20240812PAC to Bayer 1-20.pdf

RECEIVED
Monday,August 12,2024
_ ROCKY MOUNTAIN IDAHO PUBLIC
POWER UTILITIES COMMISSION
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 12, 2024
Thomas J. Budge
ti(&racineolson.com(C)
Brian C. Collins bcollins(&consultbai.com
Greg Meyer gmeyerkconsultbai.com
Kevin Higgins khiggins(c�r�,energystrat.com(C)
Neal Townsend ntownsendkenergystrat.com(C)
RE: ID PAC-E-24-04
Bayer Set 1 (1-20)
Please find enclosed Rocky Mountain Power's 1st Supplemental Response to Bayer 1st Set Data
Request 2. Provided via BOX is Confidential Attachment Bayer 2 1"Supplemental.
Confidential information is provided subject to protection under IDAPA 31.01.01.067 and
31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No. 67 —Information
Exempt from Public Review, and further subject to the non-disclosure agreement (NDA)
executed in this proceeding.
If you have any questions,please feel free to call me at(801) 220-2313.
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA elo(&echohawk.com(C)
Lance Kaufman/IIPA lancena,ae isg insi hg t�(C)
Matthew Nykiel/ICL matthew.nykielkiamail.com
Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org
Ronald L. Williams/PIIC rwilliamsghawlevtroxell.com
Brandon Helgeson/PIIC bhelfzeson(&hawleytroxell.com
Bradley Mullins/PIIC brmullinsha,mwanalytics.com
Val Steiner/PIIC val.steinerkitafos.com
Kyle Williams/PIIC williamskkbvui.edu
Monica Barrios-Sanchez/IPUC monica.barriossanchez(),puc.idaho.gov
S ecretary(a),puc.idaho.gov

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 2— 1 st Supplemental
Bayer Data Request 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?
1" Supplemental Request received from Bayer Corporation (Bayer) on
August 7, 2024—Please supplement the response by providing the calculated
adjustments for: FERC Account 403 (providing the depreciation expense); FERC
Account 108 (providing the depreciation reserve); and FERC Account 190
(providing the accumulated deferred income tax (ADIT) information). Please
provide the work papers supporting these responsive calculations, in Excel format
with formulas intact.
1st Supplemental Response to Bayer Data Request 2
Further to the Company's response to Bayer Data Request 2 dated July 30, 2024,
and to Bayer Corporation's (Bayer) follow up request received on August 7, 2024,
the Company provides the following additional information:
PacifiCorp objects to this data request on the grounds that it assumes the
Company's initial response to Bayer Data Request 2 was deficient. Subject to and
without waiving the foregoing objection, the Company responds as follows:
The Company does not agree that its response to Bayer Data Request 2 was
deficient. The Company's response to subpart(b) included all applicable
information such as FERC Accounts and allocation factors necessary to prepare a
revenue requirement adjustment. The Company's response in subpart (c) further
stated that this calculation was not a work product previously prepared by the

PAC-E-24-04/Rocky Mountain Power
August 12, 2024
Bayer Data Request 2— 1 st Supplemental
Company and refers to subpart (b) for the information required for Bayer to
prepare the analysis requested. Notwithstanding the foregoing clarification, the
Company provides the following supplemental information responsive to subparts
(b) and(c):
(b) Please refer to Confidential Attachment Bayer 2.1" Supplemental.
(c) Please refer to the Company's response to subpart(b) above.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67—Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA)executed in this proceeding.
Recordholder: Nick Highsmith
Sponsor: Shelley McCoy