20180827Staff 1-9 to PAC.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702,5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF'ROCKY MOUNTAIN
POWER'S APPLICATION FOR A
DETERMINATION OF 2016 AND 2017
DEMAND-SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. PAC-E-18-07
FIRST 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,
Edith Pacillo, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY,
SEPTEMBER 17,2018.
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 mrmber of
FIRST PRODUCTION REQUEST
TO ROCKY MOI-]NTAIN POWER
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1 AUGUST 27,2078
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
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
Demand Side Management (DSM) tariff rider account for 2016 and20l7. 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 2016-2017.
REQUEST NO. 3: Please provide the tariff rider revenue by year and by customer class
for 2016-2017.
REQUEST NO. 4: Please provide the cost-effectiveness workpapers and calculations
for all DSM programs, including demand response, by year (2016-2017) 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 Evaluation, Measurement and Verification (EM&V), charged to the Idaho
DSM tariff rider during 2016 and2017. If any of the fees were allocated among jurisdictions,
please provide the calculation and explanation 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 2016 and2017. Please include a detailed description of
each project.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 27,2018
REQUEST NO. 7: Please compare the Company's acquired annual class 2 DSM
savings by program and sector with targets from the Integrated Resource Plan (IRP) and
conservation potential assessment for 2016-2017. If the Company did not achieve its targets,
such as the IRP energy efficiency savings for 2017 on a statewide level, please explain why.
REQUEST NO. 8: Please describe how common costs are allocated among
jurisdictions.
REQUEST NO. 9: Please provide the amount of labor expense charged to the DSM
tariff rider for the years 2016-2017 . 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.
DATED at Boise, Idaho, this
i:umisc:prodreq/pace I 8.7epbl prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
of August 2018
Edith Pacillo
Deputy Attorney General
nq-
aJ AUGUST 27,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF AUGUST 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-I8-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi com. com
DANIEL E SOLANDER
MICHAEL S SNOW
ROCKY MOI-INTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
mi chael. snow@,pacifi corp. com
CERTIFICATE OF SERVICE