20240926Bayer 94-96 to PAC.pdf

RECEIVED
Thursday, September 26, 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 NINTH 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 ninth 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. 94: Please refer to Confidential Attachment Bayer 34 provided in Response
to Bayer Data Request 34. Pease explain how sellbacks of hedges Deal Nos. 2334384, 2335565,
2336726, 2336170, and 2344336 are in accordance with PacifiCorp's Energy Risk Management
Policy and will help achieve the Company's goal of achieving physical hedges at 75% of the
peak usage.
Request No.95: Please provide the following information with respect to PacifiCorp's
Multi-State Process ("MSP"):
BAYER'S NINTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 1

a. Current version of the PacifiCorp MSP,
b. Expiration date of PacifiCorp's current MSP,
c. Please explain in detail if the expiration of PacifiCorp's' current MSP could
impact the RMP Idaho revenue requirement proposed in this proceeding,
d. Please provide any estimates of cost impacts prepared by the Company that would
impact Idaho's jurisdictional revenue requirement.
Request No. 96: Please provide the hourly regulation reserves (MW) included in the
Aurora Production model. Please explain if the volume of regulation reserves are provided as an
input in the Aurora model, or are calculated within the model. If the Company produces any
inputs that determines the volume of regulation reserves within the model please provide all
workpapers supporting the inputs in their original format with all formulae and links intact.
DATED this 261h day of September, 2024.
RACINE OLSON, PLLP
By:
THOMAS J. BUDGE
BAYER'S NINTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 261h 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 NINTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3