20240904PAC to IIPA 1-46.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 4, 2024
Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail] (C)
RE: ID PAC -E-24-04
IIPA Set 1 (1-46)
Please find enclosed Rocky Mountain Power’s Responses to IIPA 1st Set Data Requests 1-46
excluding 1, 3-6, 8, 10, 13, 19, 32, 38 and 46. The remaining responses will be provided under
separate cover. Provided via e-mail are the non-confidential Attachments. The Confidential
Response and Confidential Attachments are provided via BOX. 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.: Lance Kaufman/IIPA [e-mail] (C)
Monica Barrios-Sanchez/IPUC [e-mail]
[e-mail]
Matthew Nykiel/ICL [e-mail]
Brad Heusinkveld/ICL [e-mail]
Thomas J. Budge/Bayer [e-mail] (C)
Brian C. Collins/Bayer [e-mail]
Greg Meyer/Bayer [e-mail]
Kevin Higgins/Bayer [e-mail] (C)
Neal Townsend/Bayer [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
RECEIVED
Wednesday, September 4, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Brandon Helgeson/PIIC [e-mail]
Bradley Mullins/PIIC [e-mail]
Val Steiner /PIIC [e-mail]
Kyle Williams/PIIC [e-mail]

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 2

IIPA Data Request 2

How do non-attorney RMP employees record labor costs associated with
litigation? Please provide illustrative accounting ledger entries.

Response to IIPA Data Request 2

Non-attorney Rocky Mountain Power (RMP ) employees do not record labor costs
associated with litigation.

Recordholder: Sheila Diver

Sponsor: Nikki Kobliha

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 7

IIPA Data Request 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.

Response to IIPA Data Request 7

Please refer to the table provided below:

Deferral Description Case No. Requesting Recovery or Amortization in
PAC-E -24-04?
2019 ECAM Deferral PAC-E-20-02 No
Rate Plan Application - Cholla PAC-E-20-03 No
COVID Deferred Accounting Order PAC-E-20-04/GNR-U-20 -03 No
2021 General Rate Case PAC-E-21-07 Yes*
2020 ECAM Deferral PAC-E-21-09 No
2021 ECAM Deferral PAC-E-22-05 No
2022 ECAM Deferral PAC-E-23-09 No
Wildfire Liability Deferral PAC-E-23-16 No, application withdrawn without prejudice.
Wildfire Insurance Premium Deferral PAC-E-23-18 Yes
NTO Property Disposition and
Accounting Deferral PAC-E-23-19 No, case is pending.
2023 ECAM Deferral PAC-E-24-05 No

* In Case No. PAC-E-21 -07, the company was permitted to defer the incremental depreciation expense approved in
Case No. PAC -E-18-08. Also in Case No. PAC-E-21-07, the parties agreed that the Company would continue to defer
the incremental costs in the Resource Tracker Mechanism (RTM) through December 31, 2021 as a regulatory asset.
The Company is seeking recovery of this RTM balance in the current case, PAC-E-24-04.

Recordholder: Mark Alder

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 9

IIPA Data Request 9

For each excess liability insurance policy renewal from 2019 to present, please
provide all documentation of the policy.

Response to IIPA Data Request 9

Please refer to Confidential Attachment IIPA 9.

The company will update this response to include the 2024/2025 Excess Liability
cost once it becomes available in 4th Quarter of 2024.

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: Wendy Wallis

Sponsor: Mariya V Coleman

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 11

IIPA Data Request 11

Does the proposed Catastrophic Fire Fund or Insurance Mechanism require
participation by all states in PacifiCorp’s jurisdiction? If no, why not?

Response to IIPA Data Request 11

The Company is not proposing an Insurance Mechanism as part of this general
rate case (GRC). The requested Insurance Cost Adjustment (ICA) includes
Idaho’s allocated portion of the 2024/2025 insurance premiums and the
amortization of the insurance deferral. The ICA does not require participation by
all states in PacifiCorp’s jurisdiction.

The full design and operation of the Catastrophic Fire Fund is still under
development and discussion with stakeholders in the workshop process. As such,
how the fund would operate if not all states participate is yet to be determined.

Recordholder: Shelley McCoy

Sponsor: Joelle Steward

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 12

IIPA Data Request 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?

Response to IIPA Data Request 12

Yes. The Company intends to withdraw the proposed funding of the Catastrophic
Fire Fund from this general rate case (GRC) in Idaho to allow time for additional
development of the proposal.

Recordholder: Shelley McCoy

Sponsor: Joelle Steward

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 14

IIPA Data Request 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.

Response to IIPA Data Request 14

Based on conversation held on August 22, 2024 between the Company and the
Idaho Irrigation Pumpers Association (IIPA ), clarification was reached to provide
period balances by FERC Account, general ledger (G/L) account and allocation
factor. Since calendar year 2024 is not yet complete, the data provided for annual
balances will be calendar years 2019 through 2023. Based on the foregoing
clarifications, the Company responds as follows:

Please refer to Attachment IIPA 14.

Recordholder: Tyler Wells

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 15

IIPA Data Request 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.

Response to IIPA Data Request 15

Please refer to Attachment IIPA 1.15 which provides information on union
increases. Please refer to the table below which provides information on non-
union increases:

Year/Program Increase Percent
2024 Merit 3.50 percent
2023 Merit 3.50 percent
2022 Merit 3.69 percent
2021 Merit 1.50 percent
2020 Merit 2.80 percent
2019 Merit 2.70 percent

Recordholder: Matthew Swanson / Sam Hayden

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 16

IIPA Data Request 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.

Response to IIPA Data Request 16

Please refer to the work paper supporting the direct testimony of Company
witness, Robert M. Meredith, specifically file “ID GRC Blocking 2024.xlsx”, tab
“Table 3” which supports the hard coded numbers on sheet 3.1.3-3.1.4.

Recordholder: James Zhang

Sponsor: Robert Meredith

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 17

IIPA Data Request 17

Please refer to 3.4 - REC Revenues.xlsx. Please provide work papers supporting
the hard coded numbers on sheet 3.4.1.

Response to IIPA Data Request 17

Please refer to Confidential Attachment IIPA 17. Note: the requested items are
provided from general ledger (G/L) accounts in the Company’s accounting
system, SAP.

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: Justin Waterman

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 18

IIPA Data Request 18

Please refer to 3.5 - Wheeling Revenue.xlsx. Please provide work papers
supporting the hard coded numbers on sheet 3.5.1.

Response to IIPA Data Request 18

Please refer to the Company’s response to IPUC Data Request 145 specifically
Confidential Attachment IPUC 145.

Recordholder: Louisa Bruschi-Dadik

Sponsor: Shelley E McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 20

IIPA Data Request 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?

Response to IIPA Data Request 20

Please refer the Company’s response in PIIC 19, specifically subpart d, for the
treatment of credit facility fees and the exclusion from the cost of capital.

Recordholder: Justin Waterman

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 21

IIPA Data Request 21
Please refer to 4.2 - Wage and Employee Benefits_CONF.xlsx.
(a) Please provide work papers 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 work papers supporting the hard coded numbers on sheet 4.2.5.

(e) Please provide work papers supporting the hard coded numbers on sheet 4.2.6.
(f) Please provide work papers supporting the Percentage of eligible wages on
sheet 4.2.7.

Response to IIPA Data Request 21

Referencing work paper “4.2 - Wage and Employee Benefits_CONF.xlsx”, the
Company responds as follows:

(a) No work papers supporting the hard coded numbers on tab 4.2.2 are
available. The figures referenced in this data request represent accounting
actuals for the base period at the applicable level pulled from the Company’s
accounting system to support the referenced work paper.

(b) The Company assumes 12 months ended 2019, 2020, 2021 and 2022 to be 12
months ended December of each of the listed years. Based on the foregoing
assumption, the Company responds as follows:

Please refer to Attachment IIPA 21-1.

(c) No work papers supporting the hard coded numbers on tab 4.2.3 – 4.2.4 are
available. The figures referenced in this data request represent accounting
actuals for the base period at the applicable level pulled from the Company’s
accounting system to support the work paper.

(d) No work papers supporting the hard coded numbers on tab 4.2.5 are
available. The figures referenced in this data request represent accounting
actuals for the base period at the applicable level pulled from the Company’s
accounting system to support the work paper.

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 21

(e) Please refer to Confidential Attachment IIPA 21-2 which provides the
support for the projected December 2024 gross numbers on tab 4.2.6 . The
remaining hardcoded numbers on tab 4.2.6 do not have work papers
supporting the figures available. Those numbers represent accounting actuals
at the level pulled from the Company’s accounting system to support the
work paper.

(f) Please refer to Attachment IIPA 21-3 which provides support of the Social
Security Percentage of eligible wages on tab 4.2.7. The percentage of eligible
wages for Medicare is assumed at 100 percent and does not have supporting
work papers.

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: Christina Lopas

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 22

IIPA Data Request 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 work papers supporting the hard coded numbers on sheet 4.3.1.

Response to IIPA Data Request 22

(a) The Company maintains a construction work in progress (CWIP) reserve to
estimate the risk of canceled projects written off to expense, and the
adjustment in “4.3 - Remove Non-Recurring Entries.xlsx” was to reverse a
reserve recorded in a prior period as the Company now expects to move
forward with the associated project.

(b) Please refer to Attachment IIPA 22 which provides transaction support for the
hard coded figure on Page 4.3.1 of RMP Exhibit No. 48.

Recordholder: Sheila Diver

Sponsor: Sheila Diver

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 23

IIPA Data Request 23

Please refer to 4.4 - Outside Service Expense.xlsx. Please provide work papers
supporting the hard coded numbers on sheet 4.4.1.

Response to IIPA Data Request 23

Please refer to Attachment IIPA 14 for Outside Service Expense amounts
recorded in FERC account 923 for the periods 2021 – 2023.

Recordholder: Tyler Wells

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 24

IIPA Data Request 24

Please refer to 4.5 - Generation Overhaul Expense.xlsx.

(a) Please provide work papers 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.

Response to IIPA Data Request 24

Referencing work paper “4.5 - Generation Overhaul Expense.xlsx”, the Company
responds as follows:

(a) Please refer to Attachment IIPA 24-1 which provides support for the hard
coded numbers on tab 4.5.2 (calendar years 2010 through 2023).

(b) Please refer to Attachment IIPA 24-2 which provides data by units for
PacifiCorp owned plants.

(c) Please refer to Attachment IIPA 24-1 which provides data from 2010 through
2023.

Recordholder: Justin Waterman

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 25

IIPA Data Request 25
Please refer to 4.6 - Insurance Expense.xlsx.
(a) Please provide work papers 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?

Response to IIPA Data Request 25

(a) Please refer to Confidential Attachment IIPA 25.

(b) The $35 million in third party insurance claim proceeds is being removed
from the calculation as the claim proceeds are for a cash payment that is also
being removed from the calculation.

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: Laura Miller

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 26

IIPA Data Request 26

Please refer to 4.7 - Uncollectible Expense.xlsx. Please provide the data on sheet
4.7.1 for 2017 to 2020.

Response to IIPA Data Request 26

Please refer to the table provided below:

12 Months Ended Idaho
FERC Account 904
General Business
Revenues
Uncollectible
Accounts Percent
Dec ember 2017 608,998 295,378,051 0.206%
Dec ember 2018 431,822 286,227,855 0.151%
Dec ember 2019 616,125 279,009,378 0.221%
Dec ember 2020 394,095 291,171,039 0.135%

Recordholder: Tyler Wells

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 27

IIPA Data Request 27

Please refer to 4.8 - Memberships and Subscriptions.xlsx.

(a) Please provide work papers supporting the hard coded numbers on sheet 4.8.1.

Response to IIPA Data Request 27

Please refer to Attachment IIPA 27.

Recordholder: Louisa Bruschi-Dadik

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 28

IIPA Data Request 28

Please refer to 4.9 - Pension Non-Service Expense.xlsx. Please provide work
papers supporting the hard coded numbers on sheet 4.9.1.

Response to IIPA Data Request 28

There are no work papers supporting the actual 12 months ended December 2023
figure. The figures referenced in this data request represent accounting actuals for
the base period at the applicable level pulled from the Company’s accounting
system to support the work paper. Please refer to Confidential Attachment IIPA
28 which provides the support for the Post-Retirement Non-Service Expense
forecasted 12 months ending December 2024.

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: Chistina Lopas

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 29

IIPA Data Request 29
Please refer to 4.10 - Incremental O&M.xlsx.
(a) Please provide work papers supporting the hard coded numbers on sheet 4.10.1.
(b) Please provide work papers supporting the hard coded numbers on sheet 4.2.5.

Response to IIPA Data Request 29

(a) Please refer to Attachment IIPA 29.

• Please refer to tab “2023 Wildfire Actuals” for the support for cell D16 in
4.10.1.

• Please refer to tab “2024 Wildfire Forecast” for the support for cells
G11:G15 in 4.10.1.

• Please refer to tab “2024 Corrective Main Forecast” for the support for
cell G18 in 4.10.1.

• The $808,000 listed for 2023 actuals in tab “2024 Corrective Main
Forecast” in Attachment IIPA 29 is supported by tab “2023 Corrective
Maint Actual” in Attachment IIPA 29.

(b) Sheet 4.2.5 does not exist in “4.10 – Incremental O&M.xlsx”.

Recordholder: Aaron Rose

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IPUC Data Request 30

IIPA Data Request 30
Please refer to 7.2 - Property Tax Expense.xlsx. Please provide work papers supporting the hard coded numbers on sheet 7.2.1.

Response to IIPA Data Request 30

Referencing the work papers supporting the direct testimony of Company witness,
Shelley E. McCoy, specifically file “7.2 - Property Tax Expense”, the Company
responds as follows:

The 2023 amount of $153,145,653 is what was booked to SAP account 579000
and is located in B Tab -5 (taxes other than income). For the 2024 estimate of
$147,726,894, please refer to Confidential Exhibit No. 50 (Property Tax
Estimation).

Recordholder: Matt Paz

Sponsor: Shelley E McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 31

IIPA Data Request 31

Please refer to 7.3 - Production Tax Credit.xlsx. Please provide work papers
supporting the hard coded numbers on sheet 7.3.1.

Response to IIPA Data Request 31

Referencing the work papers supporting the direct testimony of Company witness,
Shelley E. McCoy, specifically file “7.3 – Production Tax Credit”, the Company
responds as follows:

The generation amounts included in file “7.3 – Production Tax Credit” were
produced using the Aurora production cost model for wind generation on eligible
facilities. The Aurora model’s output is included in the confidential work papers
and exhibits supporting the direct testimony of Company witness, Ramon J.
Mitchell. Specifically, please refer to confidential file “ID_GRC_2025_2023
Normalized Load.xlsm. The wind generation is provided on tab “NPC
Summary”, starting on row 563.

Note: only production tax credit (PTC) eligible generation is included in file “7.3
– Production Tax Credit”. A small portion of the generation from the Glenrock,
Rolling Hills and Glenrock III wind facilities are not PTC eligible as certain
turbines within these facilities have reached the end of the PTC period. Therefore,
the production included in file “7.3 – Production Tax Credit” for these facilities is
slightly less than the production generated by the Aurora model.

Recordholder: Brian Keyser

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 33

IIPA Data Request 33

Please refer to 8.2 - Trapper Mine Rate Base.xlsx.

(a) Please provide work papers supporting the hard coded numbers on sheet 8.2.1.

(b) Please provide work papers supporting the hard coded numbers on sheet 8.2.2.

Response to IIPA Data Request 33

(a) Please refer to Confidential Attachment IIPA 33.

(b) Please refer to the Company’s response to subpart (a) 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: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 34

IIPA Data Request 34
Please refer to 8.3 - Jim Bridger Mine Rate Base.xlsx.
(a) Please provide work papers supporting the hard coded numbers on sheet 8.3.1.
(b) Please provide work papers supporting the hard coded numbers on sheet 8.3.2.

Response to IIPA Data Request 34

(a) Please refer to Confidential Attachment IIPA 34.

(b) Please refer to the Company’s response to subpart (a) 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: Shelley E McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 35

IIPA Data Request 35

Please refer to 8.4 - Customer Advances for Construction.xlsx.

(a) Please provide work papers supporting the hard coded numbers on sheet 8.4.1.

(b) Please provide the data on sheet 8.4.1 for 2019 to present.

Response to IIPA Data Request 35

(a) Please refer to Attachment IIPA 35-1.

(b) Please refer to Attachment IIPA 35-2 for the data consistent with the format
provided on Page 8.4.1 of RMP Exhibit 48. For the 2023 data, please see
Page 8.4.1 of RMP Exhibit 48. Information related to 2024 is not yet
available and will be provided with the Company’s December 2024 Idaho
Results of Operations filed on or around April 30, 2025.

Recordholder: Tyler Wells

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 36

IIPA Data Request 36
Please refer to 8.5 - Major Plant Additions.xlsx.
(a) Please provide work papers supporting the hard coded numbers on sheet 8.5.3.
(b) Please include work papers identifying the December 2024 accumulated
depreciation associated with the plant additions.

(c) For each plant addition please provide the basis for the forecasted plant.

Response to IIPA Data Request 36

(a) Please refer to the Confidential Attachment Bayer 8, specifically tab Forecast
Monthly Details CONF.

(b) Please refer to the workpaper file 6.1 and 6.2 Depr and Amort Exp_Reserve,
specifically tab 6.2.1 column L.

(c) The Company has included projected capital additions greater than $5 million
that are expected to be in-service before the rate effective period.

Recordholder: Craig Larsen

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 37

IIPA Data Request 37
Please refer to 8.6 - Miscellaneous Rate Base.xlsx.
(a) Please provide work papers 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.

Confidential Response to IIPA Data Request 37

(a) Please refer to Confidential Attachment IIPA 37-1.

(b) PacifiCorp objects to this data request on the grounds that it seeks information
that is not relevant, and the request is not reasonably calculated to lead to the
discovery of admissible evidence. Subject to and without waiving the
foregoing objection, the Company responds as follows:

The Company assumes the request for “data on 8.6.1 by month from 2020 to
present” is intended to mean monthly actual ending coal fuel stock balances in
dollars by plant for years starting in 2020 through 2024 to date. Based on the
foregoing assumption the company responds as follows:

Please refer to Confidential Attachment IIPA 37-2 which provides actual
ending coal fuel stock balances in dollars by plant for years 2020 through July
2024.

(c) The fuel stock level at the 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
throughout 2024 as the plant builds inventory
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 underground mine at BCC ceased operations 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
PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 37

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
due to unreliable coal supply. The conversion of Jim Bridger Unit 1 and Jim
Bridger Unit 2 from coal to natural gas operations in 2024, does not change
the plant’s coal supply or delivery risk profile for Jim Bridger Unit 3 and Jim
Bridger Unit 4 in 2024.

(d) The Company maintains long-term parts (LTP) and customer service
agreements (CSA) with the OEM manufactures of its combustion turbines.
These agreements have a factor fired hour (FFH) fee that is paid per hour that
the unit is operated. The FFH fees are paid quarterly and booked into prepaid
accounts. When overhauls are performed for the respective plants, the
corresponding cost of the overhaul is booked into capital or operation and
maintenance (O&M) representative of the scope of that overhaul. The prepaid
accounts are brought to $0 at the completion of a major overhaul cycle
including one hot gas path (HGP) and one major inspection.

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 / Matt Murray

Sponsor: To Be Determined

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IPUC Data Request 39

IIPA Data Request 39

Please refer to 8.12 - Pension Asset Adjustment.xlsx. Please provide work papers
supporting the hard coded numbers on sheet 8.12.1.

Response to IIPA Data Request 39

There are seven balances shown on 8.12.1. Please refer to the notes below to find
the values that make up each in order of appearance.

Account 128 Factor SO - $120,368,751
This amount comes from the $120,369 (in thousands) as shown on Exhibit B15
under Primary Account 1281000. For further details of accounting entries see tab
B15 on Attach IIPA 39.xlsx.

Account 182M Factor SO - $214,591,529
This amount comes from the sum of two account balances as follows. For further
details of accounting entries see tab B16 on Attach IIPA 39.xlsx.
$256,041 (in thousands) as shown on Exhibit B16 under Primary Account
1823870 and secondary account 187017.
($41,449) (in thousands) as shown on Exhibit B16 under Primary Account
1823870 and secondary account 18621.
256,041,000
+ (41,449,000)
214,591,000

Account 182M Factor WY - $4,830,348
This amount comes from the 4,380 (in thousands) as shown on Exhibit B16 under
Primary Account 1823870 and secondary account 187613. For further details of
accounting entries see tab B16 on Attach IIPA 39.xlsx.

Account 2283 Factor SO - $0
There is a $0 balance for this account.

Account 190 Factor SO - $10,191,000
This amount comes from the $10,191 (in thousands) as shown on Exhibit B19
under Primary Account 1901000 and Secondary Account 287198. For further
details of accounting entries see tab B19 on Attach IIPA 39.xlsx.

Account 283 Factor SO – ($91,786,905)
This amount comes from the sum of three account balances as follows. For further
details of accounting entries see tab B19 on Attach IIPA 39.xlsx.
($62,952) (in thousands) shown on Exhibit B19 under Primary Account 2831000
and Secondary Account 287738.
PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IPUC Data Request 39

($15,973) (in thousands) shown on Exhibit B19 under Primary Account 2831000
and Secondary Account 287569.
($12,863) (in thousands) shown on Exhibit B19 under Primary Account 2831000
and Secondary Account 286909.
(62,952,000)
(15,973,000)
+(12,862,000)
(91,787,000)

Account 283 Factor WY – (1,187,618)
This amount comes from the ($1,188) (in thousands) as shown on Exhibit B19
under Primary Account 2831000 and Secondary Account 286889. For further
details of accounting entries see tab B19 on Attach IIPA 39.xlsx.

Recordholder: Jeffrey Decker

Sponsor: Shelley McCoy

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 40

IIPA Data Request 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.

Response to IIPA Data Request 40

(a) Known and measurable relates to test year adjustments made in general rate
cases using an historical test year as Idaho uses. Known and measurable
means the change is known and is there a way to measure such a change. An
example of a known and measurable change is a signed new labor contract
applying to the test year. The signed contract is known, and the effect of the
contract change can be measured. In the context of Bayer Data Request 3, the
capital additions included are discrete, non-blanket projects with an
expectation of completion before the rate effective period.

(b) The Company assumes that part b is asking about the Company’s response to
Bayer Data Request 3 related to calculation of accumulated depreciation
reserve. With that assumption the Company answers as follows: No. The
response to Bayer Data Request 3 explained that the accumulated depreciation
reserve balances were not walked out to 2024 because the Company doesn’t
prepare fully forecasted rate cases in Idaho.

(c) The Company first included forecast capital projects greater than $5 million in
Docket PAC-E-08-07. The base period for that case was 12 months ended
December 31, 2007, with known and measurable adjustments through the end
of December 2008. Prior to Docket PAC -E-08-07, the Company included
forecast capital projects greater than $2 million as described in Docket PAC-
E-07-05.

Recordholder: Craig Larsen

Sponsor: Shelley McCoy
PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 41

IIPA Data Request 41
Please provide the number of employees separated from the company by month from January 2019 to present.

Response to IIPA Data Request 41

Below are termination counts for full-time and part-time employees at PacifiCorp,
including Bridger Coal Company.

Year/Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
2019 56 44 66 52 60 51 60 47 41 34 34 44
2020 54 63 45 32 31 26 42 34 36 40 24 50
2021 68 35 58 70 48 60 67 45 70 47 50 116
2022 66 59 64 70 43 54 46 43 46 41 53 80
2023 38 40 48 50 40 41 48 48 50 34 36 47
2024 44 43 55 51 51 56 46

Recordholder: Shelley Zoller

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 42

IIPA Data Request 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.

Response to IIPA Data Request 42

(a) As with all other companies, PacifiCorp saw a decline in headcount during
the COVID pandemic. As positions became open, the company reviewed the
necessity as to the immediate need to backfill.

(b) As the COVID pandemic lifted, PacifiCorp and offices were back open,
PacifiCorp sought to backfill the open positions.

(c) The company does not maintain termination data by state and department in
the normal course of business.

Recordholder: Julie Lewis

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 43

IIPA Data Request 43

Please provide the amount of over-time charged by hourly employees by month
and department in 2023.

Response to IIPA Data Request 43

Please see the table below. It is not standard practice for the Payroll Department
to track overtime by department.

2023 Amounts
01 - Jan $4,972,737
02 - Feb $3,798,771
03 - Mar $6,183,323
04 - Apr $2,921,235
05 - May $4,282,941
06 - Jun $7,176,273
07 - Jul $2,391,225
08 - Aug $4,889,005
09 - Sep $7,369,124
10 - Oct $4,417,914
11 - Nov $4,715,951
12 - Dec $6,751,446
Total $59,869,945

Recordholder: Jennifer Dudas

Sponsor: Julie Lewis

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 44

IIPA Data Request 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.

Response to IIPA Data Request 44

When it is determined that a customer will need to pay a security deposit, an entry
is made by the retail billing system to bill the customer for the deposit:

Debit– Account #115050 (FERC account 1420000) (Customer Service Deposits Receivable)
Credit – Account #230140 (FERC Account 2350000) (Customer Security Deposits)

Once the deposit is received by a customer, the retail billing system processes the
receipt and posts an entry to:
Debit– Cash
Credit – Account #115050 (FERC Account 1420000) (Customer Service Deposits Receivable)

The result is a balance in account #230140 (FERC Account 2350000) (Customer
Security Deposits) for the amount of the deposit, to be repaid back to the
customer at a later date.

Here is an example for an Idaho customer:

Original Billing – on July 2, 2024
Debit – 115050 / FERC account 1420000 (Customer Service Deposits Receivable) - $106
Credit – 230140 / FERC Account 2350000 (Customer Security Deposits) - $106

First payment of $53 on July 23, 2024
Debit – Cash - $53
Credit – 115050 / FERC account 1420000 (Customer Service Deposits Receivable) - $53

Second payment of $53 on August 19, 2024 Debit – Cash - $53
Credit – 115050 / FERC account 1420000 (Customer Service Deposits Receivable) - $53

Recordholder: Sheila Diver

Sponsor: To Be Determined

PAC-E-24-04 / Rocky Mountain Power
September 4, 2024
IIPA Data Request 45

IIPA Data Request 45

Please provide the company’s current 20 year forecast for annual energy and
system peak. Please provide such data by state.

Response to IIPA Data Request 45

The Company objects to this request on the grounds that it is outside the scope of
this proceeding and not reasonably calculated to produce admissible evidence.
Without waiving any objection, the Company responds as follows:

Please refer to Attachment IIPA 45 which provides the annual forecasted energy
at input and system peak for the 2024 through 2043. Note: this general rate case
(GRC) proceeding is based on historical data not forecasted data.

Recordholder: Lee Elder

Sponsor: Lee Elder

1
Joe Dallas (ISB# 10330)
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

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

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CASE NO. PAC-E-24-04

ATTORNEY’S CERTIFICATE
CLAIM OF CONFIDENTIALITY
RELATING TO DISCOVERY
RESPONSES

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 Idaho Irrigation Pumpers Association Set 1 contains Company
proprietary information that could be used to its commercial disadvantage.
2
Rocky Mountain Power herein asserts that the aforementioned responses contain
confidential information that the information contains Company proprietary information.
I am of the opinion that this information is “Confidential,” as defined by Idaho Code
Section 74-101, et seq. and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilized only in accordance with the terms of the
Protective Agreement in this proceeding.

DATED this 4th day of September, 2024.

Respectfully submitted,

By__________________________
Joe Dallas
Attorney
Rocky Mountain Power