20240709Bayer 1-20 to PAC.pdf

RECEIVED
2024 July 9, 3:04PM
IDAHO PUBLIC
Thomas J. Budge, ISB No. 7465 UTILITIES COMMISSION
RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center St.
Pocatello, Idaho 83204-1391
[phone]
[e-mail]
Attorneys for P4 Production, L.L.C., an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND BAYER'S FIRST SET OF
APPROVAL OF PROPOSED ELECTRIC DISCOVERY REQUESTS TO
SERVICE SCHEDULES AND ROCKY MOUNTAIN POWER
REGULATIONS
P4 Production, L.L.C., an affiliate of Bayer Corporation ("Bayer"), by and through
counsel, submits this first set of discovery requests to Rocky Mountain Power("RMP")pursuant
to rules 221-225 of the Commission's Rules of Procedure, IDAPA 31.01.01.
These discovery requests are to be considered continuing; therefore, RMP should
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that are responsive to these requests.
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 identify the name,job title, location, and telephone
number of the record holder. Please provide all Excel and other electronic files on a thumb drive
or via email or other electric communication with formulas intact and activated.
DISCOVERY REQUESTS
Request No. 1: Test period. Please prepare and provide a complete set of Idaho revenue
requirement models, adjustments, and work papers, comparable in all respects to RMP's as-filed
models/work papers used to produce RMP witness Shelley E. McCoy's Exhibit No. 48,but that
reflects a 13-month average rate base amount for 2024. In preparing these revenue requirement
models, please do not reflect any annualizations for any adjustments with changes occurring
during the 2024 calendar year, including annualizations of post-2023 capital additions. Also,
please provide the net power cost revenue requirement for 2024 without any annualizations.
Please provide the models/work papers in Excel format with formulas intact.
BAYER'S FIRST SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

Request No. 2: 2020 New Wind/Transmission Projects. In Case No. PAC-E-17-07,
the Idaho Commission conditionally approved a Stipulation and CPCN for RMP's New 2020
Wind and Transmission Projects (alternatively, "2020 Combined Projects")upon setting an
overall capital cost cap at the Company's project estimate. In its 2021 rate case (Case No. PAC-
E-21-07), RMP witness Joelle Steward noted in her direct testimony that the capital costs for the
2020 Combined Projects exceeded the cost cap and requested recovery of the costs in excess of
the cap.
a. Has RMP included an adjustment to reflect the cost cap ordered by the Idaho
Commission in this case? If not, why not? If so,please identify the workpaper(s)
where all the adjustment(s) may be found.
b. If RMP did not include an adjustment to reflect the cost cap,please provide all the
adjustments by FERC account and interjurisdictional allocation factor necessary
to reflect compliance with the Commission's order. Please provide all
workpapers in Excel format with formulas intact.
C. Assuming it was not included in RMP's filing, what would be the revenue
requirement impact if RMP had applied the 2020 Combined Projects cost cap?
Request No. 3: Accumulated Depreciation/Amortization Reserve. Is RMP adjusting
the accumulated depreciation/amortization reserve for existing plant in the base period to reflect
year-end 2024 balances? If not,please explain why RMP didn't reflect year-end 2024 balances
and identify the time period RMP is proposing for this reserve balance in its filing. If so, please
provide a workpaper in Excel format that rolls forward the year-end 2023 reserve balances to
year-end 2024 balances and the location within RMP's adjustments where each of the roll
forward adjustments are located.
Request No. 4: Capital Additions. Please provide RMP's projected calendar year 2024
plant additions. For the distribution plant, please limit the response to the capital additions for
the state of Idaho. Please separate these projected calendar year 2024 plant additions into the
following functional categories: Steam Generation, Hydro Generation, Other Production
Generation, Transmission, Distribution, General, and Intangible Plant and provide the
appropriate interjurisdictional allocation factor for each. Please provide this schedule in Excel
format as well as any associated workpapers with formulas intact. If there is any differences
from the forecasted capital additions included in the Utah general rate case referenced in the
subsequent data request, please reconcile and explain any differences
Request No. 5: Capital Additions. Please provide RMP's forecasted capital additions
workpapers in its current Utah rate case (Utah Docket No. 24-035-04). Specifically,please
provide the Utah Adjustment 8.5 Proforma Plant Additions workpapers and the Confidential
Utah Adjustment 8.15 New Wind Generation Capital Additions workpapers in Excel format with
formulas intact. Please confirm that these workpapers presents the forecasted calendar year 2024
(& calendar year 2025)projected capital additions by month separated by the following
functional categories - Steam Generation, Hydro Generation, Other Production Generation,
Transmission, Distribution, General, and Intangible Plant- and provides the appropriate
interjurisdictional allocation factor for each.
BAYER'S FIRST SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

Request No. 6: Accumulated Deferred Income Taxes. On p. 5 of 303 (p. 1.3) of RMP
witness Shelley E. McCoy's Exhibit 48, Ms. McCoy provides Idaho's share ($143,870,486) of
the unadjusted 2023 accumulated deferred income tax balance in Col. (1). Please provide a 2024
forecast of accumulated deferred income taxes (both Total Company and Idaho allocated) that is
not otherwise included in the various RMP adjustments summarized on p. 6 of 303 (p. 1.4) of
Exhibit 48. Please provide this forecasted amount broken down by function(e.g. generation,
transmission, distribution, etc.). Please provide any workpapers supporting this response in
Excel format with formulas intact.
Request No. 7: Depreciation Expense/Accumulated Depreciation Reserve. In its
Incremental Depreciation Expense Adjustment 6.1, RMP includes an adjustment(Total
Company= $5,080,376; Idaho Allocated= $274,487)to annualize the depreciation expense for
the portion of the major capital additions that were placed in service during the 2023 historic test
year. Did RMP include an adjustment to the Accumulated Depreciation Reserve to reflect this
incremental depreciation expense? If not, why not? If so, please identify the location within
RMP's workpapers where this adjustment to the accumulated depreciation reserve is located.
Request No. 8: Adjustment 8.5—Major Plant Additions. In the 8.5 exhibit workpaper
file, the values on p. 8.5.2 & 8.5.3 appear to show the calendar year 2023 & 2024 major plant
gross plant-in-service capital additions. Please confirm that RMP is reflecting a 2024 end-of-
period plant in service balance for each project (in addition to the 2023 end of period balances).
For major plant addition project, please provide a workpaper deriving the 13-month average
balance for 2024 for gross plant, accumulated depreciation, and accumulated deferred income
taxes. Please reconcile any differences with the rate base amounts included in RMP's filing.
Request No. 9: Adjustment 8.5—Major Plant Additions. For any new major capital
addition in which some portion of the project has an in-service date during calendar year 2023,
please provide a monthly breakdown of the capital additions for both calendar years 2023 &
2024. As part of this response, please include the pro forma monthly depreciation expense,
accumulated depreciation, and accumulated deferred income taxes by month for each project. If
there is any difference from the amounts included in RMP's filing, please reconcile the
difference with the requested amount in the filing.
Request No. 10: Annual Incentive Plan.-Please provide all documentation that explains
the different components of RMP's Annual Incentive Plan(AIP). The response should describe
the different metrics used to award AIP payments.
Request No. 11: Annual Incentive Plan. Please provide a copy of the Annual Incentive
Plan documents for each year, 2021 through 2023, and if available, 2024.
Request No. 12: Annual Incentive Plan. Please provide the PacifiCorp Scorecards
applicable to the Annual Incentive Plan for each year 2021 through 2023, and if available, 2024.
Request No. 13: Annual Incentive Plan. Please provide the RMP Bonus and Awards
payment balances for the last five years (2019-2023).
BAYER'S FIRST SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3

Request No. 14: Annual Incentive Plan. For 2023 and 2024, please provide a detailed
description of all actions performed that would qualify for a bonus or award payment.
Request No. 15: Payroll costs. Is RMP seeking to include payroll increases in cost of
service beyond the 2024 test year in this case? If so,please provide a detailed explanation of all
increases.
Request No. 16: Payroll costs. Please refer to Exhibit No. 48,page 4.2.2. Please
separately state the percentage of total labor dollars assigned to (a)Non-Utility Labor and(b)
Capitalized Labor for the last five years (2019-2023) and pro-forma 2024.
Request No. 17: Employee count. Please provide the actual full time equivalent(FTE)
employee count by month,beginning in January 2019 and continuing through the most recent
date available. In this response,please indicate the day of the month to which the FTE counts
correspond (e.g., 1 st of the month, last day of the month, etc.). Please supplement this response
as new information becomes available during the pendency of this case.
Request No. 18: Employee count. Please confirm that the Company's test period labor
expenses are effectively based on the average full time equivalent employee count for the base
period ended December 31, 2023. If not, please indicate the time period corresponding to the
employee count upon which test period labor expenses are based.
Request No. 19: Employee count. Please indicate whether the Company has made any
adjustments to the base period to reflect known and measurable changes that include changes to
the number of employees. If so,please explain and cite to the adjustment(s) in the Company's
filing.
Request No. 20: Customer Service Deposits. Please refer to Ms. McCoy's Exhibit No.
48 (Results of Operations),page 2.28.
a. Please explain why the entries corresponding to Customer Service Deposits (lines
2147-2149) are zero.
b. Please compare these entries to the comparable entries in Exhibit RMP_(SEM-
3), page 2.29, lines 2284-2286, in Utah Public Service Commission Docket No.
24-035-04. In the Utah docket, $13 million of Customer Service Deposits are
adjusted into the 2025 test period as a credit against rate base. Please explain in
detail why there is no analogous adjustment for Idaho and provide any
documentation and work papers supporting such explanation.
C. Please provide the actual (if available) or projected monthly balance of Idaho
Customer Service Deposits for each month from December 2022 to December
2024. Please indicate whether each amount provided represents an actual or
projected balance.
d. Please provide the actual (if available) or projected monthly Idaho interest
expense on Customer Service Deposits for each month from January 2023 to
December 2024. Please indicate whether each amount provided represents an
actual or projected amount.
BAYER'S FIRST SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 4

DATED this 91h day of July, 2024.
RACINE OLSON, PLLP
By: 77-
THOMAS J. BUDGE (�
BAYER'S FIRST SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 5

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 91h day of July, 2024, I caused a true and correct copy
of the above and foregoing document to be served via email to the following persons:
Idaho Public Utilities Commission PIIC
Commission Secretary Ronald L. Williams
P.O. Box 83720 Brandon Helgeson
Boise, ID 83720-0074 HAWLEY TROA-ELL
secretary�ic,puc.idaho.gov rwilliamsAhawleytroxell.com
bhel esonghawleytroxell.com
PacifiCorp
Data Request Response Center Bradley Mullins
datarequest(d),pacificorp.com MW Analytics
brmullins&mwanaltyics.com
Mark Alder
Idaho Regulatory Affairs Manager PIIC Electronic Service Only:
mark.alder(d),pacificorp.com Val Steiner: Val.SteinerAitafos.com
Kyle Williams: williamsk(kbyui.edu
Joe Dallas
Senior Attorney
Rocky Mountain Power
joseph.dallas(kpacificorp.com
Idaho Irrigation Pumpers Association
Eric L. Olsen
ECHO HAWK& OLSEN, PLLC
elo(&,echohawk.com
Lance Kaufinan, Ph.D.
lance&ae_isg insi_hg t.com
40
� `�/
THOMAS J. BUDGE
BAYER'S FIRST SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 6