20231018Staff 1-3 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 8 AM 0:54
PO BOX 83720
BOISE,IDAHO 83720-0074 Sl(3N(208)334-0312
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PROPOSED TARIFF )CHANGES TO ELECTRIC SERVICE )CASE NO.PAC-E-23-21
REGULATION NO.12 (LINE EXTENSION))
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy AttorneyGeneral,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
WEDNESDAY,NOVEMBER 8,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 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.
REQUESTNO.1:Please provide the original basis for the current Extension
Allowance for customers over 1,000 kVA of up to nine times the estimated monthlyrevenue.
REQUESTNO.2:In reference to customers with an executed Master Electric Service
Agreement ("MESA")prior to October 3,2023,please provide the following:
a.The number of customers with executed MESAs prior to October 2023;
b.A copy of each executed MESAs executed prior to October 3,2023,and an
explanation on how the Line Extension Allowance for these MESAs were
determined;and
c.For each of the customers with an executed MESA prior to October 2023,please
provide an estimate of the Line Extension Allowances under the Company's
proposed Line Extension modifications.
REQUESTNO.3:Please confirm if the Company also plans to provide estimates using
the Company's proposed Line Extension modifications for new customer load requests received
after October 3,2023,and up to the date of the Commission's approval of the proposed
modifications.
DATED at Boise,Idaho,this day of October 2023.
rdie
Deputy AttorneyGeneral
i:umisc:prodreq/PAC-E-23-21 PR#l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 18,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF OCTOBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-
23-21,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL:[e-mail] PORTLAND OR 97232
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE