20240821PAC to Bayer 49-52 and 54.pdf

RECEIVED
Wednesday, August 21, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
_ ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 21, 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 3 (49-56)
Please find enclosed Rocky Mountain Power's Responses to Bayer 3rd Set Data Requests 49-52
and 54. Also provided is Attachment Bayer 49. The responses to Bayer 53, 55-56 will be
provided under separate cover. Provided via BOX are Confidential Attachments Bayer 50 and 52
and Confidential Response Bayer 51. 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 [phone].
Sincerely,
/s/
Mark Alder
Manager, Regulation
Enclosures
C.c.: Eric L. Olsen/IIPA elo(a,echohawk.com(C)
Lance Kaufman/IIPA lancekae isinsi h�(C)
Matthew Nykiel/ICL matthew.n. k�(&gmail.com
Brad Heusinkveld/ICL bheusinkveldkidahoconservation.oriz
Ronald L. Williams/PIIC rwilliamskhawleytroxell.com
Brandon Helgeson/PIIC bhel eg sonkhawleytroxell.com
Bradley Mullins/PIIC brmullins&mwanalytics.com
Val Steiner/PIIC val.steiner(&itafos.com
Kyle Williams/PIIC williamsk(&byui.edu
Monica Barrios-Sanchez/IPUC monica.barriossancheznpuc.idaho.gov
S ecretary(a,puc.Idaho.gov

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 49
Bayer Data Request 49
Generation Overhaul—Exhibit No. 48 Page 4.5.2:
(a) Please provide the generation expense balances by broken out by individual
generation unit. For example, page 4.5.2 indicates a Yr. Ended December
2023 balance for Jim Bridger of$9,695,947. Please indicate how this value is
broken down into Unit 1, Unit 2, etc. Please provide this information for each
plant and its respective units for each year ending December 2020 through
December 2023.
(b) Jim Bridger Unit 1 and Unit 2—Please provide a narrative explanation of how
the generation overhaul expenses of Jim Bridger Units 1 and 2 were impacted
by their conversions to gas units.
(c) Jim Bridger Unit 1 and Unit 2—Please indicate what amounts and during
which years the generation overhaul expenses for Jim Bridger Units 1 and 2
are related to their conversions to gas units.
Response to Bayer Data Request 49
(a) Please refer to Attachment Bayer 49.
(b) The gas conversion of Jim Bridger Unit 1 and Jim Bridger Unit 2 has no
impact on generation overhaul expense provided in Exhibit No. 48, Page
4.5.2.
(c) Please refer to the Company's response to subpart (b) above.
Recordholder: Aaron Lively
Sponsor: To Be Determined

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 50
Bayer Data Request 50
Fuel Stock: With regard to the Company's historic "fuel stock":
(a) Please provide the forecasted value of the Company's fuel stock in each year
from 2015 through 2025 at the time a forecast was made for that respective
year for Company operating purposes.
(b) Please provide the actual value the Company fuel stock in each year from
2015 through 2023.
(c) Please provide a breakdown of the value provided in response to subpart(a)
showing each fuel type separately, providing both the US dollar value of the
fuel stock, and its quantity and unit of measure (e.g. gallons or other).
(d) Please provide a narrative explanation of how the values provided in response
to subparts (a) and (b)were calculated. Include a copy of the Company's
calculation with this response in electronic workbook format, with all cells
and formulas intact.
(e) Where fuel stock has been assigned to a specific generator, please provide a
breakdown showing:
I. The fuel types assigned to each generator.
IL The quantity of each fuel type (including the unit of measurement)
assigned to each generator.
II1. The dollar value of each fuel type assigned to each generator.
Response to Bayer Data Request 50
PacifiCorp objects to providing 2025 forecasted data as this request is requiring
information outside the scope of this proceeding, and not reasonably calculated to
lead to the discovery of admissible evidence. Without waiving the foregoing
objection, the Company responds as follows:
(a) Please refer to Confidential Attachment Bayer 50, specifically tab "Coal Fuel
Stock Forecasts", for forecasted ending coal fuel stock balances in dollars and
tons for calendar years 2015 through 2024.
(b) Please refer to Confidential Attachment Bayer 50, specifically tab "Coal Fuel
Stock Actuals", for actual ending coal fuel stock balances in dollars and tons
for calendar years 2015 through 2023.

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 50
(c) Please refer to the Company's response to subpart(a) and(b) above.
(d) Forecasted coal stock balances are updated on a monthly basis, which includes
updated calculations for anticipated received coal quantities, and updated
forecasted generation based on generation availability and load. Actual ending
coal stock balances are calculated by taking beginning inventory amounts plus
received coal stock less coal fuel stock consumption.
(e) Please refer to the Company's response to subpart(a) and(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: Heather Garcia
Sponsor: Brian Greer

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 51
Bayer Data Request 51
Fuel Stock-Exhibit No. 48 Page 8.6.1: What were the causes of the major
increases and decreases to the fuel stock balance, by generator unit, from
December 2023 to the Test Year request for each of the specific plants outlined in
Exhibit No. 48 Page 8.6.1. Specifically:
(a) Jim Bridger
(b) Cholla
(c) Colstrip
(d) Craig
(e) Hayden
(f) Hunter
(g) Huntington
(h) Dave Johnston
(i) Naughton
0) Rock Garden
Response to Bayer Data Request 51
PacifiCorp maintains coal fuel stock inventory target ranges that support the
short-term and long-term fueling needs of each plant and the total system. These
targets are reviewed and evaluated periodically by the Company in order to
determine if the ranges are adequate to provide an economic and reliable supply
of fuel to the generating stations. These evaluations consider such factors as
transportation, coal quality, market conditions, potential disruptions, laws and
regulations, and uncertainties in weather.
(a) The fuel stock level at Jim Bridger plant at the end of 2023 was well below
historical levels due to coal supply disruptions resulting from a force majeure
event. The coal fuel stock for Jim Bridger plant is forecast to increase
throu hout 2024 as the lant builds invento
The
Jim Bridger plant has been historically supplied by three local mines, the
Bridger Coal Company(BCC)underground mine and surface mine, as well as
the Black Butte mine. The under round mine at BCC ceased o erations in
2021 and
With fewer coal supply options, the Jim Bridger plant has a higher
risk of coal supply disruption. The other available coal source is the Powder
River Basin (PRB) which is located approximately 550 miles away from the
plant. The volume of PRB coal that the plant can manage by rail is limited.
Note that as recently as 2023, Jim Bridger plant generation was constrained

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 51
due to unreliable coal supply. The conversion of Jim Bridger Units 1 and 2
from coal to natural gas operations in 2024, does not change the plant's coal
supply or delivery risk profile for Jim Bridger Units 3 and 4 in 2024.
(b) PacifiCorp ceased operating Cholla Unit 4 as of December 2020.
(c) The fuel stock for Colstrip plant had no major changes from 2023 to the test
year.
(d) The fuel stock level at Craig ended below target in 2023. Therefore,
forecasted amounts reflect the planned stockpiling of coal to optimize coal
deliveries from the Trapper mine and ensure supply reliability based upon
thermal generating station requirements.
(e) The fuel stock level at Hayden ended below target in 2023 due to an
unexpected outage in the fourth quarter of 2023 at the Twentymile mine
which supplies the plant. Therefore, forecasted amounts reflect the planned
stockpiling of coal to optimize coal deliveries and increase the coal inventory
to near targeted range.
(f) The decrease to the Hunter balance is primarily due to changes to the 2024
beginning balance after 2024 source data was prepared.
(g) The fuel stock level at Huntington ended below target in 2023. Therefore,
forecasted amounts reflect the planned stockpiling of coal to optimize coal
deliveries and ensure supply reliability based upon thermal generating station
requirements.
(h) The decrease to fuel stock for Dave Johnston plant reflects the planned
reduction in deliveries during 2024 to lower the coal inventory to within the
target range.
(i) The decrease in Naughton plant is due to the planned closure of the Naughton
plant December 31, 2025, the fuel stock forecast reflects a zero balance in
December 2025 to reflect the closure.
(j) There is no forecasted change in fuel stock balances for the Rock Garden from
December 2023 to the test year.
Recordholder: Heather Garcia
Sponsor: Brian Greer

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 52
Bayer Data Request 52
Gateway Transmission Projects: Please refer to RMP witness Rick Link's work
papers, specifically the file "Link Workpaper- Table 3 Detail CONF". The
summary for each scenario included in the referenced work papers appears to link
to external spreadsheet sources. Were these external spreadsheet sources provided
with RMP's filing? If so, please identify the RMP witness and filenames where
this external scenario cost data can be located. If not, please provide these
external work papers.
Response to Bayer Data Request 52
Please refer to Confidential Attachment Bayer 52 which provides the 10 work
papers referenced in Company witness, Rick T. Link's confidential work paper
"Link Workpaper-Table 3 Detail CONF".
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: Samuel Zacharia
Sponsor: Rick Link

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 54
Bayer Data Request 54
Gateway Transmission Projects: Please refer to RMP witness Rick Link's work
papers, specifically the file "Link Workpaper Tables 3 and 4". In this file there are
some pasted values that are used to prepare the tables in this work paper. What is
the source of these pasted values? Does Mr. Link's work papers provided with
RMP's filing include the source work papers for these pasted values? If so, please
identify these work papers. If not, please provide the workpapers for these pasted
values and identify which file supports each pasted value.
Response to Bayer Data Request 54
Please refer to the Company's response to Bayer Data Request 52. Confidential
Attachment Bayer 52 includes the confidential work papers used to generate the
pasted values in cells 1-15-9, I5-9, J5-9, and K5-9 of confidential work paper"Link
Workpapers Tables 3 and 4". Below is a direct mapping of each of the pasted
cells to the work papers included in Confidential Attachment Bayer 52.
Medium Gas-Medium Carbon (MM) price-policy scenario:
• Cell H5 reports the present value of revenue requirements (PVRR) under the
MM price-policy scenario for the analysis which includes the transmission
projects. This PVRR is drawn from cell C 134 of confidential file "ST Cost
Summary -P02-MMGR ST Split Run Cost Data LT 5230 ST 19667 (C).xlsx".
• Cell I5 reports the risk-adjusted PVRR under the MM price-policy scenario
for the analysis which includes the transmission projects. This risk-adjusted
PVRR is drawn from cell C 136 of confidential file "ST Cost Summary -P02-
MMGR ST Split Run Cost Data LT 5230 ST 19667 (C).xlsx".
• Cell J5 reports the PVRR under the MM price-policy scenario for the analysis
which excludes the transmission projects. This PVRR is drawn from cell C134
of confidential file "ST Cost Summary -P02c-MMGR-GWS ST Split Run
Cost Data LT 9077 ST 21368 (C).xlsx".
• Cell K5 reports the risk-adjusted PVRR under the MM price-policy scenario
for the analysis which excludes the transmission projects. This risk-adjusted
PVRR is drawn from cell C136 of confidential file "ST Cost Summary -P02c-
MMGR-GWS ST Split Run Cost Data LT 9077 ST 21368 (C).xlsx".
Low Gas-No Carbon (LN)price-policy scenario:
• Cell H6 reports the PVRR under the LN price-policy scenario for the analysis
which includes the transmission projects. This PVRR is drawn from cell C134

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 54
of confidential file "ST Cost Summary -P02-MMGR-LN ST Split Run Cost
Data LT 5230 ST 20591 (C).xlsx".
• Cell I6 reports the risk-adjusted PVRR under the LN price-policy scenario for
the analysis which includes the transmission projects. This risk-adjusted
PVRR is drawn from cell c136 of confidential file "ST Cost Summary -P02-
MMGR-LN ST Split Run Cost Data LT 5230 ST 20591 (C).xlsx".
• Cell J6 reports the PVRR under the LN price-policy scenario for the analysis
which excludes the transmission projects. This PVRR is drawn from cell C134
of confidential file "ST Cost Summary -P02c-MMGR-GWS-LN ST Split Run
Cost Data LT 9077 ST 22691 (C).xlsx".
• Cell K6 reports the risk-adjusted PVRR under the LN price-policy scenario
for the analysis which excludes the transmission projects. This risk-adjusted
PVRR is drawn from cell C 136 of confidential file "ST Cost Summary -P02c-
MMGR-GWS-LN ST Split Run Cost Data LT 9077 ST 22691 (C).xlsx".
Medium Gas-No Carbon (MN) price-policy scenario:
• Cell H7 reports the PVRR under the MN price-policy scenario for the analysis
which includes the transmission projects. This PVRR is drawn from cell C 13 4
of confidential file "ST Cost Summary -P02-MMGR-MN ST Split Run Cost
Data LT 5230 ST 20612 (C).xlsx".
• Cell I7 reports the risk-adjusted PVRR under the MN price-policy scenario for
the analysis which includes the transmission projects. This risk-adjusted
PVRR is drawn from cell C 136 of confidential file "ST Cost Summary -P02-
MMGR-MN ST Split Run Cost Data LT 5230 ST 20612 (C).xlsx".
• Cell J7 reports the PVRR under the MN price-policy scenario for the analysis
which excludes the transmission projects. This PVRR is drawn from cell C134
of confidential file "ST Cost Summary -P02c-MMGR-GWS-MN ST Split
Run Cost Data LT 9077 ST 22334 (C).xlsx".
• Cell K7 reports the risk-adjusted PVRR under the MN price-policy scenario
for the analysis which excludes the transmission projects. This PVRR is
drawn from cell C136 of confidential file "ST Cost Summary -P02c-MMGR-
GWS-MN ST Split Run Cost Data LT 9077 ST 22334 (C).xlsx".
High Gas-High Carbon price-policy scenario:
• Cell H8 reports the PVRR under the HH price-policy scenario for the analysis
which includes the transmission projects. This PVRR is drawn from cell C134

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 54
of confidential file "ST Cost Summary -P02-MMGR-HH ST Split Run Cost
Data LT 5230 ST 20570 (C).xlsx".
• Cell I8 reports the risk-adjusted PVRR under the HH price-policy scenario for
the analysis which includes the transmission projects. This PVRR is drawn
from cell C136 of confidential file "ST Cost Summary -P02-MMGR-HH ST
Split Run Cost Data LT 5230 ST 20570 (C).xlsx".
• Cell J8 reports the PVRR under the HH price-policy scenario for the analysis
which excludes the transmission projects. This PVRR is drawn from cell C134
of confidential file "ST Cost Summary -P02c-MMGR-GWS-HH ST Split Run
Cost Data LT 9077 ST 21809 (C).xlsx".
• Cell K8 reports the risk-adjusted PVRR under the HH price-policy scenario
for the analysis which excludes the transmission projects. This PVRR is
drawn from cell C136 of confidential file "ST Cost Summary -P02c-MMGR-
GWS-HH ST Split Run Cost Data LT 9077 ST 21809 (C).xlsx".
Social Cost of Greenhouse Gases (SCGHG) price-policy scenario:
• Cell H9 reports the PVRR under the SCGHG price-policy scenario for the
analysis which includes the transmission projects. This PVRR is drawn from
cell C134 of confidential file "ST Cost Summary -P02-MMGR-SC ST Split
Run Cost Data LT 5230 ST 20633 (C).xlsx".
• Cell I9 reports the risk-adjusted PVRR under the SCGHG price-policy
scenario for the analysis which includes the transmission projects. This risk-
adjusted PVRR is drawn from cell C136 of confidential file "ST Cost
Summary -P02-MMGR-SC ST Split Run Cost Data LT 5230 ST 20633
(C).xlsx".
• Cell J9 reports the PVRR under the SCGHG price-policy scenario for the
analysis which excludes the transmission projects. This PVRR is drawn from
cell C134 of confidential file "ST Cost Summary -P02c-MMGR-GWS-SC ST
Split Run Cost Data LT 9077 ST 21872 (C).xlsx".
• Cell K9 reports the risk-adjusted PVRR under the SCGHG price-policy
scenario for the analysis which excludes the transmission projects. This risk-
adjusted PVRR is drawn from cell C136 of confidential file "ST Cost
Summary -P02c-MMGR-GWS-SC ST Split Run Cost Data LT 9077 ST
21872 (C).xlsx".
Recordholder: Samuel Zacharia

PAC-E-24-04/Rocky Mountain Power
August 21, 2024
Bayer Data Request 54
Sponsor: Rick Link

Joe Dallas (ISB# 1033)
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-24-04
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) ATTORNEY'S CERTIFICATE
MOUNTAIN POWER FOR ) CLAIM OF CONFIDENTIALITY
AUTHORITY TO INCREASE ITS ) RELATING TO DISCOVERY
RATES AND CHARGES IN IDAHO ) RESPONSES
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
I, Joe Dallas, represent Rocky Mountain Power in the above captioned matter. I am a
attorney for Rocky Mountain Power.
I make this certification and claim of confidentiality regarding the response to the attached
Idaho Public Utilities Commission Staff discovery request pursuant to IDAPA 31.01.01 because
Rocky Mountain Power, through its response,is disclosing certain information that is Confidential
and/or constitutes Trade Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and
protected under IDAPA 31.01.01.067 and 31.01.01.233. Specifically, Rocky Mountain Power
asserts that the response to Bayer Set 3 contains Company proprietary information that could be
used to its commercial disadvantage.
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