20221227Staff 18-19 to PAC.pdf

DAYN HARDIE VEDDEPUTYATTORNEYGENERAL
IDAHO PUBLIC UTILITIES COMMISSION ,PÑ 3:(|PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-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 A PRUDENCY )CASE NO.PAC-E-22-12DETERMINATIONONDEMANDSIDE)MANAGEMENT EXPENDITURES )THIRD PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy Attorney General,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than THURSDAY,
JANUARY 5,2023.1
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 Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0312.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 DECEMBER 27,2022
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.
REQUESTNO.18:Please provide workpapers for the 2021 cost-effectiveness analysis
results using 2019 IRP avoided costs for all Idaho Energy Efficiency offerings on the portfolio,
sector,program,and measure levels in Excel format with all formulas intact and enabled.Please
provide summaries on the results of the analysis and a comparison of results with the 2021 cost-
effectiveness analysis using 2021 IRP avoided costs.
a.Please account for Low-Income Weatherization Non-Energy Impacts ("NEI")
values referenced in Production Request No.16 and provide supporting
calculations for the NEI values.
REQUESTNO.19:Please respond to the followingon the Irrigation Load Control
("ILC")cost-effectiveness calculations regarding the "Benefit of value of Dispatched kW (At
Gen)"referenced on sheet "ILC,"cell B6 in the 2020 cost-effectiveness workpapers and sheet
"ILC Report,"cell C8 in the 2021 cost-effectiveness workpapers:
a.Please provide workpapers used to calculate the "Benefit of value of Dispatched
kW (At Gen)"for both 2020 and 2021'
b.Please provide a description (with sample calculations)of how the benefit value is
calculated and used in the cost-effectiveness calculations;and
c.Please explain if the "Benefit of value of Dispatched kW (At Gen)"is system or
Idahojurisdiction specific.
DATED at Boise,Idaho,this day of December 2022.
Dayn Haidie
Deputy Attorney General
i:umise:prodreq/pace22.12dhjjt prod req 3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER 27,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF DECEMBER 2022,SERVED THE FOREGOING THIRD PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOROCKYMOUNTAINPOWER,IN CASENO.PAC-E-22-12,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
TED WESTON EMILY WEGENERROCKYMOUNTAINPOWERMICHAELSSNOW
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWERSALTLAKECITYUT841161407WNTEMPLESTE320E-MAIL:[e-mail] SALT LAKE CITY UT 84116
[e-mail] E-MAIL:[e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
SECRE RY
CERTIFICATE OF SERVICE