20220304Staff 1-11 to PAC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
-,:-,-,::li''Ii:ii.',:'_r-., '--: r .- i.)
r'' l. Pii ?:00.. ,.;, I 1.,. "{ t i'! L
r-1 !lt-r,:
Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
UPDATE ELECTRIC SERVICE
REGULATION NO. 13 _ CURTAILMENT
PLAN FOR ELECTRIC ENERGY
CASE NO. PAC-E-22-04
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the ldaho Public Utilities Commission, by and through its attomey of record,
Riley Newton, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
MARCH 25,2022.
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 MARCH 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 on CD with formulas intact and enabled.
REQUEST NO. 1: Please describe how the Company provides notification of
curtailment or intemrption to state regulatory and reliability authorities. Please provide
supporting documentation and examples.
REQUEST NO.2: Please explain how customers were notified of the proposed update
to Electric Service Regulation No. 13 and provide copies of the notification.
REQUEST NO.3: Please explain how Demand Response participants were notified of
the proposed update to Electric Service Regulation No. 13. Please provide copies of the
notification.
REQUEST NO. 4: Please describe how the Company provides notification of
curtailment or intemrption to customers and the public. Please provide copies of notifications
and/or examples.
REQUEST NO.5: Has the Electric Service RegulationNo. 13 Curtailment Plan for
Electric Energy been approved by RC West Regional Reliability Coordinator? If so, please
provide documentation of approval.
REQUEST NO. 6: Regarding Curtailment Stages, Type of Curtailment, please define
"General Use Customers" and "Residential Customers."
REQUEST NO. 7: Please provide Block Rotation documentation to include:
a. Documents and maps that define the blocks and their attributes.
b. Schedule documentation that displays "what day of the week and time of day a
curtailment event would affect each block."
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MARCH 4,2022
REQUEST NO. 8: Please explain how "facilities essential to the public welfare" are
determined, tracked, updated, and notified?
REQUEST NO. 9: Regarding Section V. Notifications and Actions, Stage 3: Peak Load
Curtailment, it is stated that "the magnitude of the event will dictate the administrative level to
which external notifications will be made." Is there an extemal notification communication
plan? If so, please provide a copy of the communication plan.
REQUEST NO. 10: Regarding Section V. Notifications and Actions, Stage 5:
Emergency Load Shed Groups, please define "all intemal and extemal notifications" and what
plan this communication would be a part of.
REQUEST NO. 11: Regarding Section III. Curtailment Stages, in the stage description
Estimated Curtailment Percent has not been updated to reflect changes to Types of Curtailment.
Please explain how the Estimated Curtailment Percentages and the accuracy of the estimates are
calculated.
#o*ofMarch 2022.DATED at Boise, Idaho, this
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
Riley N
Deputy Attorney
3 MARCH 4,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF MARCH 2022, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TrrE COMnIISSTON STAFF
TO ROCKY MOUNTATN POWER, IN CASE NO. PAC-E-22-04, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : [e-mail]
idahodockets@pac ifi com. com
DATA REQUEST RESPONSE CENTER
E-MAIL OIILY:
datareq uest@pacifi com.com
EMILY WEGENET\
ROCKY MOTINTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE