20190422Staff 1-9 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83120-0074
[phone]
IDAHO BAR NO. 10446
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 THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO MODIFY SCHEDULE NO.
135 _ NET METERING SERVICE
CASE NO. PAC.E-I9.03
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, Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than MONDAY,
MAY 13,2019.
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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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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. l: How many customers currently take service under Schedule 135?
REQUEST NO. 2: How many customers taking service under Schedule 135 transferred,
or requested to transfer, excess financial credit in 2018?
REQUEST NO. 3: Please provide, in Excel format, a spreadsheet that identifies all
Schedule 135 customers that generated excess kilowatt hours during any month of 2018. For
each Schedule 135 customer, please include the following information: account number, service
address, excess generation for each month, amount of financial credit received on that account
for each month, and whether the customer transferred a credit during that month.
REQUEST NO. 4: Please explain the process currently used by the Company to transfer
excess financial credit for Schedule 135 customers who request credit.
REQUEST NO. 5: How many customers taking service under Schedule 135 have
multiple meters under different rate schedules?
REQUEST NO. 6: From January 2018 to the present, have any Schedule 135 customers
transferred excess financial credit to a meter with a rate schedule that differs from that of the
meter that generated the excess financial credit? If so, please provide, in Excel format, a
spreadsheet that identifies all Schedule 135 customers that transferred excess financial credit to
meters with different rate schedules in that time period. For those customers, please include each
customer's:
a. Account number;
b. Rate schedule for the meter that generated excess financial credit;
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 2 APRIL 22,2079
c. Rate schedule for each meter to which excess financial credits was transferred; and,
d. The total number of transfers the customer made.
REQUEST NO. 7: The Company proposes to transfer excess financial credit to meters
that are located on, or contiguous to, the premises on which the meter with excess financial credit
is located unless the customer's properties are divided by a dedicated street, highway or other
public thoroughfare, or railway. Please explain the rationale for this exclusion.
REQUEST NO. 8: Aside from the definition of "premises" as found in Electric Service
Regulation No. 2, the Company proposes that in order to be eligible for a meter-to-meter
transfer, both meters must be served by the same primary feeder and be on the same rate
schedule. What is the Company's rationale for these restrictions?
REQUEST NO. 9: Given the eligibility requirement that the meter being credited must
be on, or contiguous to the premises on which the meter with excess financial credit is located, in
what circumstances does the Company believe the additional requirement that both meters must
be served by the same primary feeder will be invoked?
JDATED at Boise, Idaho, this ZL day of April2019.
Edward
Deputy General
i:umisc:prodreq/pacel9.3ejrfmmcwh prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J APRIL 22,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF APRIL 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-19-03, 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 84I 16
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE