20161123Staff 1-11 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
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.! .. : ·'CMM ISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR PRUDENCY DETERMINATION )
OF DEMAND-SIDE MANAGEMENT )
EXPENDITURES. )
)
)
) ___________________ )
CASE NO. PAC-E-16-14
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
Brandon Karpen, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
DECEMBER 14, 2016.
This Production Request is to be considered as continuing, and Rocky Mountain Power 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 or information
produced.
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 identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER NOVEMBER 23 , 2016
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a listing of all expenses charged to the Company's
DSM tariff rider account for 2014 and 2015. Please include date, vendor, amount, type of
expense, and a brief description of the expense. Please separate expenses by program so that the
total amount for each program ties to the amounts reported in the Annual DSM reports.
REQUEST NO. 2: Please provide the monthly interest calculations for the balance in
the DSM tariff rider account for 2014-2015.
REQUEST NO. 3: Please provide the tariff rider revenue by year and by customer class
for 2014-2015.
REQUEST NO. 4: Please provide the cost-effectiveness workpapers and calculations
for all DSM programs, including demand response, by year (2014-2015) in excel format with
formulas intact and all assumptions clearly defined.
REQUEST NO. 5: Please provide a listing of all legal and consulting fees, including,
but not limited to EM&V, charged to the Idaho DSM tariff rider during 2014 and 2015. If any of
the fees were allocated among jurisdictions, please provide the calculation and justification of the
allocation.
REQUEST NO. 6: Please provide a listing of all projects in which an incentive of
greater than $10,000 was paid during 2014 and 2015. Please include a detailed description of
each project.
REQUEST NO. 7: Please compare the Company's acquired annual class 2 DSM
savings by program and sector with targets from the IRP and conservation potential assessment
for 2014-2015. If the Company did not achieve its targets, please explain why.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 23, 2016
REQUEST NO. 8: Please describe how common costs are allocated among the
jurisdictions.
REQUEST NO. 9: Please provide the amount of labor expense charged to the DSM
tariff rider for the years 2010-2015. For each of those years, please also include the number of
Full Time Equivalents funded by the rider. Please also provide the general wage adjustment
percentage for non-union personnel approved by the Compensation Committee of the Board of
Directors for each year.
REQUEST NO. 10: Please explain the significant differences in the costs per household
served under the Low Income Energy Conservation Education Program for Eastern Idaho
Community Action Partnership and Southeastern Idaho Community Action Agency. How were
the measures chosen for each of the Community Action Partners?
REQUEST NO. 11: Was an evaluation performed by a third party evaluator on the Peak
Reduction Programs? If so, please provide the most recent evaluation. If not, please provide a
schedule as to when the Company plans to have the program evaluated.
)
DATED at Boise, Idaho, this 2.}Y-day of November 2016.
Technical Staff: Donn English (1-9)
Barbara Romano (10-11)
i:umisc:prodreq/pacel6.14bkdesdbrjk prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 23, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23rd DAY OF NOVEMBER 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-16-14,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
DANIELE SOLANDER
MICHAEL SNOW
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted. weston@pacifi corp. com
daniel [e-mail]
[e-mail]
DAT A REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp. com
·~@~
SECRE ARY
CERTIFICATE OF SERVICE