20221202Staff 5-6 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
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Street Address for Express Mail:
1I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTTLITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO IMPLEMENT THE
RESIDENTIAL RATE MODERNIZATION PLAN
CASE NO. PAC.E-22-I5
SECOND 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 ("Company")
provide the following documents and information as soon as possible, but no later than
FRTDAY, DECEMBER 23, 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 behall 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.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 DECEMBER2,2022
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. 5: Please provide the annual Cost-of-Service amounts (by function) for
Schedule Nos. I and 36. Also, please clariff how the Company associated each functional area
in Exhibit No. I as either 'Energy-Related' or 'All Other.'
REQUEST NO. 6: Please explain how the kilowatt-hour ("kWh") time of use
reallocations were determined and the basis used to determine the changes for Exhibit No. 2,
Schedule No. 36. Please include all workpapers showing the calculations used for the
reallocations in Excel format with formulas enabled.
DATED at Boise, Idatro, this 2ND day of December 2022.
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SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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Deputy Attorney General
2 DECEMBER2"2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2M DAY OF DECEMBER 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQTIEST OF THE
C0MMISSION STAFF TO ROCKY MOTTNTATN POWE& rN CASE NO. PAC-E-22-15,
BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONILY:
datarequest@pac ifi com.com
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST, SUITE 2OOO
PORTLAND OR97232
E-MAIL: [e-mail]
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SECRETAn/
CERTIFICATE OF SERVICE