20220714Staff 1-3 to PAC.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 8026
Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ELECTRIC SERVICE
SCHEDULE 191 - CUSTOMER EFFICIENCY
SERVICES RATE
CASE NO. PAC.E-Zz-IO
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,
Claire Sharp, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than THURSDAY,
JULY 28,2022.1
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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JULY 14,2022
the person preparing the documents. Please also identify 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 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 Demand-Side Management (DSM) expenditur es rn 2022, 2023, and 2024. Please
provide any calculations relevant to the DSM Account Analysis in Excel format with all
formulas intact.
REQUEST NO.3: Please provide a comparison of the Company's DSM budgeted
expenses versus actual expenses for the last five years.
DArED at Boise, Idaho, thi, I Y% of July 2022.
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Claire Sharp
Deputy Attorney General
i:umisc:prodreq/pace22. l0cslc prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 14,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS I5d' DAY OF ruLY 2022, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMIVIISSION STAFF
TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-22-10, 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 : ted.weston@f'acifi corp.com
idahodockets@pac ifi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareo uest@naci fi corp. com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE