20240819IIPA 1-46 to PAC.pdf

RECEIVED
Monday, August 19, 2024
Eric L. Olsen(ISB#4811) IDAHO PUBLIC
ECHO HAWK& OLSEN, PLLC UTILITIES COMMISSION
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: elo(a)echohawk.com
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO. PAC-E-24-04
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS RATES IDAHO IRRIGATION PUMPERS
AND CHARGES IN IDAHO AND ASSOCIATION, INC.'S FIRST SET
APPROVAL OF PROPOSED ELECTRIC OF DATA REQUESTS
SERVICE SCHEDULES AND
REGULATIONS
Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its First Data
Requests to Rocky Mountain Power,pursuant to Commission Rule 225, as follows:
IIPA 1-1: Please refer to Stewart Direct page 28 line 7 and 8.
a. Please provide the referenced article.
b. Has RMP included any costs associated with the James litigation in the test
period? If yes please identify such costs.
IIPA 1-2: How do non-attorney RMP employees record labor costs associated with
litigation? Please provide illustrative accounting ledger entries.
IIPA 1-3: Please identify all currently active wildfire related litigation where RMP is a
defendant.
IIPA 1-4: Please identify all wildfire related litigation in which RMP was listed as a
defendant and which was resolved through settlement. Please provide the settlement agreement.
IIPA 1-5: Please identify all wildfire related litigation in which RMP was listed as a
defendant and the fact finder ruled in favor of plaintiffs on at least one claim. Please provide the
associated ruling.
IIPA 1-6: Please refer to Stewart Direct page 34 line 1-5.
a. Please provide the current status of the Multi-State Process.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 1
CASE NO.PAC-E-24-04

b. Please provide all expenses associated with the Multi-State Process incurred in
the Test year.
IIPA 1-7: Please identify all deferrals RMP has filed in Idaho from 2020 to present. For
each deferral indicate if RMP is requesting recovery or amortization in this case.
IIPA 1-8: Please provide all communications, documents, and files received from or sent to
RMP excess liability insurers from January 1, 2019 to present.
IIPA 1-9: For each excess liability insurance policy renewal from 2019 to present, please
provide all documentation of the policy.
IIPA 1-10: Please provide excess liability insurance cost by year from 2019 to present.
IIPA 1-11: Does the proposed Catastrophic Fire Fund or Insurance Mechanism require
participation by all states in PacifiCorp's jurisdiction? If no, why not?
IIPA 1-12: Please refer to Reply Testimony of Matthew D. McVee filed in Public Utility
Commission of Oregon Docket No. 433, page 2 lines 4-6. Does PacifiCorp intend to withdraw
proposed funding of the Catastrophic Fire Fund in Idaho? If no, why does PacifiCorp propose
differential treatment in Oregon and Idaho?
IIPA 1-13: Please provide transaction summaries for costs recorded in all FERC Accounts for
the Test Year. Please provide data at a detail that correspond to PacifiCorp's Response to OPUC
Staff DR 57 in OPUC Docket No. UE 433. Please include both labor and non-labor costs and
include an indicator of whether the transaction is a labor cost.
IIPA 1-14: Please provide RMP's annual expense by FERC Account,profit center,
department, and allocation code from 2019 to present. Please provide such data separately for
labor and non-labor expense.
IIPA 1-15: Please identify each increase to RMP salary scales and rates effective from 2019
to present. Please identify the labor group the increase is applicable to and the actual labor
charged by each group from 2019 to present.
IIPA 1-16: Please refer to 3.1 3.2 3.3 - Revenue Normalization.xlsx. Please provide work
papers supporting the hard coded numbers on sheet 3.1.3-3.1.4.
IIPA 1-17: Please refer to 3.4 -REC Revenues.xlsx. Please provide workpapers supporting
the hard coded numbers on sheet 3.4.1.
IIPA 1-18: Please refer to 3.5 - Wheeling Revenue.xlsx. Please provide workpapers
supporting the hard coded numbers on sheet 3.5.1.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 2
CASE NO.PAC-E-24-04

IIPA 1-19: Please refer to 3.6 - Fly Ash Revenues.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 3.6.
b. Please provide fly ash revenues and sales quantity by month, plant, and unit from
January 1, 2019 to present.
c. Does PacifiCorp incur labor, transportation, or other expense associated with the
sale of fly ash? If no, why not? If yes,please identify such expenses in the test
year.
IIPA 1-20: Please refer to 4.1 -Miscellaneous General Expense and Revenue.xlsx. Is the
credit facility fee included in RMP's requested cost of capital?
IIPA 1-21: Please refer to 4.2 - Wage and Employee Benefits_CONF.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 4.2.2.
b. Please provide the data on sheet 4.2.2 column B for 12 months ended 2019, 2020,
2021 and 2022.
c. Please provide workpapers supporting the hard coded numbers on sheet 4.2.3-
4.2.4 CONFIDENTIAL.
d. Please provide workpapers supporting the hard coded numbers on sheet 4.2.5.
e. Please provide workpapers supporting the hard coded numbers on sheet 4.2.6.
f. Please provide workpapers supporting the Percentage of eligible wages on sheet
4.2.7.
IIPA 1-22: Please refer to 4.3 -Remove Non-Recurring Entries.xlsx.
a. Please explain the circumstances for the reversal and why the reversal is not
expected to recure.
b. Please provide workpapers supporting the hard coded numbers on sheet 4.3.1.
IIPA 1-23: Please refer to 4.4 - Outside Service Expense.xlsx. Please provide workpapers
supporting the hard coded numbers on sheet 4.4.1.
IIPA 1-24: Please refer to 4.5 - Generation Overhaul Expense.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 4.5.2.
b. Please provide the data on sheet 4.5.2 by unit.
c. Please provide the data on sheet 4.5.2 from 2010 to present.
IIPA 1-25: Please refer to 4.6 - Insurance Expense.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 4.6.1.
b. Does the $35 million in third party insurance claims proceeds offset rate base in
this case? If no, why not?
IIPA 1-26: Please refer to 4.7 -Uncollectible Expense.xlsx. Please provide the data on sheet
4.7.1 for 2017 to 2020.
IIPA 1-27: Please refer to 4.8 - Memberships and Subscriptions.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 4.8.1.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 3
CASE NO.PAC-E-24-04

IIPA 1-28: Please refer to 4.9 -Pension Non-Service Expense.xlsx. Please provide
workpapers supporting the hard coded numbers on sheet 4.9.1.
IIPA 1-29: Please refer to 4.10 - Incremental O&M.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 4.10.1.
b. Please provide workpapers supporting the hard coded numbers on sheet 4.2.5.
IIPA 1-30: Please refer to 7.2 -Property Tax Expense.xlsx. Please provide workpapers
supporting the hard coded numbers on sheet 7.2.1.
IIPA 1-31: Please refer to 7.3 -Production Tax Credit.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 7.3.1.
IIPA 1-32: Please provide availability rate, economic curtailment rate, and congestion
curtailment rate for each wind facility by month from 2019 to present.
IIPA 1-33: Please refer to 8.2 - Trapper Mine Rate Base.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 8.2.1.
b. Please provide workpapers supporting the hard coded numbers on sheet 8.2.2.
IIPA 1-34: Please refer to 8.3 - Jim Bridger Mine Rate Base.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 8.3.1.
b. Please provide workpapers supporting the hard coded numbers on sheet 8.3.2.
IIPA 1-35: Please refer to 8.4 - Customer Advances for Construction.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 8.4.1.
b. Please provide the data on sheet 8.4.1 for 2019 to present.
IIPA 1-36: Please refer to 8.5 -Major Plant Additions.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 8.5.3.
b. Please include workpapers identifying the December 2024 accumulated
depreciation associated with the plant additions.
c. For each plant addition please provide the basis for the forecasted plant.
IIPA 1-37: Please refer to 8.6 -Miscellaneous Rate Base.xlsx.
a. Please provide workpapers supporting the hard coded numbers on sheet 8.6.1
b. Please provide the data on 8.6.1 by month from 2020 to present.
c. Please explain why Jim Bridger Coal stock increases in 2024 despite the reduction
in coal units.
d. Please explain how RMP accounts for overhaul prepayments and expenses.
IIPA 1-38: Please refer to 8.9 - Klamath Regulatory Asset.xlsx.
a. Please provide this workpaper with formulae intact.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 4
CASE NO.PAC-E-24-04

b. Please explain why rate base is adjusted to 2025 13 month average while the
depreciation deferral rate base on 8.8.4 is adjusted to December 2024.
IIPA 1-39: Please refer to 8.12 -Pension Asset Adjustment.xlsx. Please provide workpapers
supporting the hard coded numbers on sheet 8.12.1.
IIPA 1-40: Please refer to the response to Bayer Data Request 3.
a. Please provide the definition of known and measurable as used by the Company
in this case.
b. Is it the Company's position that depreciation on existing plant is not known and
measurable? If yes, please provide the basis for this position.
c. Please identify the date where the company first began forecasting plant based on
capital projects over $5 million and explain how the company forecasted plant
prior to this date.
IIPA 1-41: Please provide the number of employees separated from the company by month
from January 2019 to present.
IIPA 1-42: Please refer to the response to Bayer Data Request 17.
a. Please explain why the company's employee count declined from 2019 to 2022.
b. Please explain why the Company's employee count increased from 2022 to 2024.
c. Please provide these data by state and department.
IIPA 1-43: Please provide the amount of over-time charged by hourly employees by month
and department in 2023.
IIPA 1-44: Please describe all journal entries made by the Company when it receives a
customer deposit. Please include illustrative transactions for a recent Idaho customer deposit.
IIPA 1-45: Please provide the company's current 20 year forecast for annual energy and
system peak. Please provide such data by state.
IIPA 1-46: Please provide the company's annual budget in effect on the first day of the
budget year from 2019 to present.
DATED this 19th day of August, 2024.
ECHO HAWK& OLSEN
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 5
CASE NO.PAC-E-24-04

CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 19th day of August, 2024, I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s First Set of Data Requests to
each of the following, via the method indicated below:
Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Hand Delivered
P.O. Box 83720 ❑ Overnight Mail
Boise, ID 83720-0074 ❑ Telecopy(Fax)
monica.barriossanchezgpuc.idaho.gov ® Electronic Mail (Email)
Adam Triplett ❑ U.S. Mail
Deputy Attorney General ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
P.O. Box 83720 ❑ Telecopy(Fax)
Boise, ID 83720-0074 ® Electronic Mail (Email)
adam.triplettg]2uc.idaho.gov
Mark Alder ❑ U.S. Mail
Michael Snow ❑ Hand Delivered
Idaho Regulatory Affairs Manager ❑ Overnight Mail
PacifiCorp/Rocky Mountain Power ❑ Telecopy(Fax)
1407 W. North Temple, Suite 330 ® Electronic Mail (Email)
Salt Lake City, UT 84116
mark.alder(ibp acificorp.com
michael.snowgpacificorp.com
Joseph Dallas (ISB #10330) ❑ U.S. Mail
Carla Scarsella ❑ Hand Delivered
PacificCorp/Rocky Mountain Power ❑ Overnight Mail
825 NE Multnomah, Suite 2000 ❑ Telecopy(Fax)
Portland, OR 97232 ® Electronic Mail (Email)
joseph.dallas(i pacificorp.com
carla.scarsella(cr�pacificorp.com
Data Request Response Center ❑ U.S. Mail
PacifiCorp ❑ Hand Delivered
825 NE Multnomah, Suite 2000 ❑ Overnight Mail
Portland, OR 97232 ❑ Telecopy(Fax)
datarequest(&,pacificorp.com ❑ Electronic Mail (Email)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 6
CASE NO.PAC-E-24-04

Lance Kaufman, Ph.D. ❑ U.S. Mail
Idaho Irrigation Pumpers Association, Inc. ❑ Hand Delivered
2623 NW Bluebell Place ❑ Overnight Mail
Corvallis, OR 97330 ❑ Telecopy(Fax)
lance@ae isg insi ht.com ® Electronic Mail (Email)
Mike Veile ❑ U.S. Mail
Bayer Corporation ❑ Hand Delivered
P4 Production, L.L.C. ❑ Overnight Mail
P.O. Box 816 ❑ Telecopy(Fax)
Soda Springs, ID 83276 ® Electronic Mail (Email)
[e-mail]
Thomas J. Budge ❑ U.S. Mail
Bayer Corporation ❑ Hand Delivered
Racine Olson, PLLP ❑ Overnight Mail
P.O. Box 1391 ❑ Telecopy(Fax)
Pocatello, ID 83204 ® Electronic Mail (Email)
tjkracineolson.com
Brian C. Collins ❑ U.S. Mail
Greg Meyer ❑ Hand Delivered
Bayer Corporation ❑ Overnight Mail
Brubaker&Associates ❑ Telecopy(Fax)
16690 Swingley Ridge Rd., #140 ® Electronic Mail (Email)
Chesterfield, MO 63017
[e-mail]
gmeyer(ab,consultbai.com
Kevin Higgins ❑ U.S. Mail
Neal Townsend ❑ Hand Delivered
Bayer Corporation ❑ Overnight Mail
Energy Strategies LLC ❑ Telecopy(Fax)
111 East Broadway Suite 1200 ® Electronic Mail (Email)
Salt Lake City, UT 84111
khiggins(iy�,energystrat.com
[e-mail]
Matthew Nykiel ❑ U.S. Mail
Attorney for Idaho Conservation League ❑ Hand Delivered
710 N. 6th St. ❑ Overnight Mail
Boise, ID 83702 ❑ Telecopy(Fax)
[e-mail] [e-mail] ❑ Electronic Mail (Email)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 7
CASE NO.PAC-E-24-04

Brad Heusinkveld ❑ U.S. Mail
Idaho Conservation League ❑ Hand Delivered
Regulatory Counsel ❑ Overnight Mail
710 N. 6th St. ❑ Telecopy(Fax)
Boise, ID 83702 ® Electronic Mail (Email)
beusinkveld&idahoconservation.org
Ronald L. Williams ❑ U.S. Mail
Brandon Helgeson ❑ Hand Delivered
PacifiCorp Idaho Industrial Customers ❑ Overnight Mail
Hawley Troxell Ennis & Hawley LLP ❑ Telecopy(Fax)
P.O. Box 1617 ® Electronic Mail (Email)
Boise, ID 83701
rwilliams(i�hawleytroxell.com
bhel-eg son(c-r�,hawleytroxell.com
Bradley Mullins ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
MW Analytics ❑ Overnight Mail
Teitotie 2, Suite 208 ❑ Telecopy(Fax)
Oulunsalo Finland, FI-90460 ® Electronic Mail (Email)
brmullins(&mwanalytics.com
Val Steiner ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
Itafos Conda, LLC ❑ Overnight Mail
val.steiner(a),itafos.com ❑ Telecopy(Fax)
® Electronic Mail (Email)
Kyle Williiams ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
BYU Idaho ❑ Overnight Mail
[e-mail] ❑ Telecopy(Fax)
® Electronic Mail (Email)
Eric L. Olsen, Echo Hawk& Olsen PLLC
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FIRST SET OF DATA REQUESTS—Page 8
CASE NO.PAC-E-24-04