20210805PAC to Staff 50-110-Redacted.pdf

ROCKY MOUNTAIN
FOWER
1407 W North Temple, Suite 330
Salt Lake Ci$, Utah 84116
August 5,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.norivuki@puc. idaho. eov (C)
RE ID PAC-E.21-07
IPUC Set 3 (50-110)
Please find enclosed Rocky Mountain Power's Responses to IPUC 3'd Set Data Requests 50-110.
Provided via e-mail are the non-confidential Attachments and provided via encryption are the
Confidential Attachments. Con{idential information is provided subject to protected under
IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject to any
subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone]
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PIIC [e-mail]
Bradley G. MullinslPIIC brmullins@mwanalytics. com
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. steiner@ itafos.com (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Randall C. BudgelBayer randy @racineol son. com (C)
Thomas J. Budge/Bayer ti @racineol son. com $D(C)
Brian C. Collins/Bayer bcollins@consultbai. com (W)(C)
Maurice B rubaker/B ayer rnbrubaker@c onsultbai. c orn (C)
Kevin Higgins/Bayer khieeins@enerev strat. com (C)
Lance Kaufrnan/Bayer lance@aesisinsieht. com (C)
James R. SmithlBayer j im. r. smith@ic loud. com (C)
Brad Purdy [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 5l
IPUC Data Request 51
Following up on Production Request No. 6, please provide a description, status
report, and a list of 2020 invoices for the following clean-up projects:
(a) Astoria / Unocal;
(b) Eugene MGP- PacifiCorp;
(c) Idaho Falls Pole Yard-Plant;
(d) Portland Harbor Source Contol;
(e) Silver Bell / Telluride;
(f) Pacific Power - Spill Prevention, Containment and Countermeasure (SPCC);
and
(g) Rocky Mourtain - Spill Prevention, Containment and Countermeasure
(sPCC).
Response to IPUC Data Request 51
Please refer to Attachment IPUC 5l which provides a description of
environmental projects and a list of 2020 invoices. There are not status reports to
provide with these projects.
Recordholder:Nancy Adolphson
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 52
IPUC Data Request 52
Please separate the Annual Incentive Plan (AIP) amounts on Exhibit No. 40 page
4.2.5by the group codes included in page 4.2.2.
Response to IPUC Data Request 52
The Company assumes the "group codes included in page 4.2.2" was intended to
be a reference to Exhibit No. 40, page 4.2.3. Based on the foregoing assumption,
the Company responds as follows:
The Annual Incentive Plan (AIP) is paid only to officers and certain exempt
employees which is reflected as Group Code 2, labeled "Officer/Exempf'.
Recordholder:Nick Highsmith
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 56
IPUC Data Request 56
Please provide the Commission-approved ROE in PacifiCorp's last rate case for
Washington, Oregon, Califomia, Wyoming, and Utah.
Response to IPUC Data Request 56
California - Application (A) 18-04-002 - return on equity (ROE) 10.0 percent
effective February 6, 2020.
Oregon - Docket UE-374 - ROE 9.5 percent effective January l, 2021
Utah - Docket No. 20-035-04 - ROE 9.65 percent effective January 1,2021
Washington- DocketNo. UE-191024- ROE 9.5 percent efflective January l,
202t.
Wyoming - DocketNo. 20000-578-ER-20 ROE 9.5 percent effective July l,
2021. Filed requesting a Januaryl, 2021 rate effective date.
Recordholder:Ted Weston
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Pou,er
August 5,2021
IPUC Data Request 57
IPUC Data Request 57
Following up on Production RequestNo. d please separate the IT expenses in
AttachmentIPUC 4-5 by individual IT projects.
Response to IPUC Ileta Request 57
Please refer to Attachment IPUC 57.
Recordholder:Catherine Docekal
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,202L
IPUC Data Request 58
IPUC Data Request 58
Please provide the base rate impact of Lake Side 2 power plant. Please separate
these costs into categories including O&M, Depreciation, Return on Rate Base,
Fuel Costs, etc.
Response to IPUC Data Request 58
Plerese refer to Attachment IPUC 58.
Recordholder: Laura Miller
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 61
IPUC Data Request 61
Please provide copies of all contracts referenced in Adjusftnent No. 3.6.
Response to IPUC Data Request 61
Please refer to Confidential Attachment IPUC 6l which provides a copy of the
following contracts:
(l) Generation ContoVStoragelDelivery and UFT Service Agreement between
the United States of America, Deparftnent of Energy (Bonneville Power
Administation @PA)) and PacifiCorp dated July 20,2000, and
(2) Integration and Exchange Agreement between the City of Seattle (City Light
Deparfrnent) and PacifiCorp dated December 3,2011.
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Contracts Administration
Sponsor:Not applicable
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 62
IPUC Data Request 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.
Response to IPUC Deta Request 62
To calculate the forecasted 401(k) expense, the Company begins with acflral
401(k) expense from the December 2020 Base Period and escalates this amount
using the percentage increase of regular/overtime/premium pay as shown in
Exhibit 40, Page 4.2.5.
To calculate medical and dental plans, the Company relies on health and welfare
achraries to determine medical trends and costs for items such as medical and
dental plans.
Recordholder: Julie Lewis
Sponsor:Steve McDougal
Couvldctirrl $26.r?$28.82 t33.79 $33.0r $34.99
st6-54IBEW}Ildhd $30.80 $26.06 w52 n720
3l-88 s2-03 3235 3236 32-,tlCmrrlhfrl
$2.04 $2.08IBEWl}dd t224 s1.64 s.01
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 63
IPUC Data Request 63
Please provide the contract for the renewal of Property and Liability Insurances
referenced on Exhibit No. 40 page 4.7.3 when available.
Response to IPUC Data Request 63
Premium estimates on Page 4.7.3 are developed internally based on prior
premiums, current market conditions, and factors in loss and risk exposure. The
Company will provide the acfual premium renewal amounts when they become
available after the policies are renewed. The information should be available
around Q3/Q4 of each respective year. Additionally, the Company will update to
the most recent information in rebuttal.
Recordholder: Wendy Wallis
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mormtain Power
August 5,202L
IPUC Data Request 64
IPUC Data Request 64
Please provide the rationale and any supporting documentation forthe Company's
renewal estimate provided on ExhibitNo. 40 page 4.7.3
Response to IPUC Deta Request 64
Please rcfer to the response to data request IPUC 63.
Recordholder: Wendy S/allis
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mormtain Power
August 5,2021
IPUC DataRequest 66
IPUC Deta Request 56
Please provide a copy of the lead lag study referenced in Adjustuent No. 8.1.
Response to IPUC Data Request 66
Please refer to Attachment IPUC 66.
Recordholdor:taura Miller
'Sponsor:Steven lvloDougal
PAC-E-21-07 / Rocky Mormtain Power
August 5,2021
IPUC Data Request 67
IPUC Deta Request6T
Please provide the rationale and any supporting doctrmentation of the Trapper
Mine adjustuenton ExhibitNo.40 page 8.2.
Response to IPUC Date Requet 67
The Trapper Mine is included in FERC Account 123.1, and therefore not reflected
in the base period data. This adjustuent is calculated to include PacifiCorp's
portion of the Trapper Mine investnent in the rate base.
Recordhslder: Aaron Rose
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 70
IPUC Data Request 70
Please explain how a customer advance would be allocated on an SE factor as
shown on Exhibit No. 40 page 8.2.
Response to IPUC Data Request 70
The Company assumes that the reference to "Exhibit No. 40 page 8.2" is intended
to be a reference to Exhibit No. 40, page 8.4 (Customer Advances for
Consffuction). Based on the foregoing assumption, the Company responds as
follows:
Customer advances for construction are booked into FERC Account 252 and can
result in certain balances allocated on incorrect allocation factors. The Company
prepares adjustnent 8.4, Customer Advances for Construction, to correct these
allocations. No customer advance for construction is allocated on a system energy
(SE) allocation factor.
Recordholder:Justin Waterman
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 71
IPUC Data Request 71
In the description for Adjustrnent 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.alM);
(c) AMI - Idaho IT Comm Network ($3.18M);
(d) Mapping Sys Consolidation ($1.42M);
(e) Vantage Pomona Heights 230kV Line ($1.50M); and
(0 PAC FIPS 201 (Phys Security Repl) ($1.+SVr;.
Response to IPUC Data Request 71
Items (a) The Monarch Upgrade, (b) GTX Connect Java and UI Only, (c) AMI -
Idaho IT Comm Networh (d) Mapping Sys Consolidation, and (0 PAC FIPS 201
(Phys Security Repl) projects include multiple plant functions that are
summarized separately by FERC Account to ensure proper state allocation. In
total, the projects listed are all greater than $5 million. Please refer to Attachment
IPUC 7l for further details.
Please refer to the Company's response to subpart (e) below
(e) Vantage Pomona Heights 230kV Line went into service in August 2020.T\e
$1.5 million is the continuation of the project n2021. Please refer to
Attachment IPUC 7l for further details.
Recordholder:Craig Larsen
Steven McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 73
IPUC Data Request 73
Please provide the nodal pricing capital balance by month from inception to
present. Please include the budget amounts that support Adjustnent No. 5.2.
Please update these amounts with actuals as they become available.
Response to IPUC Data Request 73
The forecast amount for this project is $3.7 million for intangible (software), and
$0.9 million for general (hardware) as shown on Exhibit No. 40, page 5.21 with
an expected final completion of December 2021. Please refer to Attachment IPUC
73 which provides the actual monthly in-service amounts from Jaruary 2021
through June 2021. Please refer to the 2020 Protocol for more infomration on
nodal pricing.
Recordholder Craig Larsen
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Fower
August 5,2021
IPUC DataRequest 75
IPUC Data Request 75
Please show the monthly fuel stock balances provided in ExhibitNo. 40 page
8.6.1. Please update the monthly amounts with actual numbers as they become
available.
Response to IPUC Data Request 75
Please refer to AttachmentIPUC 75.
Reaordholder: Aarsn Rose
Sponsor:SGven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 77
IPUC Data RequestTT
Please provide copies of all invoices and all other financial source documents to
verifr 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.
Response to IPUC Data RequestTT
The Company objects to the request as unduly broad and overly burdensome
Notwithstanding the foregoing objection, the Company responds as follows:
The Company clarifies that the reference to the "Energy Vision 2020 Projects" is
intended to be a reference to the term as utilized in the direct testimony of
Company witress, Timothy J. Hemstreet, specifically the wind projects
collectively referred to as the Energy Vision 2020 Projects, comprising:
Repowering Wind Projects - Dunlap, Glenrock [, Glenrock III, High Plains,
Leaning Juniper, Marengo I, Marengo II, McFadden Ridge, Rolling Hills, Seven
Mile Hill I, and Seven Mile Hill II.
New Wind Projects - Cedar Springs II, Ekola Flats and TB Flats
And in addition, Transmission Projects - Aeolus to Jim Bridger Anticline,
Q707, and Q712.
Further to the foregoing clarification, the Company responds as follows:
Please refer to Confidential Attachment IPUC 77 which lists the costs recorded
for each of the Energy Vision 2020 (EY 2020) projects in the Company's SAP
accounting system through June 30, 2021. Given the magnitude of the cost
documentation, the Company respectfully requests that the Idaho Public Utilities
Commission (IPUC) staffreview the provided information, and select a sample of
enties for which the Company will compile associated invoices for IPUC staffto
audit should additional verification of project costs be desired.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Gary Tawwater / Tom Evans I Lori Holland
Sponsor:Timothy J. Hemsteet
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 78
IPUC Data Request 78
Please provide all source documents pertaining to the repowering projects that
included any liquidated damages as referenced in Paragraph 7 of the Stipulation in
Case No. PAC-E-I7-06.
Confidential Response to IPUC Data Request 78
Liquidated damages associated with construction of the repowering projects are
summarized in Confidential Table I provided below. Please refer to Confidential
Attachment IPUC 78-1 which provides source documentation for this
information.
Confidential Table 1: Construction liquidated damages summary for repowering projects
Repowering Project
Name
Construction liquidated
damases ($)
Dunlap
Glenrock I
Glenrock III
Hieh Plains
Leaning Juniper
McFadden Ridge
Rolline Hills
Seven Mile Hill I
Seven Mile Hill II
Goodnoe Hills None
Marengo I & II None
Liquidated damages associated with equipment availability guarantees for the
repowering projects are summarized in Confidential Table 2 provided below.
Please refer to Confidential Attachment IPUC 78-2 which provides source
documentation for this information.
PAC-E-21-07 / Rocky Mountain Power
August 5,202t
IPUC Data Request 78
Confidential Table 2: Availability liquidated damages summary for repowering projects
Repowering Project
Name
Availability liquidated
damases ($)
Dunlap None
Glenrock I None
Glenrock Itr None
Hieh Plains None
Leanine Juniper None
McFadden Ridee None
Rolline Hills None
Seven Mile Hill I None
Seven Mile Hill II None
Goodnoe Hills None
Marengo I& II I
Confidential information is provided subject to proGction under IDAPA
31.01.01.067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Timothy J. Hemstreet
Timothy J. HemsteetSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 79
IPUC Data Request 79
Page 39 of Company witness Hemstreet's direct testimony refers to the report on
the disposition of the assets replaced by repowering and the salvage value or other
customer benefits realized. Please provide a copy of this report and update it
monthly through the course of the rate case.
Response to IPUC Data RequestT9
Please refer Confidential Attachment IPUC 79 which provides the requested
report. Repowering efforts and associated salvage activities have concluded and
there are no anticipated updates to the report. The salvage values obtained from
the projects are summarized in the table below:
Project Name Salvage value ($)Salvage component
Dunlap None
Glenrock I None
Glenrock III None
Goodnoe Hills I blades, gearboxes
High Plains None
Leaning Juniper None
Marengo I & II I blades
McFadden Ridge None
Rolline Hills None
Seven Mile Hill I None
Seven Mile Hill II None
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Timothy J. Hemstreet
Timothy J. HemsteetSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 80
IPUC Data Request 80
Please provide a copy of the RTM defenal with the monthly entries for both the
Repowering projects and the New WindA.{ew Transmission projects. Please
update this production request monthly.
Response to IPUC Data Request 80
Please refer to Attachment IPUC 80. Note: these amounts are subject to update
and will be trued up at the endof 2021. PacifiCorp already provides quarterly
updates with the energy cost adjustnent mechanism (ECAM) and will continue to
provide the updated renewable tracking mechanism (RTM) amounts there.
Recordholder:Justin Waterman
Sponsor:Steve McDougal
PAC-E-21-07 1 Rocky Mormtain Power
August 5,2AZl
IPUC DataRequest 83
IPUC Data Request E3
Pleaee provide work papers suppor-[ng Exhibit No. 45 in electronic format with
linls intact and formulas enabled.
Responre to IPUC Data Roquest 83
Please refer to the work papers ilpporting the direct testimony of Company
wifrress, Robert M. Meredith, specffieally fiIe "ID GRC Blocking 2020.xlsu("
Recordholder: Robert M. Meredith
Sponsor:Robert M. Meredith
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC DataRequest 84
IPUC Data Requost 84
Please provide work papers supporting ExhibitNo.49 tn electonic fsrmat with
links intact and formrrlas enabled.
Response to IPUC Data Requegt 84
Please refer to the work papers supporting the direct testimony of Company
witress, Robert M. Meredith, specifically file *ID GRC Bloeking 2020.NlsDC'.
Recordholder: Robert M. Meredith
Sponsor:RobertM. Meredith
PAC-E-21-07 / Rooky MountainPower
August 5,2A21
IPUC Data Request 85
IPUC Data Roquest 85
Please provide work papers supporting ExhibitNo. 52 itr electonic format with
linksintaot and formulas enabled.
Responso to IPUC Data Request 85
Plerese refer to Attachment IPUC 85.
Rccordholder:Robert M. Meredith
Sponsor:Robert M. Meredith
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 86
IPUC Data Request 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
work papers supporting the weather/temperature normalization method for each
item that is normalized.
Response to IPUC Data Request 86
The Company's class level weather normalization is created using the following
steps.
1. First, the Company creates class level regression models using cycle weather
variables, economic variables and cycle month variables fitted to ttre class
level actual sales to create predictive models used to forecast future class level
sales based on normal conditions.
2. Once the actual values are known, calendar sales are created by applying the
model coefficients from the cycle models to calendar acfual and calendar
normal variables to create calendar normal and calendar actual values for each
month.
3. The weather adjustnent is then created by subtracting the calendar actual
value from the calendar normal value for each class for each month.
4. The class level weather adjusfinents are allocated to weather sensitive rate
schedules based on the rate schedule's percentage ofclass sales.
The class level monthly weather adjustnents for each jurisdiction are increased
for line losses and allocated to days based on the ratio of actual daily weather to
daily normal weather and then to hours based on the percentage of daily
jurisdictional load. The hourly weather adjustrnent is used to normalize system
peak, energy loads and net power costs.
Please refer to the Company's responses to IIPA Data Request 1 and IIPA Data
Request 2.
Recordholder: James Zhang / Lee Elder
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 87
IPUC Data Request 87
Page 5 of Company witress 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 biling 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 determinantsby 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 work papers supporting the Company's energy sales
normalization method, in electronic format with links intact and formulae
enabled;
(c) Please provide work papers supporting the 0.04 percent decrease in energy
sales from 2019 to 2020, in electonic format with links intact and formulae
enabled; and
(d) Please provide work papers supponing the 2.17 percent increase in customer
counts from 2019 to 2020, in electronic format with links intact and formulae
enabled.
Response to IPUC Data Request 87
(a) The Company normally uses the following steps to normalize the energy sales
in a general rate case (GRC): (1) get the booked annual energy sales by class,
by schedule from the Company's revenue report system (namely 305 report)
for the test period; (2) get the annual energy sales by class, by schedule from
the Company's customer billing system and the regular bills for the test
period; (3) get the annual out ofperiod adjustrnents ofenergy sales by class,
by schedule from the Company's customer billing system and the non-regular
bills such as canceled bills and override bills out of the test period. Those
adjustnents of energy sales would be part of the normalization. For Schedule
400, the normalization also includes taking out the buy-through energy sales
and putting in the curtailed energy sales for the test period; (4) calculate the
differences between the energy sales from the billing determinants developed
from step 2 and the sales of energy booked in the customer bills and put them
as "Blocking Adjusftnent"; (5) allocate the unbilled energy sales from the 305
report by class to each schedule proportionally; (6) include the weather energy
sales adjustrnent for the corresponding class and schedule.
(b) Please refer to Attachment IPUC 87-1 for the detailed normalization of
calendar year 2019 actual energy sales, and Attachment IPUC 87-2 for the
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 87
detailed normalization of calendar year 2020 acnnl energy sales.
(c) Please refer to the work papers supporting the direct testimony of Company
witress, Robert M. Meredith, specifically file "ID GRC Blocking 2020.x1sr",
tab "Table A 20vsl9" for the support of the 0.04 percent decrease in energy
sales from 2019 to 2020, The energy sales megawatt-hours (MWh) for 2019
and2020 in the above tab is from the tab "Table A" in Attachment IPUC 87-
1, and Attachment IPUC 87-2.
(d) Please refer to the work papers supporting Mr. Meredith's direct testimony,
specifically file "ID GRC Blocking 2020.x1sx", tab "Table A 20vsl9" for the
support of the 2.17 percent increase in customer counts from 2019 to 2020.
The average customer for 2019 and2020 in the above tab is from tab "Table
A" in Attachment IPUC 87-l and Attachment IPUC 87-2.
Recordholder:Robert M. Meredith
Sponsor:Robert M. Meredith
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC DataRequest 88
IPUC Data Request 88
In reference to Meredith's direct testimony, pages 6-9, where he discusses two
changes made to the cost of service strdy, has the Company performed analysis or
analyses on the effect the two changes had on the cost of senrice study? If so,
please pmvide any analysis the Company perfomred.
Response to IPUC Data Request 88
The Company has notperforured analysis quanti&ing the impact ofthese two
changes.
Recordholder: Robert M. Meredith
Sponsor:Robert M. Meredith
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 89
IPUC Data Request 89
In reference to IPUC Audit Data Requests l, 15, 16, and 17 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).
Response to IPUC Data Request 89
There ,!re no changes to the Company's responses to IPUC Audit Data Requests
l, 15, 16 or 17 in Case No. PAC-E-20-03 because no changes were made to the
methods used to develop the weather, temperafure, or customer count adjustnents
in that case or this general rate case (GRC), Case No. PAC-E-2I-07). Please refer
to the work papers supporting the direct testimony of Robert M. Meredith for
supporting documentation of the weather, temperature, and customer count
adjustnents.
Recordholder:Robert M. Meredith
Sponsor:Robert M. Meredith
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 90
IPUC Data Request 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 work papers supporting the bill impact of 5.7 percent for
the Schedule 401 customer mentioned on page 25,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.
Response to IPUC Data Request 90
(a) Please refer to Confidential Attachment IPUC 90 which provides a
comparison of load shapes and load factors for Schedule 9 and Schedule 401
customers in 2018, 2019, and 2020.
(b) Please refer the work papers supporting the direct testimony of Company
witness, Robert M. Meredith, specifically file "ID GRC Blocking 2020.x1sx",
tab "Exhibit No 49 - Table A", cellU24.
(c) The only other special contract customer is Schedule 400. Unlike Schedule 9
or Schedule 31, Schedule 400 is for a large intemrptible customer. Since, the
customer on Schedule 400 is intemrptible it is appropriate for it to be on a
different schedule than Schedule 9 or Schedule 31.
Confidential information is provided subject to protection under IDAPA
31.01 .01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder Robert M. Meredith / Lee Elder
Sponsor:Robert M. Meredith
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 91
IPUC Data Request 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?
Response to IPUC Data Request 91
Customers can report their power outage and receive an update for the power
outage for their specific location using phone, text messaging, through our
website, our free to download mobile app or by speaking with a customer service
representative.
Improvements include initiatives to increase the capture of customers' email
addresses and phone numbers and to ensure customers are aware of our ability to
communicate individual power outage updates through the channel of the
customer's choice, which includes push notifications, text messaging, email, by
phone or by viewing our interactive power outage map.
Recordholder: Tony Worthington, Dante Hill, Barb Modey
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request92
IPUC Data Request 92
Please describe the self-help options that are available to customers using the
Company's Interactive Voice Response system. Please provide ttre utilization rate
for each available option for each of the last three years and year to date (ftD)
2021.
Response to IPUC Data Request 92
Customers utilizing the company's interactive voice response (IVR) system can
get their account balance and payment due date, report an outage and receive
outage updates, request a payment due date extension, request a time payment
plan, or request an equal payment plan.
Please see Attachment IPUC 92 for information on the percent of customers
visiting these applications.
Recordholder: Tony Worthington
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 93
IPUC Data Request 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 Ym 2021, please
provide the utilization rate for each available option. What percentage of Idaho
customers have established an online account?
Response to IPUC Data Request 93
Please see Attachment IPUC 92 for information on the self-service options
available to customers with an online accoun! the percent of contacts using these
options and the overall percentage of Idaho customers that have an online
account. The number of customers with an online account is a static count as of
luJy 21.
Self-service detail provided excludes general information the company provides
to customers within their online account including their usage graph, due date,
payment due, etc.
Recordholder: Tony Worthington
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Mor.rntain Power
August 5,2021
IPUC DataRequest 94
IPUC Data Request 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.
Response to IPUC Dete Requcst 94
Please see Attaohment IPUC 94.
Recordholder: Tony Worthin$on
Sponsor: MelissaNotingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 95
IPUC Data Request 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 parly
terminates the call before speaking with a customer service representative.
Response to IPUC Data Request 95
Please see Attachment IPUC 94.
Recordholder: Tony Worthington
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 96
IPUC Data Request 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.
Response to IPUC Data Request 96
Please see Attachment IPUC 94.
Recordholder: Tony Worthington
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 97
IPUC Data Request 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 tho perce,lrtage of
calls answered within a certain number of seconds, o.9., 80% of oalls answered
within 20 seeonds.
Response to IPUC Data Request 97
Please see Attachment IPUC 94.
Recordholder: Tony Worlhington
Sponsor: MelissaNottinghaur
PAC-E-21-07 / Rocky Mormtain Power
August 5,2021
IPUC DataRequest 98
IPUC Data Request 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
202t.
Response to IPUC Data Request 9E
Please see Attachment IPUC 94.
Recordholder: Tony Worthington
Sponsor: MelissaNottingham
PAC-E-21-07 / Rocky Morurtain Power
August 5,2021
IPUC DataReguest 99
IPUC Data Rquest 99
Please provide the average reE onse time for e-mail transactions by month for
each of the past three years plus YTD 2021. "Average response timeu is the
average ntrmber of hours from receip of an e-mail by the Company to sending a
zubstantive response; auto-response acknowledgements do not count as a
substantive rcsponse.
Response to IPUC Data Roquest 99
Please see Attachment IPUC 94.
Recordholder: Tony Worthington
Sponsor: MelissaNottingham
PAC-E-21-07 / Rocky Motrntain Power
August 5,2021
IPUC Data Request 100
IPUC Data Request 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 "of[-line" time it takes to complete the
transaction or fully resolve the customer's issue(s).
Response to IPUC Data Request 100
Please see Attachment IPUC 94.
Recordholder: Tony Worthington
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 101
IPUC Data Request 101
Does the Company tack the number of its Idaho customers who receive
assistance under the Company's Low Income Weatherization Assistance progftrm
(LIWA) operated by the Eastern Idaho Community Action Partrership (EICAP)
and Southeastern Idaho Community Action Parftrership (SEICCAX
Response to IPUC Data Request 101
Yes. Low Income Weatherization Assistance (LIWA) program customer projects
are tacked in the Company's demand-side management cental (DSMC) system.
Recordholder: Charity Spires
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 102
IPUC Data Request 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
firnding in each of the past five years? In responding to this request, please break-
out the percentage of such customers who utilize gas versus electicity as their
primary heating source.
Response to IPUC Data Request 102
The Company assumes that the reference to the "preceding request (Request No
103) is intended to be a reference to IPUC Data Request 101. Based on the
foregoing assumption, the Company responds as follows:
Please refer to Attachment IPUC 102.
Recordholder: Charity Spires
Sponsor: Melissa Nottingham
PAC-E-21-07 / Rocky Motrntain Power
August 5,2021
IPUC Data Request 103
IPUC Data Request 103
Is there a limitation that the Company imposes on those customers seeking LIWA
funding such that they must consume a minimum of a specific number of
kilowatts of electicity and/or therms of gas annually? If so, what are those
limitations and why are they imposed?
Response to IPUC Data Request 103
No. The Company does not impose a minimum number of kilowatts (kW) of
electricity for customers to participate in Low Income Weatherization Assistance
(LIWA) program.
Recordholder: Charity Spires
Sponsor:Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 104
IPUC Data Request 104
If your response to the preceding request (Request No 105) is yes, what are those
minimum consumption levels for both gas and/or electicity 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?
Response to IPUC Data Request 104
The Company assumes that the reference to the "preceding request (Request No
105) is intended to be areference to IPUC Data Request 103. Based on the
foregoing assumption, the Company responds as follows:
Please refer to the Company's response to IPUC Data Request 103.
Recordholder:Charity Spires
Melissa NottinghamSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 105
IPUC Data Request 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.
Response to IPUC Data Request 105
No. The Company has not conducted any studies during the past five years of the
effect that its Low Income Weatherization Assistance (LIV/A) program has on
low-income customers in terms of reducing their uncollectible accounts and
related collection costs for the Company.
Recordholder: Charity Spires
Sponsor:Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2AZl
IPUC DataRequest 106
IP-UC Data Rquost 106
I
What are the number of disconnections betrreen residential customers who
receive LIWA assistance and thosewho do not?
Responsc to IPUC Ilete Request 105
Please refer to Attachment IPUC 106.
Recordholder:Charity Spires
Melissa NottingbamSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC DataRequest 107
IPUC Data Requost 107
How many of the Company's low-income customers have been disconnected due
to nou-payment, or inability to pay, their electic bills in each of the past five
years and whatpercentage are residential customers?
Rosponse to IPUC Data Request 107
Please refer to Attacbment IPUC 107.
Reoordholder:Charity Spires
Melissa NottinghamSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 108
IPUC Data Request 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.
Response to IPUC Data Request 108
Please refer to response IPUC 106 for the comparison of the number of
disconnections between residential customers that are LIWA recipients versus
non-LIWA residential customers.
The Company has a standard residential reconnection fee of $25.00 regardless of
LIWA status.
Recordholder: Charity Spires
Sponsor:Melissa Nottingham
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUC Data Request 109
IPUC Data Request 109
Please provide data, if available, supporting the Company's curent 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.
Response to IPUC Data Request 109
The Company does not have available data supporting the Low Income
Weatherization Assistance (LIWA) program and the effect of reducing
disconnections, bad debt expense, and other costs related to the loss of low-
income customers due to their inabilrty to pay. However, lrr,2019, the Company
contacted with ADM Associates Inc for the Evaluation of Idaho Low Income
Weatherization Program for years 2016 and 2017 which showed a reduction on
participants' reliance on energy payment assistance programs and reduced the
,urears balances carried by participants. For the above, please refer to Attachment
IPUC 109 for a copy of the Idaho Low Income Weatherization Program
Evaluation, Measurement & Verification Report 2016-2017 and refer to section 7
Conclusions and Recommendations section on page 39.
Recordholder:Charity Spires
Melissa NottinghamSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
IPUCDafaRequest 110
IPUC Data Request 110
How many residential dwellings have been weatherized using LIM assistance in
the Company's Idaho service tenitory in each of the past five calendar years? Of
those homes weafherized, what was the total aver4ge cost for each firyElling and
the average number of residential customers who have received such finding in
each ofthe past five calendar years?
Response to IPUC Data Request 110
Please refer to Attachment IPUC 110.
Recordholder:Charity Spires
Melissa NottingharrSponsor: