20161222Staff 12-25 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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ZO i DEC 22 AM 11: 08
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'. it • f ·.-. r:o:.{MISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP OBA ROCKY MOUNTAIN )
POWER FOR PRUDENCY DETERMINATION )
OF DEMAND-SIDE MANAGEMENT )
EXPENDITURES. )
)
)
) ___________________ )
CASE NO. PAC-E-16-14
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than THURSDAY,
JANUARY 12, 2017.
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.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER 22, 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. 12: Please provide a breakdown of the number, and type of dwellings
weatherized using Rocky Mountain funds for Program Years 2012-2015. (Ex. Single Family,
Mobile, Multifamily)
REQUEST NO. 13: Please provide a detailed explanation of how Rocky Mountain
determines whether expenses for the Low Income Weatherization Program are prudent?
REQUEST NO. 14: Please provide any reference material that Rocky Mountain uses to
estimate the energy savings for individual measures installed in a participant's home under the
weatherization program.
REQUEST NO. 15: What documentation does Rocky Mountain receive from EICAP
and SEICAA to determine which specific measures are paid for with utility funds under the
weatherization program?
REQUEST NO. 16: Please provide, or make available, the EA5 audit reports, Job Order
Sheets, and invoices for each Idaho unit completed during the 2013, 2014, and 2015 program
years.
REQUEST NO. 17: Please provide any quality assurance or inspection documentation
Rocky Mountain collects, or receives, regarding the installation of measures for each Idaho home
completed during the 2014, or 2015 program years, if available.
REQUEST NO. 18: What steps does Rocky Mountain take to ensure all measures
installed at homes under the weatherization program are installed properly and performing as
designed?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER 22, 2016
REQUEST NO. 19: What criteria does Rocky Mountain use to determine whether
measures installed under the Low Income Weatherization Program are for Health and Safety?
REQUEST NO. 20: Are measures approved by Rocky Mountain prior to installation?
REQUEST NO. 21: How many homes did Rocky Mountain visit to confirm installation
of measures installed as part of the Low Income Weatherization Program in 2014 and 2015?
REQUEST NO. 22: What steps has Rocky Mountain taken to ensure that the most cost
effective measures are prioritized in a participant home under the Low Income Weatherization
Program?
REQUEST NO. 23: Please provide invoices for all projects completed as part of the
Low Income Weatherization Program in 2014, and 2015.
REQUEST NO. 24: Does Rocky Mountain track low income weatherization expenses
on a per project basis? If not, why?
REQUEST NO. 25: Both EICAP and SEICAA have had issues with finding
participants that qualify for the program. What steps is Rocky Mountain taking to remedy this
problem?
-7 7"":h--DATED at Boise, Idaho, this l.Y day of December 2016.
Technical Staff: Johnathan Farley (12-25)
i:umisc:prodreq/pace l 6.14bkdesdbrjk prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3
arpen
Deputy Attorney General
DECEMBER 22, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22nd DAY OF DECEMBER 2016,
SERVED THE FOREGOING THIRD 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: [e-mail]
[e-mail]
[e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N. 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
DAT A REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
CERTIFICATE OF SERVICE