20230317CEO to PAC 1-3.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Phone: (208) 391-2961
[e-mail]
Attorney for the Clean Energy Opportunities of Idaho
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
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CASE NO. PAC-E-22-15
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO’S FIRST PRODUCTION
REQUEST TO ROCKY MOUNTAIN
POWER
COMES NOW Clean Energy Opportunities for Idaho (CEO), by and through its attorney
of record, Kelsey Jae of the firm Kelsey Jae LLC, and requests that Rocky Mountain Power (“the
Company”) provide the following documents within 21 days or sooner if possible.
This Production Request is continuing, and the Company 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 produced. Please provide answers to each question
with supporting workpapers that provide detail or are the source of information used in
calculations. Please provide any Excel files with formulas active. Additionally, please include the
name and phone number of the person preparing the document, and the name, location, and
phone number of the record holder and, if different, the witness who can sponsor the answer at
hearing if need be. As allowed by IDAPA 31.01.01.228.01, CEO agrees to the Company
depositing the response in an electronic depository.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 1
PAC-E-22-15
RECEIVED
Friday, March 17, 2023 3:09:19 PM
IDAHO PUBLIC
UTILITIES COMMISSION
REQUEST NO 1. The Company's application describes on page 4 that a customer’s
decision to opt into the Schedule 36 time of use program should be motivated by “a desire to
shift load to lower cost times”. What are the potential benefits to the public interest that may
result from customers shifting load into lower cost times?
REQUEST NO 2. On page 14 of the testimony provided by Robert Meredith, Mr.
Meredith explains that the on-/off peak periods proposed for future use in Schedule 36 are based
on an earlier review of times when “the Energy Imbalance Market (“EIM”) pricing was the
highest”.
In PAC-E-21-07, Exhibit 54 , PacifiCorp presented average Energy Imbalance Market
Pricing weighted by PacifCorp’s Hourly Loads for the time period of three years ending
December 31, 2020. Please provide, in Excel format, the same information provided in that
Exhibit 54 but based upon EIM prices and PacifiCorp load data for the year ending December
31, 2022.
REQUEST NO 3. For each month during the years 2018 through 2022 inclusive, please
provide, in Excel format, the total dollar amount billed monthly for energy charges and customer
service charges under the following four conditions:
1. The amounts actually billed to Schedule 1 customers during each of those 60 months.
2. The amounts those Schedule 1 customers would have been billed under the proposed
“year 5” rates where the summer season energy charge is 8.6574 cents/kWh, the winter
season energy charge is 7.2145 cents/kWh, and the customer service charge is
$29.25/month.
3. The amounts actually billed to Schedule 36 customers during those months.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 2
PAC-E-22-15
4. To the extent the historic hourly Schedule 36 customer load data is available, the
amounts those Schedule 36 customers would have been billed by applying the proposed
“year 5” rates with seasonal and on-peak/off-peak durations updated as proposed and
where the Summer season on peak energy charge is 14.7738 cents/kWh, the Summer
season off-peak energy charge is 4.7423 cents/kWh, the Winter season on-peak energy
charge is 12.6572 cents/kWh, the Winter season off-peak energy charge is 4.3600
cents/kWh, and the Customer service charge is $29.25/month.
DATED this 17th day of March, 2023.
Respectfully submitted,
______________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 3
PAC-E-22-15
CERTIFICATE OF SERVICE
I hereby certify that on this 17th day of March, 2023, I delivered true and correct copies
of the foregoing PRODUCTION REQUEST to the following persons via the method of service
noted:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
Idaho PUC Staff
Claire Sharp
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Idaho Conservation League
Marie Callaway Kellner
[e-mail]
Brad Heusinkveld
[e-mail]
Northwest Energy Coalition
F. Diego Rivas
[e-mail]
Pacificorp, dba Rocky Mountain Power
Mark Alder 1407 West North Temple, Suite
330 Salt Lake City, UT 84116
[e-mail]
Joe Dallas 825 NE Multnomah Street, Suite
2000 Portland, OR 97232
[e-mail]
Data Request Response Center
[e-mail]
_____________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 4
PAC-E-22-15