler Online (EPO)
management product with and without the curtailment module proposed by Schneider Electric.
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER DECEMBER 9,2015
REQUEST NO. 9: Please provide the total amount of program cost savings if Schedule
7l is eliminated.
REQUEST NO. 10: The Company has proposed removing the load curtailment module
to save costs. Are there other current or future uses for which the load curtailment module would
be useful?
REQUEST NO. 1l: Please provide a copy of the Energy Exchange contract signed by
customers.
Dated at Boise, Idaho, this qfh day of December 2015.
Technical Staff: Mark Rogers (l-2, 5,7 -8)
Mike Louis (3-4,9)
Stacey Donohue (6, 10-11)
i:umisc:prodreq/pacel5. l4djhmldesdmr prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER 9,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9th DAY OF DECEMBER 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
C0MMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE
NO. PAC.E.15-I4, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
ID REG AFFATRS MANAGER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi com. com
YVONNE HOGLE
ASSISTANT GENERAL COUNSEL
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE