20210715Staff 50-110 to PAC-Redacted.pdf

DAYN HARDIE (ISB No. 9917)
MATT HUNTER (ISB No. 1066s)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSTON
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
--, tii-ji I. ' L.J
t ll L:._:J
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC.E.TI.O1
REDACTED THIRI)
PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and Matt Hunter, Deputy Attorneys General, request that Rocky Mountain
Power ("Company") provide the following documents and information as soon as possible, but
no later than THURSDAY, AUGUST 5,2021.
This Production Request is to be considered as continuing, and the Company 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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1
)
)
)
)
)
)
)
)
JULY 15,2O2I
In addition to the written copies provided as response to the requests, please provide all
EXCEL spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 50: Following up on Production Request No. 3, please provide a
description of the services rendered, copies of invoices, and status of any ongoing litigation
involved for the following events.
REQUEST NO. 51: Following up on Production Request No. 6, please provide a
description, status report, and a list of 2020 invoices for the following cleanup projects:
a. Astoria / Unocal;
b. Eugene MGP- PacifiCorp;
c. Idaho Falls Pole Yard-Plant;
d. Portland Harbor Source Control;
e. Silver Bell / Telluride;
f. Pacific Power - Spill Prevention, Containment and Countermeasure (SPCC); and
g. Rocky Mountain - Spill Prevention, Containment and Countermeasure (SPCC).
REQUEST NO. 52: Please separate the Annual Incentive Plan ("AIP") amounts on
Exhibit No. 40 page 4.2.5 by the group codes included in page 4.2.2.
REQUEST NO. 53: Does the AIP amount stated on page 4.2.2 inchtde the Incentive
Payment and Long Term Incentive Plan ("LTIP") shown on the response to Production Request
No. 24? If not please state where the Incentive Payments and LTIP are included in the rate case
REQUEST NO. 54: Please include the amount of AIP available (potential AIP) and the
annual amounts awarded for 2018 through 2020.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2
a.
b.
c.
d.
e.
JULY 15,2021
REQUEST NO. 55: Please provide the Company policy manual and categories for the
AIP. Please include the annual amounts awarded for each category for 2018 through 2020.
REQUEST NO. 56: Please provide the Commission-approved ROE in PacifiCorp's last
rate case for Washington, Oregon, California, Wyoming, and Utah.
REQUEST NO. 57: Following up on Production Request No. 4, please separate the IT
expenses in Attachment IPUC 4-5 by individual IT projects.
REQUEST NO. 58: Please provide the base rate impact of Lake Side 2 power plant.
Please separate these costs into categories including O&M, Depreciation, Retum on Rate Base,
Fuel Costs, etc.
REQUEST NO. 59: Please provide the total costs included in the case for the Green
House Gas ("GHG") compliance as well as the amounts allocated to Idaho.
REQUEST NO. 60: Please provide the total GHG revenues the Company has included
in the case and the amount allocated to Idaho.
REQUEST NO. 61: Please provide copies of all contracts referenced in Adjustment
No.3.6
REQUEST NO. 62: Please provide the supporting documentation for the Company's
Medical, Dental and 401(k) expense shown on Exhibit No. 40 page 4.2.6.
REQUEST NO. 63: Please provide the contract for the renewal of Property and
Liability Insurances referenced on Exhibit No. 40 page 4.7.3 when available.
REQUEST NO. 64: Please provide the rationale and any supporting documentation for
the Company's renewal estimate provided on Exhibit No. 40 page 4.7.3.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 ruLY 15,2021
REQUEST NO. 65: Please provide the invoices for the credit facility expense as
provided for on Exhibit No. 40 page 4.1 l.l. Please also include the month end balance of each
credit facility for year ending 2020.
REQUEST NO. 66: Please provide a copy of the lead lag study referenced in
Adjustment No. 8.1.
REQUEST NO. 67: Please provide the rationale and any supporting documentation of
the Trapper Mine adjustment on Exhibit No. 40 page 8.2.
REQUEST NO. 68: Please explain why the accumulated depreciation reduces every
month for the Trapper Mine as shown on Exhibit No. 40 page 8.2.1.
REQUEST NO. 69: Please explain the reason that the inventory is increasing each
month for the Trapper Mine as shown on Exhibit No. 40 page 8.2.1
REQUEST NO. 70: Please explain how a customer advance would be allocated on an
SE factor as shown on Exhibit No. 40 page 8.2.
REQUEST NO. 7l: In the description for Adjustment No. 8.5, it states that all pro
forma projects would be $5 million or more. Please explain why the following projects were
included.
a. Monarch Upgrade ($1.3aM);
b. GTX Connect Java and UI Only ($2.41M);
c. AMI - Idaho IT Comm Network ($3.18M);
d. Mapping Sys Consolidation ($l.a2D;
e. Vantage Pomona Heights 230kV Line ($1.50M); and
f. PAC FIPS 201 (Phys Security Repl) ($1.48M).
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 ruLY 15,2021
REQUEST NO. 72: Please provide the rationale and any supporting documentation for
increasing the fuel stock on hand for the Naughton power plant shown on Exhibit No. 40 page
8.6.1.
REQUEST NO. 73: Please provide the nodal pricing capital balance by month from
inception to present. Please include the budget amounts that support Adjustment No. 5.2. Please
update these amounts with actuals as they become available.
REQUEST NO. 74: Please update Adjustment Nos. 8.2 (Trapper Mine) and 8.3 (Jim
Bridger) to actuals as those months become available.
REQUEST NO. 75: Please show the monthly fuel stock balances provided in Exhibit
No. 40 page 8.6.1. Please update the monthly amounts with actual numbers as they become
available.
REQUEST NO. 76: Please provide the rationale for continuing to hold coal in the Rock
Garden as provided on Exhibit No.40 page 8.6.l.
REQUEST NO. 77: Please provide copies of all invoices and all other financial source
documents to verifu the actual project costs for the projects collectively referred to as Energy
Vision 2020 Projects. Please update this production request monthly for the projects still in the
construction phase.
REQUEST NO. 78: Please provide all source documents pertaining to the repowering
projects that included any liquidated damages as referenced in ParagraphT of the Stipulation in
Case No. PAC-E-17-06.
REQUEST NO. 79: Page 39 of Company witness Hemstreet's direct testimony refers to
the report on the disposition of the assets replaced by repowering and the salvage value or other
customer benefits realized. Please provide a copy of this report and update it monthly through the
course ofthe rate case.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER 5 ruLY 15,2021
REQUEST NO. 80: Please provide a copy of the RTM defenal with the monthly entries
for both the Repowering projects and the New WindAtrew Transmission projects. Please update
this production request monthly.
REQUEST NO. 81: Please provide the following documentation for each Information
Technology Hardware Maintenance, Software Maintenance, and Software Web Hosted service
or project listed in Software and Hardware Expenses for years2020 and202l. (Where requested
information has not been provided, please explain why it was not provided and how the
Company assured completion of the service or project was completed at least cost.)
a. Business case - a justification of need for each service or project and a
cost/benefit analysis comparing alternatives;
b. Project details - scope, budget, and schedule;
c. Completion dates;
d. Costs - labor, material, purchased services, and other expenses; and
e. For any project that was completed for information security, please list the
standard, regulation, or requirement the implementation fulfills.
REQUEST NO. 82: Regarding the Customer Relationship Management system
upgrade, please provide the following information:
a. Project details - scope, budget, and schedule;
b. Phase completion dates and added functionality;
c. Services provided and costs associated with purchased services; and
d. Breakout of O&M expenses.
REQUEST NO. 83: Please provide workpapers supporting Exhibit No. 45 in electronic
format with links intact and formulas enabled.
REQUEST NO. 84: Please provide workpapers supporting Exhibit No. 49 in electronic
format with links intact and formulas enabled.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER 6 ruLY t5,2021
REQUEST NO. 85: Please provide workpapers supporting Exhibit No. 52 in electronic
format with links intact and formulas enabled.
REQUEST NO. 86: Please provide a detailed description of the Company's
weather/temperature normalization method used to normalize revenues, system peak, energy
loads, net power costs, and any other items normalized by this method. Please include any
workpapers supporting the weather/temperature normalization method for each item that is
normalized.
REQUEST NO. 87: Page 5 of Company witness Meredith's direct testimony states,
"From 2019 to 2020, the Company's normalized energy sales decreased by 0.04 percent and its
customer counts increased by 2.17 percent. To put the 2019 billing determinants on a
comparable basis with the 2020 historical test period, the Company therefore decreased all
billing determinants by 0.04 percent and increased all customer-related billing determinants by
2.17 percent " Please respond to the following:
a. Please provide a detailed description of the Company's method for normalizing
energy sales;
b. Please provide workpapers supporting the Company's energy sales normalization
method, in electronic format with links intact and formulae enabled;
c. Please provide workpapers supporting the 0.04 percent decrease in energy sales
from 2019 to 2020, in electronic format with links intact and formulae enabled; and
d. Please provide workpapers supportingthe2.lT percent increase in customer
counts from 201 9 to 2020, in electronic format with links intact and formulae
enabled.
REQUEST NO. 88: In reference to Meredith's direct testimony, pages 6-9, where he
discusses two changes made to the cost of service study, has the Company performed analysis or
analyses on the effect the two changes had on the cost of service study? If so, please provide any
analysis the Company performed.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOIINTAIN POWER 7 JULY I5,2O2I
REQUEST NO. 89: In reference to IPUC Audit Data Requests l, 15, 16, and l7 in Case
No. PAC-E-20-03, please provide any updates to these responses if changes were made in the
Application of this case (Case No. PAC-E-21-07).
REQUEST NO. 90: In Meredith's direct testimony, pages 24-26, he discusses changes
to special contract requirements and Schedule 401. Please respond to the following:
a. Please provide a comparison of the load shape and load factor from the last three
years for the Schedule 9 rate class and the Schedule 401 customer;
b. Please provide the workpapers supporting the bill impact of 5.7 percent for the
Schedule 401 customer mentioned on page25,line 14, of Meredith's direct
testimony; and
c. If the 15,000-kilowatt ("kW") limit is removed from Schedules 9 and 31, what is
the justification for not moving other special contract customers to Schedules 9 or
3l? Please explain.
REQUEST NO. 91: Please describe the communication methods the Company offers to
customers for reporting outages and the communication methods the Company uses to provide
timely updates of outages to its customers. What improvements, if any, is the Company making
to its outage management notification?
REQUEST NO. 92: Please describe the self-help options that are available to customers
using the Company's Interactive Voice Response system. Please provide the utilization rate for
each available option for each of the last three years and year to date ("YTD") 2021.
REQUEST NO. 93: Please describe the self-help options that are available to customers
using the Company's website. For each of the last three years and YTD 2021, please provide the
utilization rate for each available option. What percentage of Idaho customers have established
an online account?
REQUEST NO. 94: Please provide the number of incoming calls handled by the
customer service call center by month for each of the past three years plus YTD 2021.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 JULY 15,2O2I
REQUEST NO. 95: Please provide the number of abandoned calls to the customer
service call center by month for each of the past three years plus YTD 2021. "Abandoned calls"
are calls that reach the Company's incoming telephone system, but the calling party terminates
the call before speaking with a customer service representative.
REQUEST NO. 96: Please provide the average speed of answer for the customer
service call center by month for each of the past three years plus YTD 2021. "Average speed of
answer" is the interval (typically measured in seconds) between when a call reaches the
Company's incoming telephone system and when the call is picked up by a customer service
representative.
REQUEST NO. 97: Please provide the service level for the customer service call center
by month for each of the past three years plus YTD 2021. "Service level" is the percentage of
calls answered within a certain number of seconds, e.g.,80%o of calls answered within 20
seconds.
REQUEST NO. 98: Please provide the average number of busy signals reached by
parties calling the customer service call center by month for each of the past three years and
YTD 2021.
REQUEST NO. 99: Please provide the average response time for e-mail transactions by
month for each of the past three years plus YTD 2021. "Average response time" is the average
number of hours from receipt of an e-mail by the Company to sending a substantive response;
auto-response acknowledgements do not count as a substantive response.
REQUEST NO. 100: Please provide the average handling time by month for each of the
past three years plus YTD 2021. "Average handling time" is the average amount of time
(usually expressed in minutes) it takes for a customer service representative to talk with a
customer plus any additional "off-line" time it takes to complete the transaction or fully resolve
the customer's issue(s).
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOTiNTAIN POWER 9 JULY 15,2O2I
REQUEST NO. 101: Does the Company track the number of its Idaho customers who
receive assistance under the Company's Low Income Weatherization Assistance program
("LIWA") operated by the Eastern Idaho Community Action Partnership (EICAP) and
Southeastern Idaho Community Action Partnership (SEICCAX
REQUEST NO. 102: If your response to the preceding request (Request No. 103) is
yes, what percentage of the Company's total residential customers have received LIWA funding
in each ofthe past five years? In responding to this request, please break-out the percentage of
such customers who utilize gas versus electricity as their primary heating source.
REQUEST NO. 103: [s there a limitation that the Company imposes on those customers
seeking LIWA funding such that they must consume a minimum of a specif,rc number of
kilowatts of electricity and/or therms of gas annually? If so, what are those limitations and why
are they imposed?
REQUEST NO. 104: If your response to the preceding request (Request No 105) is yes,
what are those minimum consumption levels for both gas and/or electricity and how many and
what percentage of RMP low-income customers have been denied LIWA assistance in each of
the past five years for failure to consume the amount of energy consumption stated above?
REQUEST NO. 105: Has the Company conducted any studies during the past five years
of the effect that its LIWA program has on low-income customers in terms of reducing their
uncollectible accounts and related collection costs for the Company? If yes, please provide the
results of such studies by year.
REQUEST NO. 106: What are the number of disconnections between residential
customers who receive LIWA assistance and those who do not?
REQUEST NO. 107: How many of the Company's low-income customers have been
disconnected due to non-payment, or inability to pay, their electric bills in each of the past five
years and what percentage are residential customers?
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 JULY 15,2021
REQUEST NO. 108: Please provide a comparison for the number of disconnections and
disconnection related cost, on a per customer basis, between customers who receive LIWA
funding and residential customers who do not receive funding in each of the past five years.
REQUEST NO. 109: Please provide data, if available, supporting the Company's
current LIWA program having the effect of reducing disconnection, bad debt expense, and other
costs related to the loss of low-income customers due to their inability to pay.
REQUEST NO. 110: How many residential dwellings have been weatherized using
LIWA assistance in the Company's Idaho service territory in each of the past five calendar
years? Of those homes weatherized, what was the total average cost for each dwelling and the
average number of residential customers who have received such finding in each of the past five
calendar years?
DATED at Boise,Idatro, this | 5b aayof July 2021.
Deputy Attorney General
i:umisc:prodreq/pace2 l.Tdhmhjt prod req 3
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER I I JULY I5,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l5th DAY OF ruLY 2021,
SERVED THE FOREGOING REDACTED THIRD PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE
NO. PAC-E-21-07, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: ton),@yankel.net
BzuAN C COLLINS
MAUzuCE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #I4O
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
[e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL: [e-mail]
KYLE WILLIAMS
BYU IDAHO
E-MAIL: w'[e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: [e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: elo(@echohawk.com
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE TD 8370I
E-MAIL: [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
SECRET
CERTIFICATE OF SERVTCE