20210914Staff 196-199 to PAC-Redacted.pdf

DAYN HARDIE (ISB No. 9917)
JOHN R. HAMMOND, JR. (ISB No. 5470)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
,1i^ i1rl . ,1*{'t
:.-\,r-'El;J
.,:,, I1i ll+ fil{ ll: h3
'i i'1,,).-r..v. ili,''.',,i.i;liC;i
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attomeys 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-21-07
REDACTED EIGHTH
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 John R. Hammond, Jr., Deputy Attorneys General, request that Rocky
Mountain Power ("Company") provide the following documents and information as soon as
possible, but no later than TUESDAY, SEPTEMBER 28, 2021.r
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
I Stuffit requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
REDACTED EIGHTH PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER I
)
)
)
)
)
)
)
)
SEPTEMBER 14,2O2I
the person preparing the documents. Please also identifr 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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 196: Please describe the current Energy Conservation Education
Program funded by RMP through its tariffrider and administered by the Eastem Idaho
Community Action Partnership (EICAP) and Southeastern Idaho Community Action Partnership
(SEICCA). If the two agencies tue administering different or distinct programs, please explain
why.
REQUEST NO. 197: For years 2018 through2020, of the $50,000 in annual funding
provided for Energy Conservation Education please provide: a) the total number of customers
served by the program each year; b) the total dollar amount of funds that were unused and
carried over to the following calendar year; and c) the reasons why the funds were unused.
REQUEST NO. 198: For years 2018 through2020, how many participants were under
winter protection each year? How many of those participants agreed to be placed on the winter
payment plan? How many were unable to meet their monthly payment?
REQUEST NO. 199: Please provide data and any analyses showing the following
transmission categorized capital investments are directly beneficial to PacifiCorp's Bulk Electric
System (NERC definition - Bulk Electric System (BES)
www.nerc.com/palRAPA/Pages/BES.aspx. Please also provide an explanation with specific
examples for how these investments are beneficial to Idaho customers for each project listed
below:
REDACTED EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 14,2O2I
t"tbDATED at Boise, Idaho, this day of September 2021
Deputy Attomey General
i:umisc:prodreq/pace2l .Tdhmhjt prod req 8
REDACTED EIGHTH PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER 3 SEPTEMBER 14,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING REDACTED EIGHTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE
NO. PAC-8.21-07, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOI-]NTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pac i fi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@paci fi corp.com
ANTHONY YANKEL
I27OO LAKE AVE
TINIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #140
CHESTERFIELD MO 63017
E-MAIL : [e-mail]
[e-mail]
LANCE KAUFMAN
AEGIS INSIGHT
E-MAIL: [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOI.INTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
matther,.mcvee@pacifi corp.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E'MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
[e-mail]
JAMES R SMITH
MIKE VEILE
BAYER CORPORATION
E-MAIL: [e-mail]
[e-mail]
KEVIN HIGGINS
COURTNEY HIGGINS
MILLI PICHARO
NEAL TOWNSEND
ENERGY STRATEGIES
E-MAIL: [e-mail]
chi [e-mail]
mpichardo@energy strat.com
ntownsend@energystrat. corn
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: val.steiner@,itafos.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N ITTH ST
BOISE ID 83702
E-MAIL : [e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL: [e-mail]
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL : [e-mail]
,.i^ /b.*^
SECRET/iF.z
CERTIFICATE OF SERVICE