20230120ICL and NWEC to PAC 1-15.pdf

Marie Callaway Kellner (ISB No. 8470)
710 N 6th Street
Boise, ID 83701
[phone]
[e-mail]
Attorney for the Idaho Conservation League

F. Diego Rivas (MT State Bar No. 68806741, pro hac vice admission)
1101 8th Ave
Helena, MT 59601
[phone]
[e-mail]
Attorney for the NW Energy Coalition

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
THE AUTHORITY TO IMPLEMENT THE
RESIDENTIAL RATE MODERNIZATION
PLAN
)
)
)
)
)
)
CASE NO. PAC-E-22-15

FIRST PRODUCTION REQUEST
OF IDAHO CONSERVATION
LEAGUE AND NW ENERGY
COALITION TO ROCKY
MOUNTAIN POWER
COMES NOW the Idaho Conservation League (“ICL”) and NW Energy Coalition
(“NWEC”), jointly, with the following production requests for applicant Rocky Mountain Power,
a subsidiary of PacifiCorp (“Company”). Along with the answer to each question, please provide
any supporting documents, workpapers, calculations, communications, or information sources
the Company relies upon to support its answer. As required by IDAPA 31.01.01.228.02, please
indicate the witness who can answer questions regarding the response and who will sponsor the
response at any hearing. If any responses include Excel spreadsheets or other electronic files,
please provide them with all formulas intact and activated. As allowed by IDAPA
31.01.01.228.01, if the volume of any response indicates it would be more feasible to do so, ICL
and NWEC agree to the Company depositing the response in an electronic depository.
RECEIVED
Friday, January 20, 2023 3:34:31 PM
IDAHO PUBLIC
UTILITIES COMMISSION
This production request is ongoing. Accordingly, we respectfully ask Rocky Mountain
Power to provide additional documents and information that may supplement any initial
responses. We ask the Company to provide responses at earliest convenience if available before
the 21-day response period required by IDAPA 31.01.01.225.

Request For Production No. 01
Please provide all responses to production requests filed prior to intervention order No.
35655, dated January 5, 2023.

Request For Production No. 02
Please identify and provide the number of residential household subscribers to Schedule 8
who are low-income, defined by individual or family taxable income not exceeding 150% of the
federal poverty threshold. Please also provide the percentage of Schedule 8 subscribers who meet
this definition low-income subscribers.

Request For Production No. 03
Please identify and provide the number of residential household subscribers to Schedule
36 who are low-income, defined by individual or family taxable income not exceeding 150% of
the federal poverty threshold. Please also provide the percentage of Schedule 36 subscribers who
meet this definition for low-income subscribers.

Request For Production No. 04
Please confirm that Rocky Mountain Power has the legal discretion and capacity to file a
general rate case with the Idaho Public Utilities Commission at the time of the Company’s
choosing.

Request For Production No. 05
Please provide the following:
a. For each line transformer, number of customers connected and amount of energy that
flows through each.
b. Number of line transformers that serve multiple customers.
c. Number of line transformers that serve single customers.

Request For Production No. 06
Please provide all data, analysis, communications and work papers used to identify and
determine cost shifting between high-volume and low-volume customers of Schedule 8 and
Schedule 36 identified pages Di-5 and Di-7 of the Direct Testimony of Robert Meredith
submitted with the Company's application.

Request For Production No. 07
Please provide approved customer service charges for residential classes for each of
PacifiCorp’s utilities.

Request For Production No. 08
Please provide the most recently completed conservation potential assessment and end
use study completed for Rocky Mountain Power, including any updates, supporting
documentation, studies, memos, or other supplemental information used to develop each.

Request For Production No. 09
Please provide each of the following for the previous five years:
a. Energy efficiency targets as identified by the most recent conservation potential
assessment
b. Actual energy efficiency acquisition
c. Energy efficiency budget
d. Energy efficiency actual spend totals
e. Energy efficiency actual spend, broken down by category, including incentive payments,
marketing, administration and any other relevant category.

Request for Production No. 10
On page Di-12 of Meredith Direct Testimony, you state, “usage is considerably higher
for customers who utilize electricity as their main source of heating equipment compared to other
fuels.”
a. Please confirm that you mean “electricity usage.”
b. Does Rocky Mountain Power agree that customers who use gas as their main source of
heating equipment likely use considerably higher amounts of gas as compared to those customers
who use electricity for space and water heating?
Request For Production No. 11
On page Di-12 of Meredith Direct Testimony, you state, “penalizing customers with a
higher cost per kWh for usage in excess of a threshold is unfair and not supported by cost
causation.” Is Rocky Mountain Power claiming that current rates are not just and reasonable for
its customers?

Request For Production No. 12
Please provide the authorized revenue requirement and actual revenues for the last five
calendar years (2018-2022).

Request For Production No. 13
Please provide the number of energy efficiency program participants, by measure, for the
previous ten years as well as anticipated participants for future years.

Request For Production No. 14
Please provide the number of hours, and percentage of hours, Rocky Mountain Power
purchased power in the short-term market (i.e. day ahead, hour ahead). Please also provide the
percentage of those hours that occurred at system peak.

Request For Production No. 15
Please provide survey and survey results, in their entirety, for the email survey of
customers described on page Di-11 of Meredith Direct Testimony. Please also provide the
response rate, including total number of customers receiving the survey, and total number of
customers responding to the survey.

CERTIFICATE OF SERVICE
I hereby certify that on this 20th day of January, 2023, I delivered true and correct
copies of the foregoing FIRST PRODUCTION REQUESTS to the following persons via the
method of service noted:
/s/ Marie Callaway Kellner
Marie Callaway Kellner (ISB No. 8470)
Attorney for the Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702

/s/ F. Diego Rivas
F. Diego Rivas (MT State Bar No. 68806741)
Attorney for NW Energy Coalition
1101 8th Ave.
Helena, Montana

Electronic Mail Only (See Order No.
35058):

Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
[e-mail]

Rocky Mountain Power
Mark Alder
1407 W. North Temple, Suite 330
Salt Lake City, UT 84116
[e-mail]

Joe Dallas
Attorney for Rocky Mountain Power
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
[e-mail]

Commission Staff
Claire Sharp
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]

Clean Energy Opportunities for Idaho
(“CEO”)
Mike Heckler
Courtney White
3778 Plantation River Drive, Suit 102
Boise ID, 83703
[e-mail]
[e-mail]

Kelsey Jae
Attorney for CEO
920 Clover Dr.
Boise ID 83703
[e-mail]