20230105Bayer to PAC 1-12.pdf

BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER 1
Thomas J. Budge, ISB No. 7465 RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391 (208) [e-mail]
Attorney for P4 Production, L.L.C., a subsidiary of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR AUTHORITY TO IMPLEMENT A COMMERCIAL AND INDUSTRIAL DEMAND RESPONSE PROGRAM
CASE NO. PAC-E-22-13
BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER
P4 Production, L.L.C., a subsidiary of Bayer Corporation (“Bayer”), by and through
counsel, submits this first set of production requests to Rocky Mountain Power pursuant to Rule
225 of the Commission’s rules of procedure, IDAPA 31.01.01.225.
These productions request is to be considered continuing; therefore, the Company should
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that are responsive to these requests.
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 identify the name, job title, location, and telephone
number of the record holder. Please provide all Excel and other electronic files on a thumb drive
or via email with formulas intact and activated.
The term “production requests” as used herein includes written interrogatories and
requests for admission.
Production Requests
Request No. 1: Please provide a copy of all production requests received from Commission Staff and other parties.
RECEIVED
Thursday, January 5, 2023 10:38:25 AM
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER 2
Request No. 2: Please provide a copy of your responses to production requests received from Commission Staff and other parties.
Request No. 3: Please provide a copy of the workpapers supporting the Application filed in this matter. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact.
Request No. 4: Please state the number of Company customers in Idaho with a load
greater than 500 kW. Request No. 5: Please state the number of Company customers in Idaho that the Company anticipates may participate in the Wattsmart Business Demand Response Program (the
“Program”), and state the collective load such customers.
Request No. 6: Please explain why the Company proposes that the Program be treated as a situs program as opposed to a system program.
Request No. 7: Please state the anticipated effect on rates charged to each customer class
in Idaho if the Program achieves 15 MW of curtailable demand response. Request No. 8: If the Program offered by the Company in Idaho generated more interest than 15 MW, would the Company expand the program demand response limit beyond 15 MW?
Request No. 9: Please identify by name and case number all applications filed by the Company in other jurisdictions for similar commercial and industrial demand response programs to the Program. For those jurisdictions that have an approved program similar to the Program, please provide the tariffs authorizing that program.
Request No. 10: If the Company anticipates filing an application in one or more other states for a commercial and industrial program similar to the Program, please identify which states in which the Company anticipates filing such application and the anticipated filing date. Please provide a detailed discussion of the Program parameters.

Request No. 11: Does the Company anticipate that the Wattsmart Program and/or other programs proposed by the Company will replace the current interruptible products included in the Bayer special contract?
Request No. 12: Does the Company anticipate that similar programs offered in other
states may impact the special contracts of other customers?
BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER 3
DATED this 5th day of January, 2023.

RACINE OLSON, PLLP
By: ___________________________
THOMAS J. BUDGE
BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 5th day of January, 2023, I served a true, correct and
complete copy of the foregoing document by email to each of the following:
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074 [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8, Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074
[e-mail]
Michael S. Snow PacifiCorp/dba Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116 [e-mail]
PacifiCorp/dba Rocky Mountain Power 825 NE Multnomah Street, Suite 2000
Portland, OR 97232
[e-mail]
Data Request Response Center
PacifiCorp [e-mail]
Eric L. Olsen
Attorney for Idaho Irrigation Pumpers
Association, Inc. ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205 [e-mail]
Idaho Irrigation Pumpers Association, Inc.
2623 NW Bluebell Place Corvallis, OR 97330 [e-mail]
Brian C. Collins
Greg Meyer
Bayer Corporation 16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017
[e-mail]

THOMAS J. BUDGE