20220914Staff 1-11 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 9917
Steet Address for Express Mail:
1133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEF'ORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR A PRT]DENCY
DETERMINATION ON DEMAI\D SIDE
MANAGEMENT EXPENDITURES
CASE NO. PAC.EAZ-D
FIRST PRODUCTION
REQUEST OF THE
COMNIISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commissiorq by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and infomration as soon as possible, but no later than WEDNESDAY,
ocToBER 5,2022.
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 behalt 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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQI.JEST
TO ROCKY MOI.JNTAIN POWER
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I SEPTEMBEP. 14,2022
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 a list of all expenses charged to the Company's
Demand Side Management (*DSM") tariffrider account for years 2020 and 2021. Please
include date, vendor, amount, type of expense, and a brief description of the expense. Please
separate expenses by program so that the total amount for each progfirm ties to the amounts
reported in the Annual DSM reports.
REQUEST NO. 2: Please provide the monthly interest calculations for the balance in
the DSM tariffrider account for2020-2021.
REQUEST NO. 3: Please provide the tariffrider revenue by month and by customer
class for 2020-2021.
REQUEST NO.4: Please provide the cost-effectiveness workpapers and calculations
for all DSM programs foryears 2020 and202l n Excel format.
a. Please provide the basis used to calculate and include the Non-Energy Benefits
("NEBs") value for the Low-Income Weatherization program.
REQUEST NO. 5: Please provide a listing of all legal and consulting fees, including,
but not limited to Evaluation, Measurement and Verification ("EM&V"), charged to the Idaho
DSM tariffrider during 2020 and202l. lf arry of the fees were allocated among jurisdictions,
please provide the calculation and explanation of the allocation.
REQIJEST NO. 6: Please provide the amount of labor expense charged to the DSM
tariffrider for the years 2020 and202l. For each of those years, please also include the number
of Full Time Equivalents funded by the rider. Please also provide the general wage adjustnent
percentage for non-union personnel approved by the Compensation Committee of the Board of
Directors for each year.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBERI ,2022
REQUEST NO. 7: Please provide a current organizational chart by title and name
showing all Rocky Mountain Power and contract employees who charge time to the DSM rider.
Please include complete job descriptions, required qualifications, salary ranges, bonus
opportunities, and total compensation ranges, including benefits, for all employees identified in
this request.
REQUEST NO.8: Please provide copies of all intemal audit reports referencing any of
the Company's DSM expenses and processes for 2020 to current date. If no reports were issued,
please provide the date and scope of the audit and all internal auditor workpapers.
REQUEST NO. 9: Please provide the following information related the Energy
Conservation Education kits ("Kits") for the Low-Income Weatherization program.
a. Please provide the Kit inventories for EICAP and SEICAA at the beginning and
end of the 2020 and202t programyears.
b. Please provide all invoices for Kits ordered by either agency for 2020 and202l
program years.
c. Please breakdown total cost of the Kits in 2020 and,202l per agency by Kit
contents, packaging, shipping, and administration/overhead.
d. Please breakdown each individual Kit cost in 2020 and202l per agency by Kit
contents, packaging, shipping, and administration/overhead.
e. Please provide a reconciliation of Kit purchases and Low-Income expenses for the
EICAP and SEICAA for each year for 2018 to 2021. Please clearly identiff
which program year expenses were charged to the Customer Efliciency Tariff
Rider.
REQUEST NO. l0: Please provide detailed data of the Irrigation Load Control program
administered and managed by EnerNOC for years 2020 and 2021. This includes, but is not
limited to the following:
a. the date and time for each initiated irrigation event;
b. the amount of demand saved in megawatts for each event hour;
c. the amount of energy saved in megawatt-hours for each event hour;
FIRST PRODUCTION REQUEST
TO ROCKY MOI.TNTAIN POWER 3 SEPTEMBER 14,2022
d. the value of demand saved in each event hour;
e. the program cost for demand saved in each event hour;
f. the value and cost of energy saved in each event hour;
g. the corresponding market price of energy for each event hour;
h. a breakdown of incentives paid to each participant by event;
i. any event adjustnent for participant opt-outs; and
j. any event adjusbnents for non-participation.
REQUEST NO. 11: Please provide Appendix A referenced in the footrote nthe2020
Idaho Energy Efficiency and Peak Reduction Annual Report at 16.
DATED at Boise, Idaho, this lry day of Septerrber 2022.
Deputy Attomey General
i:umisc:prodreq/pace22.l2dhiit prod req I
FIRST PRODUCTION REQI.JEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 14, 2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I }I.AVE THIS 14lh DAY OF SEPTEMBER 2022,
SERVED THE FOREGOING FrRST PRODUCTTON REQUEST OF TrrE COMMISSION
sTArF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-22-I2, BY
E.MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOI.JNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT t4I 16
E-MAIL: ted.rveston{@paci ficom.com
idahodockets@oaci fi com.com
DATA REQLJEST RESPONSE CENTER
F-MAIL ONLY:
datare o uest{doaci fr com.com
EMILY WEGENER
MICHAEL S SNOW
ROCKY MOI.JNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84T 16
E-MAIL: [e-mail]
m icheal.snorv@mci ficorp.com
CERTIFICATE OF SERVICE