20191118Staff 18-22 to PAC.pdf

DA\'}.I HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.9917
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWERTO CLOSE THE
NET METERING PROGRAM TO NEW
SERVICE & IMPLEMENT A NET BILLING
PROGRAM TO COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED
GENERATION.
cAsE NO. PAC-E-I9-08
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
iig li0Y l8 Pl'l12: hl
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attomey General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY,
DECEMBER 9,2019.
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
THIRD PRODUCTION REQUEST
TO ROCKY MOI]NTAIN POWER NoVEMBER 18. 20 I 9
iiIOEIVED
I
the person preparing the documents. Please identif,y the name. job title, location, and telephone
number ofthe record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic filcs on CD with formulas intact and enabled.
R-EQUEST NO. 18: Referencing Meredith Exhibit No. 2 (Excel File), please provide
supporting information and documents for the following:
a. 2017 Total Customer Generation Administrative Costs;
b. Hourly Engineering Costs ($/Hour);
c. Engineering review time per application;
d. Meter Exchange Work Orders;
i. Average Handle Time;
ii. 2017 Customer Generator Meter Exchange Work Orders in ldaho;
e. Calls;
i. 2017 Count of Calls from Customer Generator Split in Idaho;
ii. Average Handle Time (Seconds); and
f. Call Center Agent Cost ($/Hour).
REQUEST NO. 19: Referencing MacNeil's Exhibit No. I (Excel File), please provide
supporting documents and any narrative explaining the reasoning ofthe following:
a. HLH Weighting (Export Credit Tab);
b. LLH Weighting (Export Credit I'ab); and
c. Energy Scalars: PACE ELAP 2018.
REQUEST NO.20: On page 6 of his direct testimony, Mr. MacNeil states that "The
Company has used the results from power l'low studies to calculate a marginal loss by load by
load level and then fitted it to a l2 month by 24 hour profile lbr each ofthe interconnection
levels referenced above." Please provide the workpapers and results fbr this power flow study in
electronic format with formulae and links in tact.
2 NOVEMBER I8.20I9
THIRD PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER
REQUEST NO. 21: On pages 3 and 4 of his direct testimony, Mr. Meredith describes
the method for determining each customer's generation and consumption profile. For each
customer used in Mr. Meredith's analysis, please provide the following:
a. Generation system parameters assumed by Mr. Meredith's model, including
Generation Type, County, Schedule under which customer takes service, and AC
nameplate capacity. For solar generation systems, please include panel
orientation (Azimuth and Elevation), and latitude/longitude. Identify the source
of weather information used by the model;
b. A customer code corresponding to the customer codes provided by the Company
in its workpapers in response to Staffs Production Request No. 13;
c. Hourly modeled Export kWh;
d. Hourly modeled Delivered kWh;
e. Hourly modeled billed kWh;
f. Hourly modeled consumption (kWh);
g. Actual Monthly Export kWh;
h. Actual Monthly Delivered kWh; and
i. Actual Monthly Billed kWh.
REQUEST NO.22: Please provide net billing updates and workpapers using 2019
IRP data.
DATED at Boise, fa*,o, ttirtftay of November 2019.
D ardie
puty Attorney General
i:umisc:prodreq/pac€l9.8dhmmjt prod rcq 3
3 NOVEMBER 18,20I9
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIF-Y TIIAT I HAVI] TIIIS 18Ih DAY OF NOVEMBER 2019,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OFTHE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E.I9-08,
BY MAILINC A COPY TIIEREOF, POSTAGE PREPAID. TO THE ITOLLOWINC:
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq ucst(D.paci tlcorp.com
ERIC L OLSEN
ECHO IIAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: clo(Oechoharvk .cot.ll
ANTIIONY YANKEL
12700 LAKE AVE
LTNIT 2505
LAKEWOOD OH44IO7
E-MAIL: [e-mail]
PR-ESTON N CARTER
GIVENS PURSLEY LLP
601 W BANNOCK S'f
BOISE ID 83702
E-MAIL : prestoncaft eraall gi venspursley.com
kendrahlrls ivensnurslcy.conr
Lnr&u YISECRETAffi_
CERIIFICATE, OF SERVICL
TED WESTON
ROCKY MOLINTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I I6
E-MAIL: ted.weston@pacifi corp.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TI{ ST
BOISE ID 83702
E-MAIL: bolto@ idahoconservati<-rn.org
YVONNE R HOGLE
ROCKY MOUNTAIN POWER
I4O7 WN TEMPI,E STE 320
SALT LAKE CITY UT 84I16
E-MAIL: yvonne.hoslefJ)pacifi corp.com
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