20230126Staff 20-21 to PAC.pdf

DAYN HARDIE ED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 6 MD i 5
PO BOX 83720
BOISE,IDAHO 83720-0074 SS:N(208)334-0312
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-22-12
DETERMINATION ON DEMAND SIDE )MANAGEMENT EXPENDITURES )FOURTH 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,
FEBRUARY 9,2023.1
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 telephonenumber of
1 Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0312.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JANUARY 26,2023
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.20:Please explain if there have been any changes in the past ten years
to the Company's practices regarding the use of Integrated Resource Plan avoided cost data to
evaluate the cost-effectiveness of its programs for a given year and for program planning for the
next year (i.e.,use the avoided costs available at program planning for evaluating the cost-
effectiveness for that given year,use the most current avoided costs at the time of evaluation,
etc.).
REQUESTNO.21:Please respond to the followingregarding the Wattsmart Homes
electronics measure category.
a.Please provide a list of offerings provided in the Wattsmart Homes electronics
measure category for the 2018,2019,2020,and 2021 program years.
b.Please list any changes to the category's offerings or incentives for the 2018,
2019,2020,and 2021 program years.
c.Please detail the Company's previous efforts and current plans to address the cost-
effectiveness of the measure category.
DATED at Boise,Idaho,this1Piday of January 2023.
yn Har "e
Deputy AttorneyGeneral
i:umise:prodreq/pace22.12dhjjt prod req 4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JANUARY 26,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF JANUARY 2023,SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOROCKYMOUNTAINPOWER,IN CASE
NO.PAC-E-22-12,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
TED WESTON EMILY WEGENER
ROCKY MOUNTAIN POWER MICHAEL S SNOW
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]
SECRET RY
CERTIFICATE OF SERVICE