20230306PAC to ICL-NWEC 1-15.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
March 6, 2023 Marie Callaway Kellner (ISB No. 8470) 710 N 6th Street Boise, ID 83701
[e-mail] (C)
Attorney for the Idaho Conservation League
F. Diego Rivas (MT State Bar No. 68806741, pro hac vice admission)
1101 8th Ave Helena, MT 59601 [e-mail] (C) Attorney for the NW Energy Coalition RE: ID PAC-E-22-15
ICL-NWEC Set 1 (1-15) Please find enclosed Rocky Mountain Power’s Responses to ICL-NWEC 1st Set Data Requests 2-15. Also provided are Attachments ICL-NWEC 5, 7, 9, 12, 13, and 14-3. Confidential Attachments ICL-NWEC 14-1 and 14-2 are posted to BOX. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt from Public Review, and further subject to the Protective Agreement executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely, ____/s/____ Mark Alder Manager, Regulation Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Claire Sharp/IPUC [e-mail] Mike Heckler/CEO [e-mail] Courtney White/CEO [e-mail] Kelsey Jae/CEO [e-mail]
RECEIVED
2023 March 6, PM 12:11
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 2
ICL-NWEC Data Request 2 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.
Response to ICL-NWEC Data Request 2
The Company assumes that the reference to “Schedule 8” is intended to be a reference to Idaho Schedule 1. Based on the foregoing assumption, the Company responds as follows:
Based on the 12-month period from June 2021 through May 2022, there were
about 973 Schedule 1 customers defined as low-income; about 2 percent of the total Schedule 1 customers in Idaho. The Company identified customers who received energy assistance during this period as being low-income.

Recordholder: James Zhang Sponsor: Robert M. Meredith

PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 3
ICL-NWEC Data Request 3 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.
Response to ICL-NWEC Data Request 3
Based on the 12-month period from June 2021 through May 2022, there were about 177 Schedule 36 customers defined as low-income; about 2 percent of the total Schedule 36 customers in Idaho. The Company identified customers who received energy assistance during this period as being low-income.

Recordholder: James Zhang
Sponsor: Robert M. Meredith

PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 4
ICL-NWEC Data Request 4 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.
Response to ICL-NWEC Data Request 4
PacifiCorp objects to this request as it calls for a legal conclusion, speculation,
and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection, Rocky Mountain Power (RMP) responds as follows: Pursuant to Idaho Code 61-622, RMP must seek approval from Idaho Public
Utilities Commission (IPUC) to increase its tariffed electric rates. The timing of
any filing before the IPUC may be impacted by various other legal and regulatory requirements and considerations.

Recordholder: Joe Dallas Sponsor: Joe Dallas
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 5
ICL-NWEC Data Request 5 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. Response to ICL-NWEC Data Request 5 Please refer to Attachment ICL-NWEC 5. Note: the kilovolt ampere (kVA) value
refers to the size of the transformer.
Recordholder: Thom Riese

Sponsor: Robert Meredith
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 6
ICL-NWEC Data Request 6 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. Response to ICL-NWEC Data Request 6

The Company assumes that the reference to “Schedule 8” is intended to be a reference to Idaho Schedule 1. Based on the foregoing assumption, the Company responds as follows: The Company’s work paper “COST ID 2021 FINAL @8m Increase.xlsx” and
Exhibit No. 1 supporting the direct testimony of Company witness, Robert M.
Meredith show the details of the unit cost of service (COS) by functions and demonstrates the cost shifting between high-volume and low-volume customers of Schedule 1 and Schedule 36. In addition to the above, the Company has not
performed other analysis nor does the Company have additional work papers.
Recordholder: James Zhang Sponsor: Robert M. Meredith
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 7
ICL-NWEC Data Request 7 Please provide approved customer service charges for residential classes for each of PacifiCorp’s utilities.
Response to ICL-NWEC Data Request 7 Please refer to Attachment ICL-NWEC 7.

Recordholder: James Zhang Sponsor: Robert M. Meredith
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 8
ICL-NWEC Data Request 8 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. Response to ICL-NWEC Data Request 8

The Company’s most recently completed conservation potential assessment used for PacifiCorp’s 2021 Integrated Resource Plan is publicly and can be accessed by utilizing the following website link to “2021 IRP support and studies”: https://www.pacificorp.com/energy/integrated-resource-plan/support.html

The webpage above includes Volume I and Volume II of the potential assessment, as well as Appendices A through K and the underlying measure database and assumptions documenting the assessment’s inputs.

Recordholder: Peter Schaffer Sponsor: Clay Monroe

PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 9
ICL-NWEC Data Request 9 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.
Response to ICL-NWEC Data Request 9
Energy efficiency targets are informed by technical achievable potential provided
in the Conservation Potential Assessment. The Company’s integrated resource plan’s (IRP) selection of cost-effective energy efficiency informs the basis of the Company’s energy efficiency targets. Energy efficiency selections in PacifiCorp’s 2021 IRP are provided in Volume II, Appendix D (Demand-Side Management Resources), Table D.4 (First Year Energy Efficiency Resource Selections (2021
IRP Preferred Portfolio)).
The Company’s 2021 IRP is publicly available and can be accessed by utilizing the following website link:

Integrated Resource Plan (pacificorp.com) Please refer to Attachment ICL-NWEC 9 which provides the Company’s Idaho Annual Energy Efficiency and Peak Reduction Reports (Annual Reports) for program years 2017 through 2021. Note: the Annual Report for 2022 will not be
available until Q2 2023. The Annual Reports are also publicly available under
Case No. PAC-E-05-10 and can be accessed by utilizing the following website link to the Company’s website: https://www.pacificorp.com/environment/demand-side-management.html.
The formatting and content of the Annual Reports has changed over time, but each Annual Report’s respective tables and content throughout each document provides actual energy efficiency acquisition, energy efficiency budgets, energy efficiency actual spend totals, and various breakdowns of spend, incentives,
measure categories, outreach and communications, participation, and other
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 9
relevant categories. Recordholder: Peter Schaffer / Michael Snow

Sponsor: Clay Monroe
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 10
ICL-NWEC Data Request 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? Response to ICL-NWEC Data Request 10
(a) Confirmed.
(b) Agreed.

Recordholder: Robert M. Meredith Sponsor: Robert M. Meredith
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 11
ICL-NWEC Data Request 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? Response to ICL-NWEC Data Request 11

No, the Company is not claiming that current rates are not just and reasonable for its customers. As the Company’s witness, Robert M. Meredith has stated and explained in his direct testimony, the Company’s current residential rate structure does not adequately reflect cost, and the effect of a low Customer Service Charge and tiered energy charges is that customers with low monthly usage are
subsidized by customers with higher monthly usage.
Recordholder: Robert M. Meredith

Sponsor: Robert M. Meredith
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 12
ICL-NWEC Data Request 12 Please provide the authorized revenue requirement and actual revenues for the last five calendar years (2018-2022).
Response to ICL-NWEC Data Request 12 The Company objects to this request as overly broad and outside the scope of this
proceeding. The requested information is also not likely to lead to admissible
evidence in this proceeding. Notwithstanding the foregoing objection, the Company responds as follows: Please refer to Attachment ICL-NWEC 12.

Recordholder: James Zhang Sponsor: Robert M. Meredith
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 13
ICL-NWEC Data Request 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.
Response to ICL-NWEC Data Request 13 Please refer to the Company’s response to ICL-NWEC Data Request 9 which
includes a description and copy of the Company’s 2017 through 2021 Idaho
Annual Energy Efficiency and Peak Reduction Reports (Annual Reports). Please refer to Attachment ICL-NWEC 13 which provides the Company’s Annual Reports for 2012-2016. The Annual Reports provide variations of participation by measure category, number of installations, number of homes served, etc., and is commensurate with the level of data the Company tracks and reports on. With
respect to anticipated participants for future years, the Company intends to
maintain participation levels similar to that which is provided in the most recent Annual Reports.

Recordholder: Michael Snow Sponsor: Clay Monroe

PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 14
ICL-NWEC Data Request 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.
Response to ICL-NWEC Data Request 14
The Company objects to this request as overly broad and unduly burdensome. The
requested information is also not likely to lead to admissible evidence in this proceeding. Notwithstanding the foregoing objection, the Company responds as follows: The Company has not performed the requested analysis.

Please refer to Confidential Attachment ICL-NWEC 14-1 which provides a summary of hourly day-ahead and real-time purchase transactions during calendar year 2022 (megawatts-hours (MWh)). Please refer to Confidential Attachment
ICL-NWEC 14-2 which provides hourly jurisdictional load data for calendar year
2022 (megawatts (MW)). Please refer to Attachment ICL-NWEC 14-3 which provides the Company’s peak / energy information for calendar year 2022. Note: calendar year 2022 data is preliminary and subject to change. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules of
Procedure No. 67 – Information Exempt from Public Review, and further subject to the Protective Agreement executed in this proceeding.

Recordholder: Ray Zacharia / David Novom Sponsor: Doug Young
PAC-E-22-15 / Rocky Mountain Power March 6, 2023 ICL-NWEC Data Request 15
ICL-NWEC Data Request 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. Response to ICL-NWEC Data Request 15

Please refer to the Company’s response to IPUC Data Request 3. The survey was sent to 45,560 unique Idaho customers email accounts, of which 3,035 Idaho customer responded, resulting in a response rate of 6.7 percent.

Recordholder: Robert M. Meredith / Lee Elder Sponsor: Robert M. Meredith / Lee Elder