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Home My WebLink About20241008PAC to Bayer 89-93.pdf RECEIVED Tuesday, October 08, 2024 IDAHO PUBLIC UTILITIES COMMISSION _ ROCKY MOUNTAIN POWER A DIVISION OF PACIFICORP 1407 W North Temple, Suite 330 Salt Lake City, Utah 84116 October 8, 2024 Thomas J. Budge tj(&racineolson.com(C) Brian C. Collins bcollins(&consultbai.com Greg Meyer gmeyerkconsultbai.com Kevin Higgins khiggins(c�r�,energystrat.com(C) Neal Townsend ntownsendkenergystrat.com(C) RE: ID PAC-E-24-04 Bayer Set 8 (89-93) Please find enclosed Rocky Mountain Power's Responses to Bayer's 8"' Set Data Requests 89- 93. If you have any questions, please feel free to call me at (801)220-2313. Sincerely, /s/ Mark Alder Manager, Regulation Enclosures C.c.: Eric L. Olsen/IIPA elokechohawk.com(C) Lance Kaufman/IIPA lance(&ae isg insi h�(C) Matthew Nykiel/ICL matthew.nykiel(&gmail.com Brad Heusinkveld/ICL bheusinkveld(&idahoconservation.org Ronald L. Williams/PIIC rwilliamskhawleytroxell.com Brandon Helgeson/PIIC bhel eg sonLhawleytroxell.com Bradley Mullins/PIIC brmullins(&mwanalytics.com Val Steiner/PIIC val.steiner(&itafos.com Kyle Williams/PIIC williamsk(&byui.edu Monica Barrios-Sanchez/IPUC monica.barriossanchez(a),puc.idaho.gov SecretM(a,puc.Idaho.gov PAC-E-24-04/Rocky Mountain Power October 8, 2024 Bayer Data Request 89 Bayer Data Request 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 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. Response to Bayer Data Request 89 Yes. Rocky Mountain Power(RMP)response to Bayer Data Request 85 does mean that the Idaho allocated wildfire legal expense amount provided in Confidential Attachment Bayer 85 is included in the adjusted FERC Account 925 amount of$2,357,590 shown in RMP witness McCoy's Exhibit No. 48. Recordholder: Laura Miller Sponsor: Shelley McCoy PAC-E-24-04/Rocky Mountain Power October 8, 2024 Bayer Data Request 90 Bayer Data Request 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. Response to Bayer Data Request 90 It is confirmed that the wildfire legal and expert witness fees provided in the Company's responses to PIIC Data Request 22 and PIIC Data Request 23 are recorded only in FERC Account 923 and FERC Account 925. Recordholder: Tarisa Chiotti Sponsor: Shelley McCoy PAC-E-24-04/Rocky Mountain Power October 8, 2024 Bayer Data Request 91 Bayer Data Request 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. Response to Bayer Data Request 91 The amounts included on page 4.6.1 of McCoy's Exhibit 48,Adjustment 4.6 (Insurance Expense) do not include legal and expert witness fees. Recordholder: Laura Miller Sponsor: Shelley McCoy PAC-E-24-04/Rocky Mountain Power October 8, 2024 Bayer Data Request 92 Bayer Data Request 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. Response to Bayer Data Request 92 Please refer to the table below for the wildfire legal and expert witness fees that are included in the system overhead (SO) lines shown on page 4.4.1 of McCoy's Exhibit No. 48. There are not any wildfire legal and expert witness fees that are included in the Idaho lines shown on page 4.4.1. Factor 2021 2022 2023 SO 14,240 (6,256,391) 7,173,071 Recordholder: Laura Miller Sponsor: Shelley McCoy PAC-E-24-04/Rocky Mountain Power October 8, 2024 Bayer Data Request 93 Bayer Data Request 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-parry 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? Response to Bayer Data Request 93 (a) May 7, 2021. (b) March 15, 2019. (c) Yes. (d) Yes. (e) Yes. Recordholder: Kris Bremer/Veronica Whitesmith Sponsor: Rick Vail