20240722Bayer to PAC 21-48.pdf

RECEIVED
Monday, July 22, 2024
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 SECOND 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. 21: Please provide Bayer witness Colin T. Fitzhenry with access to the
AURORA production cost model that Rocky Mountain Power used to calculate its net power costs.
Colin Fitzhenry's contact information is below.
Colin T. Fitzhenry
Associate
Brubaker&Associates, Inc.
16690 Swingley Ridge Road, Suite 140
BAYER'S SECOND SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

Chesterfield, MO 63017
cfitzheM(d),consultbai.com
Request No. 22: Please refer to the Direct Testimony of Ramon Mitchell, Page 9, Lines
17-22. Please explain why the procedure described is necessary, and why the Company cannot use
the 2023 weather normalized load in its initial Aurora model run.
Request No. 23: Please provide the following annual data for all PacifiCorp generating
units for the period 2021-2023:
a. Net Generation
b. Operating Capacity (Seasonal, if Applicable)
c. Capacity Factor
d. Seasonal Derates
e. Forced Outage Hours
f. Western Resource Adequacy Plan Accredited Capacity
Request No.24: Please provide the following data on an hourly basis for the period 2021-
2023:
a. Market Purchases (kWh)
b. Market Sales (kWh)
c. Market Purchase Price ($/MWh)
d. Market Sales Price ($/MWh)
Request No. 25: Please provide all load forecasts that support the Company's 2025 NPC
forecast.
Request No. 26: Please provide the following data with respect to the Washington Cap
and Invest Program and the 2025 NPC forecast:
a. Forecasted Net Generation of Chehalis Power Plant with GHG allowance.
b. Forecasted Net Generation of Chehalis Power Plant without GHG allowance.
c. Production cost of Chehalis Power Plant without GHG allowance price.
d. Production cost of Chehalis Power Plant with GHG allowance price.
e. Please explain if the Aurora model includes any additional constraints on the
Chehalis Power Plant as a result of the Washington Cap and Invest Program.
f. Please identify the Aurora model run that does not include the Washington Cap and
Invest Program.
Request No. 27: Please explain how cost from the GHG allowances will be recovered
and utilized.
Request No. 28: Please identify the Idaho allocated percentage of total company
forecasted NPC.
BAYER'S SECOND SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

Request No. 29: Please provide all workpapers supporting the Company's DART
adjustment in Excel format with formulae and links intact.
Request No. 30: Please provide the following information with respect to the DA/RT
adjustment for each month of 2023:
a. Actual net balancing cost
b. Actual balancing purchases (MWh)
c. Actual balancing sales (MWh)
d. Average cost of actual balancing purchases ($/MWh)
e. Average cost of actual balancing sales ($/MWh)
Request No. 31: Please provide a copy of the Company's current Energy Risk
Management Policy.
Request No. 32: Please explain if the Idaho Public Utilities Commission has reviewed
and/or approved the Company's current Energy Risk Management Policy.
Request No. 33: Please explain if the Idaho Public Utilities Commission has previously
provided any oversight into the Company's hedging policies. Oversight might include prudency
reviews of the Company's fuel and purchased power cost or requirements with respect to hedging
practices.
Request No. 34: Please refer to the Direct Testimony of Ramon Mitchell, page 61.
Please provide a summary of all power hedges to date secured for 2025. Consider this an
ongoing request to update this summary as new transactions occur.
Request No. 35: Please explain if the Company's current hedging practices have resulted
in it procuring more power than required to serve the Company's actual load. If the answer is in
the affirmative,please explain how the Company handles sell-backs of over-hedged positions and
how these sell-backs impact NPC.
Request No. 36: Please refer to the Direct Testimony of Ramon Mitchell, page 62. With
respect to the simulated short-term firm transactions, please provide the following data.
a. Workpapers supporting all forecasted short-term firm transactions used in the
Aurora production-cost model. Please provide workpapers in Excel format with all
formulae and links intact.
b. With regard to subpart a,please provide the forecasted prices of all short-term firm
transactions and any workpapers used to derive the forecasted prices.
c. Given that the hedges are secured the quarter prior to their effective period, does
the Company agree that the price differential between the hedged block and the
actual market price will be minimal? Please explain.
d. Please explain how Aurora models the fixed volumes of the hedged blocks versus
the variable volume of other market purchases using the OFPC.
BAYER'S SECOND SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3

Request No. 37: Please provide all workpapers supporting the Company's market sales
capacity limits adjustment in Excel format with formulae and links intact.
Request No.38: Please refer to the Direct Testimony of Ramon Mitchell,page 66. Do the
market sales capacity limits create a situation where the Company's simulated hedges cannot be
sold back into the market? Please explain.
Request No.39: Please provide all workpapers supporting the Figure Regulation Reserves
on page 70 of Mr. Mitchell's direct testimony.
Request No.40: Please provide the net generation and maximum operating capacity of all
PacifiCorp thermal generating units on an hourly basis for the year 2023.
Request No. 41: Please provide the volume (MWh) and cost ($/MWh) of emergency
purchases included in the 2025 NPC forecast.
Request No. 42: Please refer to the Direct Testimony of Ramon Mitchell, pages 58-59,
and provide the curtailments (MWh) for each applicable generation resource included in the 2025
NPC forecast.
Request No. 43: New Wind Generation Plant—Rock Creek I. For the Rock Creek I
wind project:
a. Please separately identify each revenue requirement component(e.g., rate base,
expense, PTCs, REC revenue) associated with Rock Creek I wind project in the
Jurisdictional Allocation Model and/or the Regulatory Adjustment Model. In
addition,please identify the location within PacifiCorp's work papers where the
amounts for each of these revenue requirement items are located.
b. Using each of the identified amounts in a), please provide the revenue
requirement for the Rock Creek I wind project included in the test period in Excel
format with formulas intact.
c. Please provide the exact date the project is expected to commence commercial
operation.
d. If during the pendency of this case, RMP changes the expected commercial
operation date for this project, please provide the revised date for commercial
operation.
Request No. 44: New Wind Generation Plant—Rock River I Repower. For the Rock
River I wind repowering project:
e. Please separately identify each revenue requirement component(e.g., rate base,
expense, PTCs, REC revenue) associated with Rock River I wind repowering
project in the Jurisdictional Allocation Model and/or the Regulatory Adjustment
Model. In addition, please identify the location within PacifiCorp's work papers
where the amounts for each of these revenue requirement items are located.
BAYER'S SECOND SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 4

f. Using each of the identified amounts in a), please provide the revenue
requirement for the Rock River I wind repowering project included in the test
period in Excel format with formulas intact.
g. Please provide the exact date the repowering project is expected to commence
commercial operation.
h. If during the pendency of this case, RMP changes the expected commercial
operation date for this project, please provide the revised date for commercial
operation.
Request No. 45: New Wind Generation Plant—Foote Creek II-IV Repower. For the
Foote Creek II-IV wind repowering project:
a. Please separately identify each revenue requirement component(e.g., rate base,
expense, PTCs, REC revenue) associated with Foote Creek II-IV wind
repowering project in the Jurisdictional Allocation Model and/or the Regulatory
Adjustment Model. In addition, please identify the location within PacifiCorp's
work papers where the amounts for each of these revenue requirement items are
located.
b. Using each of the identified amounts in a), please provide the revenue
requirement for the Foote Creek II-IV wind repowering project included in the
test period in Excel format with formulas intact.
c. Please provide the exact date the repowering project went into commercial
operation.
Request No. 46: New Transmission Plant—Gateway South. For the Gateway South
transmission project:
a. Please separately identify each revenue requirement component(e.g., rate base,
expense, PTCs, REC revenue) associated with the Gateway South transmission
project in the Jurisdictional Allocation Model and/or the Regulatory Adjustment
Model. In addition, please identify the location within PacifiCorp's work papers
where the amounts for each of these revenue requirement items are located.
b. Using each of the identified amounts in a), please provide the revenue
requirement for the Gateway South transmission project included in the test
period in Excel format with formulas intact. If RMP expects to place various
segments of the project into service at different times, please separately identify
the revenue requirement for each time period.
c. Please provide the exact date(s) the transmission project is expected to commence
commercial operation.
d. If during the pendency of this case, RMP changes the expected commercial
operation date(s) for this project,please provide the revised date(s) for
commercial operation.
Request No. 47: New Transmission Plant—Gateway West Segment D.1. For the
Gateway West Segment D.I transmission project:
BAYER'S SECOND SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 5

a. Please separately identify each revenue requirement component(e.g., rate base,
expense, PTCs, REC revenue) associated with the Gateway West Segment D.1
transmission project in the Jurisdictional Allocation Model and/or the Regulatory
Adjustment Model. In addition, please identify the location within PacifiCorp's
work papers where the amounts for each of these revenue requirement items are
located.
b. Using each of the identified amounts in a), please provide the revenue
requirement for the Gateway West Segment D.1 transmission project included in
the test period in Excel format with formulas intact. If RMP expects to place
various segments of the project into service at different times,please separately
identify the revenue requirement for each time period.
c. Please provide the exact date(s) the transmission project is expected to commence
commercial operation.
d. If during the pendency of this case, RMP changes the expected commercial
operation date(s) for this project,please provide the revised date(s) for
commercial operation.
Request No. 48: Gateway Transmission. Please refer to the Direct Testimony of Rick
T. Link,pp. 13-15.
a. Please identify the development status of each of the wind facilities included in
the 1,627 MW of expected resource need beginning 2025 identified in the 2021
IRP. Specifically identify the nameplate capacity of each wind resource and
categorize RMP's best understanding of its likelihood to be in service on
December 31, 2024.
b. Please provide the executed Large Generator Interconnection Agreement(LGIA)
for the project associated with the 500 MW of point-to-point transmission service
referenced by Mr. Link.
c. What is RMP's understanding as to whether the 500 MW point-to-point
transmission service to a third party referenced by Mr. Link will be operational
and providing service to that customer by December 31, 2024? If RMP does not
expect to be providing service to this customer on December 31, 2024, what date
does the Company expect to begin providing service?
d. What is the projected annual revenue requirement for the 500 MW of point-to-
point transmission service to the third party in 2024? Is this revenue included in
Exhibit 48, Adjustment 3.5 (Wheeling Revenues)? If so,please identify which
entry includes this revenue.
e. What is the projected annual revenue requirement for the 500 MW of point-to-
point transmission service to the third party in 2025?
DATED this 22nd day of July, 2024.
RACINE OLSON, PLLP
By: � j �/ . 7%��►�
THOMAS J. BUDGE
BAYER'S SECOND SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 6

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 22nd 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 Idaho Irrigation Pumpers Association
Commission Secretary Eric L. Olsen
P.O. Box 83720 ECHO HAWK& OLSEN, PLLC
Boise, ID 83720-0074 elogechohawk.com
secretary�ic,puc.idaho.gov
Lance Kaufman, Ph.D.
Adam Triplett lanceAae isg insi hg t.com
Deputy Attorney General
Idaho Public Utilities Commission PIIC
adam.triplettkpuc.idaho.gov Ronald L. Williams
Brandon Helgeson
Bayer: HAWLEY TROA-ELL
Brian C. Collins rwilliams(&,,hawleytroxell.com
Greg Meyer bhel e�(&�hawleytroxell.com
Brubaker&Associates
bcollins(kconsultbai.com Bradley Mullins
gmeyer(d),consultbai.com MW Analytics
brmullinskmwanaltyics.com
Kevin Higgins
Neal Townsend PIIC Electronic Service Only:
Energy Strategies LLC Val Steiner: Val.Steinergitafos.com
khiggins(kenergystrat.com Kyle Williams: williamskkbyui.edu
ntownsend(d),energystrat.com
Idaho Conservation League
PacifiCorp Matthew Nykiel
Data Request Response Center Attorney for Idaho Conservation League
datarequest(d),pacificorp.com matthew.n. k elAgmail.com
Mark Alder Brad Heusinkveld
Idaho Regulatory Affairs Manager Idaho Conservation League
mark.alder(d),pacificorp.com Regulatory Counsel
beusinkveld(&,idahoconservation.org
Joe Dallas
Senior Attorney
Rocky Mountain Power
joseph.dallas(kpacificorp.com
THOMAS J. BUDGE
BAYER'S SECOND SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 7