20181016Staff 10-13 to PAC.pdf

EDITH PACILLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5430
NECEIVEI]
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tsst0r.l
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 ROCKY MOUNTAIN
POWER'S APPLICATION FOR A
DETERMINATION OF 2016 AND 2017
DEMAND.SIDE MANAGEMENT EXPENSES
AS PRUDENTLY INCURRED.
CASE NO. PAC.E.18.O7
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey 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 FRIDAY,
NOVEMBER 2,2018.1
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
I Staff is requesting an expedited response. lf responding by this date will be problematic, please call Stafls
attorney at (208) 334-03 18.
SECOND PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER
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1 ocToBER 16,2018
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. 10: Please provide the supporting documentation, such as invoices,
contracts, and receipts for the expenses charged to the DSM tariff rider listed on Confidential
Attachment A (2016 Expense Sample) and Confidential Attachment B (2017 Expense Sample).
Please have this information available for review during Staff s onsite audit scheduled for
November 7-8,2018.
REQUEST NO. 11: In response to Production Request No. 5, please provide the
supporting documentation, such as invoices, contracts, and jurisdictional allocation calculations
for the consulting fees listed in Confidential Attachments A and B. Please have this information
available for review during Staff s onsite audit scheduled for November 7-8,2018.
REQUEST NO. 12: In response to Production Request No. 6, please provide the
supporting documentation, such as invoices, contracts, and detailed lists of items installed and
estimated energy savings, for the following projects:
For the year 2016:
a
o
a
a
o
a
a
a
sBrD_156720
WBID_12607
wBrD_126404
wBrD-144047
wBrD_3s425
wBID_37857
WBID_948ss
WBID-94857
For the year 2017:o WBID_14014o WBID_175772o WBID_179921o WBID_I89584o WBID_I89599o WBID 63740
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 ocroBER 16,2018
REQUEST NO. 13: In response to Production Request No. 9, please provide a detailed
summary of the expenses, including salaries, benefits, overhead or other expenses, that
contributed to the $127 ,447 in labor expenses in2016 and $131,244 in labor expenses in 2017 .
DATED at Boise, Idaho, this
i:umisc:prodreq/pace I 8.7epde prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
I b o^rof october 2018.
Edith Pacillo
Deputy Attorney General
3 OCTOBER 16,20T8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6th DAY OF OCTOBER 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-18-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareque st@ pac i fi corp. c om
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-MAIL: [e-mail]
ELECTRONIC ONLY
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON PLLP
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
[e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
DANIEL E SOLANDER
MICHAEL S SNOW
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
michael. snow@paci ficorp. com
ELECTRONIC ONLY
JOHN DUKE
IDAHOAN FOODS
E-MAIL: [e-mail]
ELECTRONIC ONLY
VAL STEINER
NU-WEST INDUSTRIES INC
E-MAIL: [e-mail]
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: mbrubaker(Econsultbai.com
kiverson@consultbai. com
ANTHONY YANKEL
LTNIT 2505
12700 LAKE AVENUE
LAKEWOOD OH 44107
E-MAIL: [e-mail]
L/M"*r
sECRE-TA(/
CERTIFICATE OF SERVICE