20240903Bayer to PAC 79-86.pdf

BAYER’S SIXTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 1
Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center St.
Pocatello, Idaho 83204-1391
[phone]
[e-mail]
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
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND
REGULATIONS
CASE NO. PAC-E-24-04
BAYER’S SIXTH SET OF
DISCOVERY REQUESTS TO
ROCKY MOUNTAIN POWER
P4 Production, L.L.C., an affiliate of Bayer Corporation (“Bayer”), by and through
counsel, submits this sixth 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. 79: Wildfire Mitigation Plan. Does the Company intend to seek deferred
accounting treatment for any of the costs included in the Wildfire Mitigation Plan filed June 7,
2024 in Case No. PAC-E-24-09? If yes, please identify the costs that the Company would
propose to defer.
Request No. 80: Generation Overhaul Expense. Please refer to Attachment Bayer 49.
RECEIVED
Tuesday, September 3, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER’S SIXTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2
a. What is the projected generation overhaul expense for Jim Bridger Unit 1 and Jim
Bridger Unit 2 for each year, 2024-2028?

b. All things being equal, does RMP expect generation overhaul expenses for Jim
Bridger Unit 1 and Jim Bridger Unit 2 to be lower now that they operate as gas units
rather than as coal units? If not, please explain.

c. Please provide the annual generation overhaul expense for the Naughton 3 unit in
each of the six years prior to its conversion to natural gas.

Request No. 81: General. Is the Company aware of any errors contained in its rate case
filing? If yes, please provide a detailed description of each known error, explain how each of the
errors impacts Exhibit No. 48, and provide the adjustment in Excel format that would be
necessary to correct the error. Please update this response as any additional errors become
known to the Company.
Request No. 82: Major Plant Additions. Regarding Ms. Shelley E. McCoy’s major
plant additions included in Exhibit No. 48, Adjustment 8.5.

a. Please identify any major capital additions included in Adjustment 8.5 that have now
been cancelled or delayed past the end of the forecasted 2024 test period.

b. Please identify any major capital additions included in Adjustment 8.5 where the in-
service date has been delayed from the date assumed and shown in Adjustment 8.5
(but still falls within the 2024 test period).

c. Please identify any major capital additions included in Adjustment 8.5 where RMP
has updated the anticipated capital addition amount (but still falls within the 2024
test period).

d. Please prepare an updated version of Ms. McCoy’s Adjustment 8.5 that reflects the
latest in-service date and capital additions amount as provided in this response
comparable to RMP’s as-filed Adjustment 8.5 and derive the adjustments by FERC
account and allocation factor that would be necessary to reflect the updated
information in the RAM. Please provide this workpaper in Excel format with
formulas intact.

e. Please provide workpapers deriving any other rate base or expense adjustments (i.e.
depreciation reserve, depreciation expense, ADIT, property taxes, O&M expenses,
etc.) by FERC account and allocation factor that would be necessary to properly
reflect this updated in-service date and updated capital addition information in the
RAM.

f. Please update this response if any subsequent changes become known to the
Company.

BAYER’S SIXTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3
Request No. 83: Major Plant Additions - Contingency Costs. Regarding Ms. Shelley
E. McCoy’s major capital additions adjustment shown included in Exhibit 48, Adjustment 8.5.

a. Do any of the projects included in Adjustment 8.5 include contingency costs?

b. If any of the plant additions included in the Company's pro forma plant additions
adjustment include contingency costs, please describe RMP’s practice regarding the
inclusion of contingency costs in its pro forma capital additions.

c. If any of the plant additions included in the Company's pro forma plant additions
adjustment include contingency costs, please specify which projects include
contingency costs and the amount included for each project, in Excel format.

d. If any plant additions include contingency costs, please indicate whether the
Company's current projection of contingency costs to be used for these projects
varies from the amounts included in the Company's filing. If so, please provide a
current estimate of the amount of contingency cost by project, in Excel format.

e. If the Company's current projection of contingency costs varies from the amount
included in the Company's direct filing, please provide a workpaper with formulas
intact that derives all the adjustments necessary to completely remove the
contingency costs for the identified projects in the RAM by FERC account and
allocation factor.

Request No. 84: Klamath Regulatory Asset. Please refer to RMP’s Adjustment 8.9 -
Klamath Regulatory Asset.

a. Please provide the workpaper, preferably in Excel format with formulas intact,
deriving the December 2023 beginning Total Company balance of $4,830,028.

b. Please provide the workpaper deriving the monthly Total Company amortization
expense amount of $99,589.

c. Please provide the complete amortization schedule by month over the 5-year period
that begins with the starting Regulatory Asset balance.

d. Please compare and explain the difference, if any, for the starting Klamath
Regulatory Asset balance in this rate case with the corresponding balance from
RMP’s last Idaho rate case, PAC-E-21-07.

Request No. 85: Wildfire Litigation Expenses. For both the 2023 historic period and test
year, please identify the amount of RMP’s wildfire litigation expenses (net of any insurance
reimbursements) by FERC account and allocation factor included in RMP’s direct filing. Please
identify the location within RMP’s filing workpapers where these amounts are included or are
identified.

BAYER’S SIXTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 4
Request No. 86: Wildfire Litigation Expenses. Please provide RMP’s wildfire
litigation expenses (net of any insurance reimbursements) by FERC account and allocation factor
for the following periods:

a. The 2023 historic year.

b. Calendar year 2022.

c. Calendar year 2021.

DATED this 3rd day of September, 2024.
RACINE OLSON, PLLP

By:
THOMAS J. BUDGE
BAYER’S SIXTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 5
CERTIFICATE OF MAILING

I HEREBY CERTIFY that on this 3rd day of September, 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
Commission Secretary
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

Adam Triplett
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]

Bayer:
Brian C. Collins
Greg Meyer
Brubaker & Associates
[e-mail]
[e-mail]

Kevin Higgins
Neal Townsend
Energy Strategies LLC
[e-mail]
[e-mail]

PacifiCorp
Data Request Response Center
[e-mail]

Mark Alder
Idaho Regulatory Affairs Manager
[e-mail]

Joe Dallas
Senior Attorney
Rocky Mountain Power
[e-mail]

Idaho Irrigation Pumpers Association
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
[e-mail]

Lance Kaufman, Ph.D.
[e-mail]

PIIC
Ronald L. Williams
Brandon Helgeson
HAWLEY TROXELL
[e-mail]
[e-mail]

Bradley Mullins
MW Analytics
[e-mail]

PIIC Electronic Service Only:
Val Steiner: [e-mail]
Kyle Williams: [e-mail]

Idaho Conservation League
Matthew Nykiel
Attorney for Idaho Conservation League
[e-mail]

Brad Heusinkveld
Idaho Conservation League
Regulatory Counsel
[e-mail]

THOMAS J. BUDGE