20241007Bayer 100 to PAC.pdf

BAYER’S ELEVENTH 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 ELEVENTH 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 eleventh 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. 100: Wheeling Revenue Adjustments. Please refer to the 1st Revised
Response to IPUC Data Request 145. Further refer to Confidential Attachment IPUC 145 1st
Revised.

a. On tab “B – Pre-Merger Adj”, lines 22-33, the forecasted transmission rates do not match
the forecasted transmission rates on tabs “A – Firm Wheeling Adj” and “E – 302980
Adj”. Please explain why the forecasted transmission rates on tab B are different than the
forecasted transmission rates on tabs A and E.
RECEIVED
Monday, October 07, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER’S ELEVENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2
DATED this 7th day of October, 2024.

RACINE OLSON, PLLP

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

I HEREBY CERTIFY that on this 7th day of October, 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