20191029Staff 1-5 to PAC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BARNO. 10655
F.ECEIVED
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Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOTSE, tD 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO REVISE
ELECTRIC SERVICE REGULATION NO. 4 -
SUPPLY AND USE OF SERVICE
CASE NO. PAC.E-I9.I4
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
FIRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER
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ocToBER 29,2019
The Staffof the Idaho Public Utilities Commission, by and through its attorney olrecord,
Matt Hunter, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than TUESDAY,
NOVEMBER 19,2019.
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
I
the person preparing the documents. Please identily the name, job title, location, and telephone
number of the record holder.
ln addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic liles on CD with formulas intact and enabled.
REQUEST NO. 2: fhe Application states, "device's capacity requirements will be
provided on the customer service application." Application at 3. Has the Company produced a
customer service application which includes an option lor small usage devices? Ifso, please
provide. If not, please explain the delay and when it will be complctcd.
REQUEST NO. 3: 'fhc revised Regulation 4 provided in Attachment I states,
"Connections w'ill be made by Company." Attachment I at 1. What is the fee for the Company
to install the small usage dcvice?
REQUEST NO,4: The revised Regulation 4 provided in Attachment I states,
"Connections will be made by Company, subject to the Customer's installation meeting all the
Company's design and installation requirements." Attachment I at I .
a. Please provide a copy of the written design and installation requirements;
b. If not completed, please provide an outline and explain what will be included in
the requirements; and
c. When the customer will receive the specific details.
REQUEST NO.5: The revised Regulation 4 provided in Attachment 1 states, "'lhe
Company shall have the right to test the capacity requirements of the small usage devices lrom
time to time." Attachment I at I . Please provide the Company's plan Ibr testing the devices
which may include which devices will be tested and how often.
FIRST PRODUCTION REQUEST
TO ROCKY MOLNTAIN POWER 1 ocToBER 29,2019
REQUEST NO. l: What schedule(s) will the small usage devices be billed under?
+/'DATED at Boise, Idaho, this )?day of October 2019.
Malt Hunter
Deputy Attomey General
i:umisc:prodreq/pace l9.l4rnhme prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J ocToBER 29,2019
CERTIFICATE OF SERVICE
I I.IEREBY CERTIFY TI{AT I HAVE THIS 29th DAY OF OCTOBER 2019.
SERVED THE FORECOING FIRST PRODUCTION REQUEST OF'THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-19-I4, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pacitlcorr;.com
S RLT
CERTIFICATE OI,' SERVICE
TED WESTON
ROCKY MOTJNTAIN POWER
I4O7 WN TEMPLE STE 330
SALT LAKE CITY UT 841 I6
E-MAIL: ted.westonfialpacificorp.com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKYMOLTNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]