20191108Staff 1-7 to PAC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BARNO. 5470
RECEIVED
1019l;Cy -8 plt 12: S l
Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 20I.A
BOISE, ID 837I4
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILTTIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO MODIFY
ELECTRIC SERVICE SCHEDULE NO.3I
PARTIAL REQUIREMENTS SERVICE
CASE NO, PAC-E-19-I5
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKYMOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
John R. Hammond, Jr., Deputy Attorney General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than FRIDAY,
NOVEMBER 29,2019.
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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NOVEMBER 8,20I9
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the person preparing the documents. Please also identify 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 files on CD with tbrmulas intact and enabled.
REQUEST NO, l: Please describe any physical change to an existing primary or
secondary distribution customer's service needed to accommodate Schedule No. 31 - Partial
Requirements Service.
REQUEST NO.2: Please explain the basis and methodology used to determine the new
Schedule No. 3l primary and secondary distribution service rate design as it pertains to each of
the lollowing:
a. Customer Service Charge;
b. Back-up Facilities Rate;
c. Back-up Power Rate;
d. Excess Power Rate;
e. Supplementary Power Rate;
f'. Supplementary and Back-up Energy Rate; and
g. Scheduled Maintenance Power Rate.
REQUEST NO. 3: Please explain how the primary and secondary distribution service
rate design differs from transmission level service under Schedule 31.
REQUEST NO.4: Please explain how the primary and secondary distribution service
rate design is the same as transmission level service under Schedule 3 l.
REQUEST N0. 5: Please explain how the change to Schedule 31 will aftect other
customers both in the customer class and outside the customer class.
REQUEST NO. 6: Please provide the workpapers, with all formulas intact, used to
determine the rate design changes for the primary and secondary distribution service excess
power rate and the scheduled maintenance power rate.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 8,20I9
REQUEST NO. 7: Plcase provide an example contract to be used by the Company for
providing new primary and/or secondary distribution service under Schedule No. 31.
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' dayDATED at Boise, Idaho, this
i:umisc:prodreq/pace19. I 5jhrk prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
ol'Novembcr 2019
John ond, Jr.
ttorney General
'i NOVEMBER 8,20I9
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oep/ty
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THNT I HAVE THIS 81H DAY OF NOVEMBER 2019,
SERVED THE FOREGOING F'IRST PRODUCTION REQUEST OF'THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO,
PAC.E-Ig-I5, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: tcd.we illcoro,com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarcquest@pacifi corp.com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOTINTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITYUT 84I I6
E-MAIL: daniel.solander@paci flcom.com
SECRETAR
CERTIFICATH OF SERVICE