20240909Bayer to PAC 87-88.pdf

BAYER’S SEVENTH 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 SEVENTH 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 seventh 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. 87: Transmission Revenue. In Response to IPUC DR No. 145, RMP
provided the workpaper supporting the adjustments for the transmission revenue items - Firm
Wheeling Revenue, Pre-Merger Firm Wheeling Revenue – UPD, Ancil Revenue Sch 2- Reactive
(Trans), Ancillary Revenue Sch 1 -Scheduling, and Transmission Point-to-Point Revenue.

a. Please confirm that the $3,094.94/MW-Mo. shown in the workpaper for the pro forma
line adjustment of Firm Wheeling Revenue, Pre-Merger Firm Wheeling Revenue – UPD,
and Transmission Point-to-Point Revenue adjustments is the FERC-approved “projected”
RECEIVED
Monday, September 09, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER’S SEVENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2
transmission rate for the Jun – 2022 to May 2023 time period. If not confirmed, please
explain and provide the source of this rate.

b. Please confirm that the $3,091.54/MW-Mo. shown in the workpaper for the pro forma
line adjustment of Firm Wheeling Revenue, Pre-Merger Firm Wheeling Revenue – UPD,
and Transmission Point-to-Point Revenue adjustments is the FERC-approved “projected”
transmission rate for the Jun – 2023 to May 2024 time period. If not confirmed, please
explain and provide the source of this rate.

c. Please explain the source of the $3,494.49/MW-Mo. transmission rate used for the pro
forma line adjustment for the Jun – 2024 to Dec. 2024 time period. Please provide any
workpapers supporting the derivation of this rate in Excel format with formulas intact. If
this is not a FERC-approved transmission rate, please also explain how and why it differs
from the FERC-approved “projected” transmission rate for this time period.

d. Please explain why RMP did not use the current FERC-approved “projected”
transmission rate of $ $4,460.80/MW-Mo for the pro forma line adjustment for the Jun –
2024 to Dec. 2024 time period

Request No. 88: Transmission Revenue. In Response to IPUC DR No. 145, RMP
provided the workpaper supporting the adjustments for the transmission revenue items - Firm
Wheeling Revenue, Pre-Merger Firm Wheeling Revenue – UPD, Ancil Revenue Sch 2- Reactive
(Trans), Ancillary Revenue Sch 1 -Scheduling, and Transmission Point-to-Point Revenue. For
the following time periods, what impact, if any, does the FERC-approved “true-up” transmission
rate have on the Transmission Revenues reflected in RMP’s direct filing? If there is no impact,
please explain why not.

a. The “True-Up” rate of $4,032.560/MW-Mo. for the Jan.-2023 to Dec.-2023 time period.

b. The “True-Up” rate for the Jan.-2024 to Dec. 2024 time period. Note: the 2024 calendar
year true-up rate is not yet posted on the OATI website.

DATED this 9th day of September, 2024.
RACINE OLSON, PLLP

By:
THOMAS J. BUDGE
BAYER’S SEVENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3
CERTIFICATE OF MAILING

I HEREBY CERTIFY that on this 9th 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