20230918Staff 13 to PAC.pdf

RECEIVED
2023 September 18 4:34PM
IDAHO PUBLIC
UTILITIES COMMISSIONCLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8026
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO COMPLETE
THE STUDY REVIEW PHASE OF THE
COSTS AND BENEFITS OF ON-SITE
CUSTOMER GENERATION
-------------------
)
) CASE NO. PAC-E-23-17
)
)
) SECOND PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF
) TO ROCKY MOUNTAIN
) POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
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
TUESDAY, OCTOBER 10, 2023.
This Production Request is to be considered as 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 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 identify the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 18, 2023
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 13: Section 4.5 of the Company's On-Site Generation Study describes
an export avoided risk value of $1.24 per megawatt-hour ("MWh") based on the same risk values
as the 2021 Integrated Resource Plan ("IRP") energy efficiency stochastic risk analysis. The
2021 IRP Volume 1 provides an energy efficiency risk reduction credit of $3 .59/MWh.
PacifiCorp 2021 IRP Volume 1 at 213.
a.Please explain the difference between the energy efficiency risk reduction credit
presented in the 2021 IRP and export avoided risk value contained in the on-site
generation study in this case;
b.Please explain why it is appropriate to use the avoided risk values of energy
efficiency programs to represent the avoided risk value of customer exports; and
c.Please describe how customer generation export risk values are like energy
efficiency risk values, how they are different, and what the Company has done to
account for any differences.
DA TED at Boise, Idaho, this
i:umisc:prodreq/pace23. I 7 prod req 2
SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER
day of September 2023.
frJ r Claire Sharp Deputy Attorney General
2 SEPTEMBER 18, 2023
18th
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HA VE THIS 18th DAY OF SEPTEMBER 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST TO ROCKY
MOUNTAIN POWER, IN CASE NO. PAC-E-23-17, 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: [e-mail]
DAT A REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareguest@pacifi corp. com
ERIC LOLSEN
ECHO HA WK & OLSEN PLLC
PO BOX 6119
POCA TELLO ID 83205
E-MAIL: [e-mail]
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST
STE 2000
PORTLAND OR 97232
E-MAIL: [e-mail]
LANCE KAUFMAN PhD
2623 NW BLUEBELL PLACE
CORVALLIS OR 97330
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE