20201001Staff 1-13 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER REQUESTING A
PRUDENCY DETERMINATION ON DEMAND.
SIDE MANAGEMENT EXPENDITURES
CASE NO. PAC.E.2O.Il
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 THURSDAY,
ocToBER22,2020.
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 OCTOBER I,2O2O
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the person preparing the documents. Please identiff 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. 1: Please provide a listing of all expenses charged to the Company's
Demand Side Management (DSM) tariff rider account for 2018 and 2019. Please include date,
vendor, amount, type of expense, and a brief description of the expense. Please separate
expenses by program so that the total amount for each program ties to the amounts reported in
the Annual DSM reports.
REQUEST NO.2: Please provide the monthly interest calculations for the balance in
the DSM tariff rider account for 2018-2019.
REQUEST NO.3: Please provide the tariff rider revenue by year and by customer class
for 2018-2019.
REQUEST NO. 4: Please provide the cost-effectiveness workpapers and calculations
for all DSM programs by year (2018 and2019) in Excel format with formulas intact and all
assumptions clearly defined.
REQUEST NO. 5: Please provide a listing of all legal and consulting fees, including,
but not limited to Evaluation, Measurement and Verification (EM&V), charged to the Idaho
DSM tariff rider during 2018 and 2019. If any of the fees were allocated among jurisdictions,
please provide the calculation and explanation of the allocation.
REQUEST NO. 6: Please provide the amount of labor expense charged to the DSM
tariff rider for the years 20 1 8 -2019 . For each of those years, please also include the number of
Full Time Equivalents funded by the rider. Please also provide the general wage adjustment
percentage for non-union personnel approved by the Compensation Committee of the Board of
Directors for each year.
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 2 OCTOBER I,2O2O
REQUEST NO. 7: Please provide a current organizational chart by title and name
showing all PacifiCorp and contract employees who charge time to the DSM rider. Please
include complete job descriptions, required qualifications, salary ranges, bonus opportunities,
and total compensation ranges, including benefits, for all employees identified in this request.
REQUEST NO. 8: Please provide a summary of the Low Income Energy Conservation
Education distributions to EICAP and SEICAA and expenditures from January 1,2017 to
December 31,2019. Please include any carryover of funds from one year to another as well as a
description of expenditures, such as the contents of energy savings kits.
REQUEST NO. 9: Please provide the cost effectiveness and deemed savings
calculations for the free advanced power strip promotion, listed on page 4l of the 2018 Annual
Report and the free Google Nest Thermostat E promotion, listed on page 40 of the 2019 Annual
Report.
REQUEST NO. 10: Please provide any additional results of the irrigation pilot program
listed on page 34 of the 2019 Annual Report.
REQUEST NO. 11: Please provide copies of all internal audit reports referencing any
of the Company's DSM expenses and processes for 2018 to current date. If no reports were
issued, please provide the date and scope of the audit and all internal auditor workpapers.
REQUEST NO. 12: Please provide details of the Peak Reduction Programs including:
a. The name of each program.
b. Guidelines and requirements for each program.
c. Each of the programs' incentive structure.
d. Number of participants in each program over the past five years.
e. Number of new participants in each program over the past five years.
REQUEST NO. 13: Please provide detailed data of the Irrigation Load Control program
administered and managed by EnerNOC for each of the years 2018 and 2019. This would
include, but not limited to the following:
FIRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER J OCTOBER I,2O2O
a. the date and time for each initiated irrigation event.b. the amount of demand saved in megawatts for each event hour.c. the amount of energy saved in megawatts hours for each event hourd. the value demand saved in each event hour.
e. the program cost for demand saved in each event hour.f. the value and cost ofenergy saved in each event hour.g. the corresponding market price of energy for each event hour.h. a breakdown of incentives paid to each participant by event.i. any event adjustment for participant opt-outs.j. any event adjustments for non-participation.
DATED at Boise, Idaho, this 1st day of October 2020
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Edward J.
Deputy Attorney General
i:umisc:prodreq/pace20. I lejbl prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 OCTOBER I,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF OCTOBER 2020,SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THECOMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.PAC-E-20-11, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
EMILY WEGENER
MICHAEL SNOW
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CMY UT 84116
E-MAIL: ted.weston @pacificorp.com
emilv. we gener @ pacificorp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest @ pacificorp.com
m ichael. snow @ pacificorp.com
SECRETARY
CERTIFICATE OF SERVICE