20220203Staff 1-11 to PAC.pdf

^-1 r:: :-" :: ! \ / i- ['];-1 .-.a'*lYLvDAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-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 REVERT THE BLUE SKY BLOCK VALUE
TO 1OO KILOWATT HOURS FROM 2OO
KILOWATT HOURS
CASE NO. PAC.E-22-02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than THURSDAY,
FEBRUARY 17,2021.r
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
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I FEBRUARY 3,2022
the person preparing the documents. Please also identifu 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. l: Please provide a copy of the Idaho 2021 Annual Blue Sky Program
Report and workpapers. If not complete, please provide in draft form.
REQUEST NO.2: Please provide the total Renewable Energy Credit ("REC")
purchases for Idaho in202l, and include RECs that were purchased in2022 to fulfill 2021
program requirements.
REQUEST NO.3: Please provide the timing of the reconciliation of REC purchases
and account balances.
REQUEST NO. 4: Please provide supporting documentation and workpapers for all
values listed in2022 Forecasted Budgets shown in Table 1 of the Application.
REQUEST NO. 5: Please provide a detailed break-down of the 2021 program
forecasted budget against actual revenue and actual expenses for 2021, including but not limited
to: administration, marketing costs, community education and outreach, and program fund
balance.
REQUEST NO. 6: Please describe the efforts the Company made in202l to promote
initiatives, education, and project opportunities in Idaho.
REQUEST NO. 7: Please provide a list of projects that were funded during 2021
REQUEST NO. 8: Please provide annual and cumulative ldaho 2021participation
results for Blue Sky program. Please breakdown participation by month.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 FEBRUARY 3,2022
REQUEST NO. 9: For the Blue Sky progftrm in202l,please provide total blocks and
kWh purchased by Blue Sky customers for ldaho and for the Company's system.
REQUEST NO. 10: Please provide program REC purchase detail including: generator,
location, quantity, total price, price per REC, date purchased, and weighted average price on
behalf of Idaho customers in 2021.
REQUEST NO. 1l: In the Company's previous filing PAC-E-19-L7,the Company
sought approval from all six states to maintain uniformity in the Program management
operations. Is it the Company's intent to file the changes proposed in this case in the Company's
other jurisdictions? If not, please explain. If so, please state whether the Company has applied
in any other state and provide the docket number, or confirm when the Company plans to file
with the other states.
zrJ)-DATED at Boise, Idaho, this day of February 2022.
Deputy Afforney General
i:umisc:prodreq/pace22.2dhtnctt prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J FEBRUARY 3,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF FEBRUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
CoMMISSION STAFF TO ROCKY MOIINTAIN POWE& rN CASE
NO. PAC-E-22-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
MICHAEL SNOW
ROCKY MOI.INTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@pacifi corp.com
michael. snow@pac ifi corp. com
DATA REQI.JEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp.com
EMILY WEGENER
ROCKY MOLINTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: emilLwegener@nacifi com.com
ARY
CERTIFICATE OF SERVICE