20240802PIIC to PAC 1-28.pdf

RECEIVED
Friday, August 2, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
HAWLEY TROXELL ENNIS &HAWLEY LLP
877 W. Main Street, Suite 200
P.O. Box 1617
Boise, ID 83701-1617
Telephone: [phone]
Facsimile: 208.954.5253
Email: [e-mail]
[e-mail]
Attorneys For PIIC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO CASE NO. PAC-E-24-04
INCREASE ITS RATES AND CHARGES IN
IDAHO AND APPROVAL OF PROPOSED FIRST PRODUCTION REQUEST OF
ELECTRIC SERVICE SCHEDULES AND PACIFICORP IDAHO INDUSTRIAL
REGULATIONS CUSTOMERS TO ROCKY
MOUNTAIN POWER
PacifiCorp Idaho Industrial Customers ("PIIC"), by and through its attorneys of record
and pursuant to the Rules of Procedure of the Idaho Public Utilities Commission
("Commission"), hereby requests that Rocky Mountain Power("RMP")provide the following
documents and information no later than Friday,August 23, 2024.
Please provide answers to each question and supporting work papers that provide detail or
are the source of information used in calculations. In addition to the written copies provided as
response to the questions,please provide all Excel and electronic files on CD or via e-mail or other
electronic communication with formulas activated. Please provide a copy of all responses
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 1
59501.0004.17468673.1

electronically to PIIC consultant,Brad Mullins, via his email as shown on the attached service list.
This Production Request is continuing, and RMP 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.
Request No 1: Reference the workpapers of Witness Shelley McCoy: Please provide all
of the B-Tab workpapers supporting Ms. McCoy's revenue requirement calculations in the same
manner provided in response to PIIC Production Request 5 in Case No. PAC-E-21-07.
Request No 2: Reference the workpapers of Witness Shelley McCoy: Please provide all
of the B-Tab workpapers for calendar years 2020, 2021 and 2022 supporting PacifiCorp's results
of operations in manner provided in response to PIIC Production Request 5 in Case No. PAC-E-
21-07.
Request No 3: Please identify the total non-NPC revenue requirement of Chehalis
included in the test period this matter, including separate detail for the following:
a. Gross Plant;
b. Accumulated Depreciation;
c. Accumulated Deferred Income Taxes;
d. Fuel Stock;
e. Other rate base items;
f. Operating expenses;
g. Property Taxes;
h. Washington State Taxes;
i. Insurance; and,
j. Any Other Expenses.
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 2
59501.0004.17468673.1

Request No 4: Does PacifiCorp own any transmission equipment interconnected to the
Chehalis Power plant? If yes, please describe all such assets and identify the revenue
requirement associated with the assets.
Request No 5: Please provide a description Washington Public Utility Tax and identify
the amount of the tax(on both a System and Idaho-allocated basis) included in revenue
requirement.
Request No 6: Please explain how the Washington Public Utility Tax is assigned under
the Washington Interjurisdictional Allocation Method("WIJAM").
Request No 7: Does PacifiCorp pay any use taxes to the State of Washington for natural
gas purchased to fuel the Chehalis Power plant? If yes,please:
a. Identify and describe all such taxes;
b. Identify the FERC account where the taxes are recorded;
c. State the amount of such taxes included in revenue requirement(on both a System
and Idaho-allocated basis); and,
d. State the amount of such taxes paid or incurred in calendar year 2023 (on both a
System and Idaho-allocated basis).
Request No 8: Please provide PacifiCorp's best estimate of the fair market value of the
Chehalis power plant as of December 31, 2023.
Request No 9: Please confirm or deny that the Chehalis power plant has a negative fair
market value as of December 31, 2023. Please explain the answer and provide analytical
workpapers supporting any assertions made as to the value of the Chehalis power plant.
Request No 10: Please provide PIIC Witness Bradley G. Mullins with access to the Aurora
model, Aurora model project files, and all workpapers and scripts necessary to duplicate the NPC
modelling PacifiCorp is proposing to include in revenue requirement in this docket.
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 3
59501.0004.17468673.1

Request No 11: Please provide a fully functional, linked version of the NPC template,
including links to the DART adjustment workpapers and any other native links.
Request No 12: Reference workpaper"Aurora GN Market Prices CONF," Tab "Adders
Source,"
a. Please provide the source data used to calculate the values in the referenced
workpaper.
b. Please provide the equivalent DA/RT data over the period January 1, 2015
through December 31, 2019.
c. Please also provide the source data used to calculate the DART values over the
period January 1, 2015 through December 31, 2019.
Request No 13: PacifiCorp has announced its intention to cease all MSP negotiations.
Please explain how PacifiCorp proposes to calculate actual net power costs included in the
Energy Cost Adjustment Mechanism following the expiration of the 2020 Protocol.
Request No 14: Reference McCoy workpaper"4.9 -Pension Non-Service Expense," Tab
"4.9.1:
a. Please explain what pension non-service expenses and post-retirement non-
service expenses are and how they are calculated.
b. Why did PacifiCorp set the GL 554012 Pension Non-Service Expense amount to
zero in the forecast period?
c. Please provide the GL 554012 Pension Non-Service expense/benefit by month
over the period January 1, 2020 through December 31, 2023.
d. Reference GL 554022 Post-Retirement Non-Service Expense: Please provide the
GL 554012 Pension Non-Service expense/benefit by month over the period
January 1, 2020 through December 31, 2023
e. Please provide PacifiCorp's most recent actuarial reports calculating pension non-
service expenses and other post-retirement benefit non-service expenses.
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 4
59501.0004.17468673.1

Request No 15: Please identify all costs included in revenue requirement associated with
allocations from Berkshire Hathaway Energy Holdings Company or any other affiliate. Please
provide this detail by FERC account.
Request No 16: Please provide the intercompany allocation manual that establishes how
costs are allocated to and from PacifiCorp affiliates.
Request No 17: Please provide transaction level details supporting all amounts allocated to
PacifiCorp from Berkshire Hathaway Energy Holdings Company or any other affiliate.
Request No 18: Please identify all memberships and dues included in revenue requirement
through an intercompany allocation to PacifiCorp from an affiliate or parent, with detail of
amount and the organization to which the amounts were paid.
Request No 19: Reference McCoy workpaper"4.1 -Miscellaneous General Expense and
Revenue,"Tab "4.1.U'
a. Please provide an explanation for the item titled"Credit facility fees."
b. Please provide workpapers supporting the adjustment of$2,431,425 with respect
to Credit facility fees, including details of each debt instrument, the balance as of
December 31, 2023, the total amount drawable, and the expiration.
c. Are the Credit facility fees annual charges or a one-time charge in connection
with a debt instrument. Please explain.
d. Please explain why Credit facility fees are not already included in PacifiCorp's
results of operations.
e. Please provide an explanation of how Credit facility fees are considered under
FERC accounting rules.
f. Please provide any correspondence between PacifiCorp and FERC regarding the
FERC accounting for Credit facility fees.
g. Please identify all amounts in excess of$10 million drawn from a credit facility
over the period January 1, 2020 through July 31, 2024 and describe the purpose
for the withdrawal.
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 5
59501.0004.17468673.1

Request No 20: Please provide PacifiCorp's calculation of the effective rates for
Allowance for Funds Used for Construction that were used for calendar year 2023, with details
of all debt items and equity costs included in that calculation.
Request No 21: Reference McCoy workpaper"4.4 - Outside Service Expense," Tab
"4.4.1":
a. Please provide the equivalent data for each calendar year 2018, 2019, and 2020.
b. Please explain why the outside services expenses increase so significantly in 2022
and 2023.
c. Was the increase in 2022 and 2023 related to wildfire litigation? If yes,please
quantify the amount of the increase related to wildfire litigation.
Request No 22: Please provide transaction level detail of all legal expenses included in the
test period revenue requirement, with a description of the legal matter on which the legal services
were performed.
Request No 23: Please provide transaction level detail of all expert witness consulting
services accrued in the test period revenue requirement, with a description of the matter on which
the services were performed.
Request No 24: Reference McCoy workpaper"4.5 - Generation Overhaul Expense":
Please provide detail of generation overhaul expenses detailed by plant and outage over the
period January 1, 2020 through December 31, 2023, including the following information:
a. A description of the major maintenance performed.
b. The duration of the maintenance activities.
c. The total cost of the maintenance activities.
d. Amounts covered under a long-term service agreement.
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 6
59501.0004.17468673.1

Request No 25: Please identify each long term service agreement that PacifiCorp has for
its power plants, and describe the terms of the agreement, including the amounts paid, the timing
of payment and how the rates change over time.
Request No 26: Reference McCoy workpaper"3.6 -Fly Ash Revenues.":
a. Please explain why fly ash revenues are expected to decline so significantly in
2024, and;
b. Please provide all executed fly ash sales agreements in effect in calendar years
2023, 2024, and 2025.
Request No 27: Please provide PacifiCorp's financial statement tax provision calculation
by book-tax difference item as of December 31, 2023.
Request No 28: Please provide the Jim Bridger Fuel stock balance by month over the
period January 1, 2023 through July 31, 2024.
Dated this 2nd day of August, 2024.
HAWLEY TROXELL ENNIS & HAWLEY LLP
By
V411,-
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
Attorneys For PIIC
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 7
59501.0004.17468673.1

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I caused to be served a true copy of the foregoing FIRST
PRODUCTION REQUEST OF PACIFICORP IDAHO INDUSTRIAL CUSTOMERS TO
ROCKY MOUNTAIN POWER by the method indicated below, and addressed to each of the
following:
Commission Secretary ❑ U.S. Mail, Postage Prepaid
Idaho Public Utilities Commission ❑ Hand Delivered
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A ❑ Overnight Mail
Boise, ID 83714 Q E-mail
secretary�ic,puc.idaho.gov ❑ Facsimile
❑ iCourt
Data Request Response Center ❑ U.S. Mail, Postage Prepaid
825 NE Multnomah St. Suite 2000 ❑ Hand Delivered
Portland, OR 97232 ❑ Overnight Mail
datarequest(4 pacificorp.com Q E-mail:
❑ Facsimile
❑ iCourt
Joe Dallas ❑ U.S. Mail, Postage Prepaid
Rocky Mountain Power ❑ Hand Delivered
825 NE Multnomah, Suite 2000 ❑ Overnight Mail
Portland, OR 97232 Q E-mail:
Joseph.dallasgpacificorp.com ❑ Facsimile
❑ iCourt
Mark Adler ❑ U.S. Mail, Postage Prepaid
Rocky Mountain Power ❑ Hand Delivered
1407 West North Temple, Suite 330 ❑ Overnight Mail
Salt Lake City, UT 84116 Q E-mail:
[e-mail] ❑ Facsimile
❑ iCourt
Brad Mullins ❑ U.S. Mail, Postage Prepaid
Principal Consultant ❑ Hand Delivered
MW Analytics ❑ Overnight Mail
Teitotie 2, Suite 208 Q E-mail:
Oulunsalo Finland, FI-90460 ❑ Facsimile
brmullins&mwanaltyics.com ❑ iCourt
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 8
59501.0004.17468673.1

Eric L. Olsen ❑ U.S. Mail, Postage Prepaid
Echo Hawk& Olsen PLLC ❑ Hand Delivered
505 Pershing Ave., Suite 100 ❑ Overnight Mail
PO Box 6119 Q E-mail:
Pocatello, ID 83205 ❑ Facsimile
elo(d,echohawk.com ❑ iCourt
Aegis Strategies ❑ U.S. Mail, Postage Prepaid
Lance Kaufman: ❑ Hand Delivered
lancegae_isg insi_hg t.com ❑ Overnight Mail
Q E-mail:
❑ Facsimile
❑ iCourt
Thomas J. Budge ❑ U.S. Mail, Postage Prepaid
Racine, Olson, PLLP ❑ Hand Delivered
201 E. Center ❑ Overnight Mail
PO Box 1391 Q E-mail:
Pocatello, ID 83204-1391 ❑ Facsimile
ti(&,racineolson.com ❑ iCourt
Brian C. Collins ❑ U.S. Mail, Postage Prepaid
Greg Meyer ❑ Hand Delivered
Brubaker&Associates ❑ Overnight Mail
16690 Swingley Ridge Rd., #140 Q E-mail:
Chesterfield, MO 63017 ❑ Facsimile
[e-mail] ❑ iCourt
gme ergconsultbai.com
Kevin Higgins ❑ U.S. Mail, Postage Prepaid
Neal Townsend ❑ Hand Delivered
Energy Strategies LLC ❑ Overnight Mail
khiggins(&,energystrat.com Q E-mail:
ntownsend(&_�energ_ystrat.com ❑ Facsimile
❑ iCourt
Matthew Nykiel ❑ U.S. Mail, Postage Prepaid
Brad Heusinkveld ❑ Hand Delivered
Idaho Conservation League ❑ Overnight Mail
710 N. 6t' St. Q E-mail:
Boise, ID 83702 ❑ Facsimile
matthew.n, k elkamail.com ❑ iCourt
bheusinkveldgidahoconservation.org
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 9
59501.0004.17468673.1

Val Steiner ❑ U.S. Mail, Postage Prepaid
Itafos Conda, LLC ❑ Hand Delivered
val.steinergitafos.com ❑ Overnight Mail
Q E-mail:
❑ Facsimile
❑ iCourt
Kyle Williams ❑ U.S. Mail, Postage Prepaid
BYU Idaho ❑ Hand Delivered
[e-mail] ❑ Overnight Mail
Q E-mail:
❑ Facsimile
❑ iCourt
Dated: August 2, 2024.
AO.#q � VwA�
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
PIIC First Production Request to RMP, Case No. PAC-E-24-04 - 10
59501.0004.17468673.1