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Home My WebLink About20240820Bayer to PAC 75-78.pdf RECEIVED Tuesday, August 20, 2024 IDAHO PUBLIC UTILITIES COMMISSION Thomas J. Budge, ISB No. 7465 RACINE OLSON, PLLP P.O. Box 1391; 201 E. Center St. Pocatello, Idaho 83204-1391 (208) 232-6101 tj@racineolson.com 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 FIFTH 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. 75: Resources Interconnecting to Gateway South and Gateway West. Please refer to the Direct Testimony of Richard A. Vail,p. 23 (lines 13-14), in which Mr. Vail states as follows: "[T]hese Transmission Projects allow the Company to interconnect up to approximately 2,030 megawatts ("MW") of new resources." a. What portion of the 2,030 MW is expected to interconnect to Gateway South and what portion is expected to interconnect to Gateway West? BAYER'S FIFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I b. For the portion of the 2,030 MW expected to interconnect to Gateway South, please identify each resource, its location, nameplate capacity, whether or not it is owned by PacifiCorp or under contract to sell its generation output to PacifiCorp, and whether it is included in the 1,640 MW of resources selected to the final shortlist of RMP's 2020AS RFP as referenced in the direct testimony of RMP witness Rick T. Link, p. 37 (lines 5-7). c. For each project identified in subpart(b), please provide a copy of each Large Generator Interconnection Agreement(LGIA), Small Generator Interconnection Agreement(SGIA), or transmission service agreement, as applicable. d. What is the expected in-service date of each project identified is subpart 75(b)? If the Company is aware of any delays in expected in-service dates please identify them. Request No. 76: Resources Interconnecting to Gateway South and Gateway West. Please refer to the Direct Testimony of Rick Vail,p. 24 (lines 21-23), in which Mr. Vail states as follows: "...PacifiCorp has executed 13 contracts with third-party customers that require constructing one or both of the Transmission Projects." a. Which of the resources listed in response to Bayer Data Request 75(b) above correspond to any of the 13 contracts referenced by Mr. Vail? b. Please indicate which, if any, of the 13 contracts referenced by Mr. Vail are associated with resources that are included in the 1,640 MW of resources selected to the final shortlist of RMP's 2020AS RFP as referenced in Mr. Link's direct testimony, p. 37. c. If any of the 13 contracts referenced by Mr. Vail are not listed in response to Bayer Data Request 75(b) above, please: (i) identify each resource, its location, and nameplate capacity; (ii) provide a copy of each Large Generator Interconnection Agreement(LGIA), Small Generator Interconnection Agreement(SGIA), or transmission service agreement, as applicable; and (iii)indicate its expected in-service date if known. Request No. 77: Gateway South Net Benefits. Please refer to Exhibit No. 31 attached to the direct testimony of Rick T. Link. Regarding the entry labeled "Avoided Transmission— Base 230 kV"under each scenario of this exhibit: a. Please confirm that this entry refers to the costs avoided from not constructing transmission upgrades to accommodate PacifiCorp's obligation to provide 500 MW BAYER'S FIFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2 of firm point-to-point transmission service to a third-party customer as discussed on pages 29-30 of Mr. Link's direct testimony. b. What is the estimated construction cost of the transmission facilities associated with the $(843 million) PVRR in each price policy scenario in Exhibit No. 31? Is it the $1.4 billion referenced by Mr. Link on page 30 of his direct testimony or some other amount? C. In calculating the $(843 million) PVRR in Exhibit No. 31, did the Company assume that 80% of the revenue requirement of the avoided 230 kV transmission line would have been borne by PacifiCorp retail customers if that line had been built to meet PacifiCorp's obligation to provide 500 MW of firm point-to-point transmission service to a third-party customer? If not, please indicate the percentage the Company used and explain the basis for it. d. Is Mr. Link familiar with FERC's "Higher of Pricing Policy as discussed in FERC Order 890,paragraphs 870-885? e. In preparing the analysis presented in Exhibit No. 31, why didn't the Company assume that retail customers would not have been expected to pay for the cost of a 230 kV line required to serve a third-party customer seeking 500 kW of firm transmission service, since that customer could have been required to pay the monthly incremental cost transmission rate using the revenue requirement associated with the required upgrades as discussed in FERC Order 890? f. In preparing its PVRR analysis, if the Company had assumed that the third-party customer seeking 500 kW of firm transmission service would have been required to pay the monthly incremental cost transmission rate using the revenue requirement associated with the required upgrades, would the $(843 million) PVRR entry in Exhibit No. 31 have changed to zero? If the Company's response is "no,"please explain in detail why. Request No. 78: Gateway South. Please refer to Mr. Link's direct testimony,pages 29- 30, in which he refers to PacifiCorp's obligation to provide 500 MW of firm point-to-point transmission service to a third-party customer. a. Does the referenced transmission service customer currently have a transmission service agreement with the Company? If yes, are the rates charged under the agreement the embedded cost rate in the Company's OATT or the monthly incremental cost transmission rate using the revenue requirement associated with the Gateway South project? b. When did the referenced customer begin to take transmission service from PacifiCorp? If the customer has not yet started to take service, when does the Company expect the customer to begin taking service? BAYER'S FIFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3 c. If the customer has not yet started to take service, is the customer still subject to charges from the Company? If yes,please indicate the rate and annual amount of the charges. d. If the rate charged under the agreement is the embedded cost rate in the Company's OATT,please explain why the Company did not seek to charge the monthly incremental cost transmission rate using the revenue requirement associated with the Gateway South project? DATED this 201h day of August, 2024. RACINE OLSON, PLLP --------------- By: THOMAS J. BUDGE BAYER'S FIFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 4 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 201h day of August, 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 FIFTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 5