20221201Staff 1-4 to PAC.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSTON
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 8026
qiCEIVED
;;!: DIC - | PH t: 07
' '( i.ir'l.',.lil iUBLIii'll-i; CCUl,,{l CN
U
Irb
Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES 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
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its afforney 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
THURSDAY, DECEMBER 22, 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 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
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
)
)
)
)
)
)
)
)
)
1 DECEMBER 1,2022
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: The Company proposes that "the time of use definitions for
Schedule 36 be changed to those used for Schedule 9." Meredith Direct at 13. The Company
also explains that the new on-peak period "better reflects times when it is more costly for the
Company to serve." Meredith Direct at 14. Please provide details of any other "on-peak"
definitions used by the Company in other programs (such as Demand Response).
REQUEST NO. 2: Please provide the analysis similar to Exhibit No. 3. (Dollar
Distribution of Monthly Bill Impacts Across Customers Over Full Transition Period) pages 5, 7,
9 and 11, but only use the usage for each of the following months:
a. February;
b. Muy;
c. August; and
d. November.
REQUEST NO.3: Please provide studies the Company has on the electricity usage of
low-income customers.
REQUEST NO. 4: Please provide an analysis similar to Exhibit No. 3 (Dollar
Distribution of Monthly Bill Impacts Across Customers Over Full Transition Period), pages 5, 7,
9 and 11, but only use the usage from customers in ldaho that have used low-income programs
(i.e., LIHEAP, LIWA, etc.).
FIRST PRODUCTTON REQUEST
TO ROCKY MOI-]NTAIN POWER 2 DECEMBER 1,2022
DATED at Boise, Idatro, this lsr day of December 2022.
( o^ia gl^""A
Claire Sharp
Deputy Attorney General
t
i:umisc:prodreq/pace22.5csmsjt prod req I
FIRST PRODUCTION REQUEST
TO ROCKYMOUNTAIN POWER 3 DECEMBERI,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IST DAY OF DECEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION
sTAFf,' TO ROCKY MOUNTATN POWE& IN 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 84116
E-MAIL: mark.alder@pacifi com.com
DATA REQUEST RESPONSE CENTER
E.MAIL OI[LY:
datarequest@nacifi corp.com
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST, SUITE 2OOO
PORTLAND OR 97232
E-MAIL: joseph.dallas@,pacifi corp.com
SECRETARY
CERTIFICATE OF SERVICE