20240924Bayer 89-93 to PAC.pdf

RECEIVED
Tuesday, September 24, 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
[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 CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND BAYER'S EIGHTH 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 eighth 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. 89: Wildfire Litigation Expenses. In its response to Bayer Data Request
No. 85, RMP provided the calendar year 2023 wildfire litigation expenses on both a Total
Company and Idaho allocated basis and indicated these amounts are included in FERC Account
925 (Injuries & Damages). Further, RMP stated that it"has not applied any pro-forma
adjustment to these balances in the Test Year." According to witness Shelley E. McCoy's
Exhibit No. 48, the adjusted Idaho FERC Account 925 amount is $2,357,590. Does RMP's
response to Bayer Data Request No. 85 mean that the Idaho allocated wildfire litigation expense
amount contained in Confidential Attachment Bayer 85 is included in the adjusted FERC
BAYER'S EIGHTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

Account 925 amount of$2,357,590 shown in Ms. McCoy's Exhibit 48? If no, please explain
what wildfire litigation expense amount is included in Ms. McCoy's Exhibit 48 adjusted FERC
Account 925 amount and reconcile this amount to the Idaho allocated amount provided in
Confidential Attachment Bayer 85.
Request No. 90: Wildfire Litigation Expenses. In its Confidential response to PIIC
Data Request Nos. 22 & 23, RMP provided its legal and expert witness expenses recorded in the
2023 base year. This response appears to indicate that wildfire litigation legal and expert witness
expenses are recorded in FERC accounts 923 or 925. Please confirm that the wildfire legal and
expert witness expenses in the 2023 base year are only recorded in these two FERC accounts. If
not confirmed, please provide the 2023 base year wildfire legal and expert witness expenses by
FERC account and allocation factor recorded in the 2023 base year.
Request No. 91: Wildfire Litigation Expense. Please refer to RMP witness Shelley E.
McCoy's Exhibit 48, Adjustment 4.6 (Insurance Expense). On page 4.6.1 (page 78 of 303) for
this adjustment, RMP provides the adjustments to move from RMP's net accrued expense to a
three-year average cash basis for FERC account 925 (Injuries &Damages Expense). For each
line shown on page 4.6.1,please provide the amount of wildfire litigation and expert witness
expenses, if any, included in the amounts in each column shown on this page.
Request No. 92: Wildfire Litigation Expense. Please refer to RMP witness Shelley E.
McCoy's Exhibit 48, Adjustment 4.4 (Outside Services Expense). On page 4.4.1 (page 72 of
303) for this adjustment, RMP provides the adjustments to move from RMP's December 2023
actual outside services expenses to a three-year average basis for FERC account 923 (Outside
Services Expense). For the Idaho (ID) and System Overhead(SO) lines shown on page 4.4.1,
please provide the amount of wildfire litigation and expert witness expenses, if any, included in
the amounts shown on this page.
Request No. 93: Gateway South. Please refer to Mr. Link's direct testimony,page 29,
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. On what date did this customer file its request for interconnection service from the
Company?
b. On what date did this customer file its transmission service request with the Company?
c. Was the Gateway South transmission project included in the Company's long term
transmission plan prior to the interconnection request from this customer?
d. Was the Gateway South transmission project included in the Company's long term
transmission plan prior to the transmission service request from this customer?
e. On the date this customer filed its transmission service request, was Gateway South
identified on the Company's OASIS as a planned project?
BAYER'S EIGHTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

f. On the date this customer filed its transmission service request, did the Company's
Available Transfer Capability(ATC)postings reflect incremental transmission capacity
associated with the Gateway South project?
DATED this 241h day of September, 2024.
RACINE OLSON, PLLP
By: -- -
THOMAS J. BUDGE C1757—r
BAYER'S EIGHTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 241h 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 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 EIGHTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 4