20201211Staff 14-16 to Staff.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL t i AN ;n.I oIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 ''
[phone]
IDAHO BAR NO.10446
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )ROCKY MOUNTAIN POWER REQUESTINGA )CASE NO.PAC-E-20-11PRUDENCYDETERMINATIONONDEMAND-)SIDE MANAGEMENT EXPENDITURES )
)SECOND PRODUCTION
)REQUESTOF 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 AttorneyGeneral,requests that Rocky Mountain Power provide
the followingdocuments and informationas soon as possible,but no later than MONDAY,
JANUARY 4,2021.
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
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 DECEMBER 11,2020
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.
REQUESTNO.14:Regarding the response to Production Request No.8,please
explain the disparity between SEICAA's RMP Energy Conservation Fund 2017 ending balance
of $1,822.20 and 2018 beginning balance of $0.
REQUESTNO.15:Regarding the response to Production Request No.8,please
explain the disparity between EICAP's Energy Conservation Fund 2018 beginning balance of
$30,038 and 2017 ending balance of $23,353,as reported in Table 11 of the Company's 2017
Idaho Energy Efficiency and Peak Reduction Annual Report.
REQUESTNO.16:Please provide all documentation supporting the Gross kWh
Savings totals for the Home Energy Reporting program in 2018 and 2019.
DATED at Boise,Idaho,this day of December 2020.
Edwar ewell
Deputy Attorney General
i:umise:prodreq/pace20.1lejbl prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER l1,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF DECEMBER 2020,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION 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 CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
michael.snow acificor .comPP
SECRETAR
CERTIFICATE OF SERVICE