20220204Staff 1-5 to PAC.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 11542
Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOIINTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ELECTRIC SERVICE
SCHEDULE 191. CUSTOMER EFFICIENCY
SERVICES RATE
CASE NO. PAC.E-22-03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Taylor Brooks, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
FEBRUARY 18,2022.r
This Production Request is 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 Staffir 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 4,2022
the person preparing the documents. Please 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 with formulas intact and enabled.
REQUEST NO. 1: Please provide Company workpapers in Excel format with all
formulas intact for all calculations included in the Application and in Attachments A, B, and C.
REQUEST NO. 2: Please provide supporting documentation and workpapers for the
forecasted DSM expenditur es in 2022, 2023, and 2024.
REQUEST NO.3: Please explain if the Company factored in a potential increase in
DSM expenditures from the PAC-E-21-I6 case currently pending before the Commission.
REQUEST NO. 4: Please provide a comparison of the Company's demand-side
management (DSM) budgeted expenses versus actual expenses for the last f,rve years.
REQUEST NO. 5: Forecasted DSM expenses in 2022 are expected to be more than $l
million greater than202l expenses. Please explain the increase in expenses and provide
supporting documentation. Please provide the response in Excel format displaying a comparison
in program and measure expenses from202l to2022.
DATED at Boise,Idaho, this 4ft day of February 2022.
General
i:umisc:prodreq/pace22.3tbtt prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
T
2 FEBRUARY 4,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4fl' DAY OF FEBRU AP(Y 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-22.03, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
MICHAEL SNOW
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: ted.weston@f'acificom.com
michael. snow@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi corp.com
EMILY WEGENER
ROCKY MOI.]NTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
J",4r2.,^
SECRETAY
CERTIFICATE OF SERVICE