20241106PIIC to PAC 51-66.pdf

RECEIVED
Wednesday, November 6, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
HAWLEY TROXELL ENNIS &HAWLEY LLP
877 W. Main Street, Suite 200
P.O. Box 1617
Boise, ID 83701-1617
Telephone: [phone]
Facsimile: 208.954.5253
Email: [e-mail]
[e-mail]
Attorneys For PIIC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO CASE NO. PAC-E-24-04
INCREASE ITS RATES AND CHARGES IN
IDAHO AND APPROVAL OF PROPOSED THIRD PRODUCTION REQUEST OF
ELECTRIC SERVICE SCHEDULES AND PACIFICORP IDAHO INDUSTRIAL
REGULATIONS CUSTOMERS TO ROCKY
MOUNTAIN POWER
PacifiCorp Idaho Industrial Customers ("PIIC"), by and through its attorneys of record
and pursuant to the Rules of Procedure of the Idaho Public Utilities Commission
("Commission"), hereby requests that Rocky Mountain Power("RMP")provide the following
documents and information no later than Wednesday, November 27, 2024.
Please provide answers to each question and supporting work papers that provide detail or
are the source of information used in calculations. In addition to the written copies provided as
response to the questions,please provide all Excel and electronic files on CD or via e-mail or other
electronic communication with formulas activated. Please provide a copy of all responses
electronically to PIIC consultant,Brad Mullins,via his email as shown on the attached service list.
This Production Request is continuing, and RMP is requested to provide,by way of supplementary
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 1
59501.0004.17804723.1

responses, additional documents that it or any person acting on its behalf may later obtain that will
augment the documents produced.
Request No 51: Please provide PacifiCorp's actual total-system and Idaho-allocated Gross
Plant Balances detailed by FERC account and allocation factor as of the last day of each month
beginning September 2023 through September 2024 (i.e. 13-months). If accounting for
September 2024 plant balances is not yet available,please provide the balances as of the last day
of each month beginning August 2023 through August 2024. Please exclude plant held for
future use from this information and separately detail any plant acquisition adjustments.
Request No 52: Please provide PacifiCorp's actual total-system and Idaho-allocated
Depreciation and Amortization Reserve balances detailed by FERC account and allocation factor
as of the last day of each month beginning September 2023 through September 2024 (i.e. 13-
months). If accounting for September 2024 plant is not yet available,please provide the
balances as of the last day of each month beginning August 2023 through August 2024.
Request No 53: Please provide PacifiCorp's actual total-system and Idaho-allocated
Accumulated Deferred Income Tax balances detailed by FERC account and allocation factor as
of the last day of each month beginning September 2023 through September 2024 (i.e. 13-
months). If accounting for September 2024 balances is not yet available,please provide the
balances as of the last day of each month beginning August 2023 through August 2024.
Request No 54: Please provide PacifiCorp's total-system and Idaho-allocated actual Fuel
Stock balances with detail by power plant(or fuel stock source) as of the as of the last day of
each month beginning September 2023 through September 2024 (i.e. 13-months). If accounting
for September 2024 balances is not yet available, please provide the balances as of the last day of
each month beginning August 2023 through August 2024.
Request No 55: Please provide PacifiCorp's total-system and Idaho-allocated Material &
Supplies balances with detail by FERC account as of the as of the last day of each month
beginning September 2023 through September 2024 (i.e. 13-months). If accounting for
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 2
59501.0004.17804723.1

September 2024 plant balances is not yet available,please provide the balances as of the last day
of each month beginning August 2023 through August 2024.
Request No 56: Please provide PacifiCorp's total-system and Idaho-allocated Working
Capital balances as of the last day of each month beginning September 2023 through September
2024 (i.e. 13-months). If accounting for September 2024 plant balances is not yet available,
please provide the balances as of the last day of each month beginning August 2023 through
August 2024.
Request No 57: Please provide PacifiCorp's Idaho-allocated Customer Advances for
Construction balances with detail by power plant(or fuel stock source) as of the as of the last day
of each month beginning September 2023 through September 2024 (i.e. 13-months). If
accounting for September 2024 plant balances is not yet available, please provide the balances as
of the last day of each month beginning August 2023 through August 2024.
Request No 58: Please provide PacifiCorp's most recent load forecast, including load,
peak and coincident peak forecasting data by jurisdiction and month over the period January 1,
2025 through December 31, 2027.
Request No 59: Please provide the (1)Aurora project files; (2)Aurora model workpapers;
and(3)working version of the NPC reports used develop the indicative and final NPC in Docket
No. UE 434, the 2025 Transition Adjustment Mechanism
Request No 60: Reference RMP's response to WIEC Data Request 2.8 in Wyoming PSC
Docket No 20000-642-EM-23:
a. Please provide Physical Position Reports and Position Calculators, in the manner
provided in the referenced response, for each trading day on, or nearest to, the
first day of each month over the period January 1, 2023 through November 30,
2024.
b. For each file provided in response to sub part(a)please provide the forward price
curve input into the dispatch simulation used to develop the Physical Position
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 3
59501.0004.17804723.1

Report and Position Calculators. Please provide the hourly input file, or the same
level of granularity as modeled in the dispatch simulation.
c. Does PacifiCorp apply a DART adjustment to its forward price curve when
developing its Physical Position Reports and Position Calculators? If no,please
explain why not.
Request No 61: Please state the date that RMP plans to begin participating in the
California extended day ahead market.
Request No 62: Reference RMP's response to WIEC Data Request 4.27 in Wyoming
Docket No. 20000-664-EM-24: For each of RMP's owned wind facilities,please provide the
P50 production estimates assumed at the time the facility was constructed and/or repowered, as
provided in response to the referenced request.
Request No 63: Reference Mitchell Workpaper"ID—GRC-2025:" For each of RMP's
owned wind facilities, please identify the variance between the P50 production estimates
assumed at the time the facility was constructed and/or repowered and the modeled production
estimates assumed in the referenced NPC Report forecast. If there is a variance, please explain
why.
Request No 64: Reference PacifiCorp's Response to PIIC Data Request 15, workpaper
"Non-IASA":
a. Please provide details of all amounts paid to Marmon LLC over the period 2013
through 2022, and specify whether the amounts have been capitalized or
expensed.
b. Please provide financial statements for Marmon LLC for calendar year 2023.
c. Please provide all invoices received by Marmon LLC for charges incurred in
calendar year 2023.
d. Please identify the projects where the amounts incurred for Marmon LLC in the
referenced request have been charged.
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 4
59501.0004.17804723.1

e. Please provide all competitive solicitations and bids received in which Marmon
LLC participated and resulted in the charges identified in the referenced
workpaper
Request No 65: Reference PacifiCorp's response to PIIC Data Request 22, Confidential
Attachment PIIC 22:
a. For each line in the referenced workpaper,please state the allocation factor (i.e.
System Overhead, Oregon, Idaho, etc.)that applies.
b. Please provide the equivalent transaction data for calendar years 2021 and 2023,
with the allocation factor included for each row.
Request No 66: Reference RMP's response to PIIC Data Request 15, workpaper"IASA"
a. For each line item in the referenced report please provide a description of the
intercompany charge.
b. Please provide intercompany invoices and accounting workpapers used to derive
the following charges:
FERC INCL in REV
SRC PLATFORM CD Account DST AMT REQ BILL PERIOD NM
Berkshire Hathaway Energy
Company 9210000 8,737.34 202301 Y
Berkshire Hathaway Energy
Company 1070000 497,310.14 202301 N
Berkshire Hathaway Energy
Company 9239990 10,531.37 202312 Y
Berkshire Hathaway Energy
Company 1652100 565,273.39 202311 Y
Berkshire Hathaway Energy
Company 1651000 924,854.38 202310 Y
Berkshire Hathaway Energy
Company 1070000 412,751.53 202302 N
Berkshire Hathaway Energy
Company 1070000 700,000.00 202309 N
Berkshire Hathaway Energy
Company 1652100 647,217.46 202309 Y
Berkshire Hathaway Energy
Company 1070000 1,118,840.00 202308 N
Berkshire Hathaway Energy
Company 1070000 773,823.94 202308 N
Berkshire Hathaway Energy
Company 1652100 2,138,282.49 202307 Y
Berkshire Hathaway Energy
Company 1652100 408,954.01 202305 Y
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 5
59501.0004.17804723.1

Dated this 6th day of November, 2024.
HAWLEY TROXELL ENNIS & HAWLEY LLP
By
�Aq'" � k/4t,
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
Attorneys For PIIC
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 6
59501.0004.17804723.1

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I caused to be served a true copy of the foregoing THIRD
PRODUCTION REQUEST OF PACIFICORP IDAHO INDUSTRIAL CUSTOMERS TO
ROCKY MOUNTAIN POWER by the method indicated below, and addressed to each of the
following:
Commission Secretary ❑ U.S. Mail, Postage Prepaid
Idaho Public Utilities Commission ❑ Hand Delivered
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A ❑ Overnight Mail
Boise, ID 83714 0 E-mail
secretaa9]2uc.idaho.gov ❑ Facsimile
❑ iCourt
Data Request Response Center ❑ U.S. Mail, Postage Prepaid
825 NE Multnomah St. Suite 2000 ❑ Hand Delivered
Portland, OR 97232 ❑ Overnight Mail
datarequest(kpacificorp.com 0 E-mail:
❑ Facsimile
❑ iCourt
Joe Dallas ❑ U.S. Mail, Postage Prepaid
Rocky Mountain Power ❑ Hand Delivered
825 NE Multnomah, Suite 2000 ❑ Overnight Mail
Portland, OR 97232 0 E-mail:
joseph.dallas(kpacificorp.com ❑ Facsimile
❑ iCourt
Mark Adler ❑ U.S. Mail, Postage Prepaid
Rocky Mountain Power ❑ Hand Delivered
1407 West North Temple, Suite 330 ❑ Overnight Mail
Salt Lake City, UT 84116 0 E-mail:
mark.adler(kpacificorp.com ❑ Facsimile
❑ iCourt
Brad Mullins ❑ U.S. Mail, Postage Prepaid
Principal Consultant ❑ Hand Delivered
MW Analytics ❑ Overnight Mail
Teitotie 2, Suite 208 0 E-mail:
Oulunsalo Finland, FI-90460 ❑ Facsimile
brmullins(d,mwanaltyics.com ❑ iCourt
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 7
59501.0004.17804723.1

Eric L. Olsen ❑ U.S. Mail, Postage Prepaid
Echo Hawk& Olsen PLLC ❑ Hand Delivered
505 Pershing Ave., Suite 100 ❑ Overnight Mail
PO Box 6119 0 E-mail:
Pocatello, ID 83205 ❑ Facsimile
elogechohawk.com ❑ iCourt
Aegis Strategies ❑ U.S. Mail, Postage Prepaid
Lance Kaufman: ❑ Hand Delivered
lancegae isi�nsig_ht.com ❑ Overnight Mail
0 E-mail:
❑ Facsimile
❑ iCourt
Thomas J. Budge ❑ U.S. Mail, Postage Prepaid
Racine, Olson, PLLP ❑ Hand Delivered
201 E. Center ❑ Overnight Mail
PO Box 1391 0 E-mail:
Pocatello, ID 83204-1391 ❑ Facsimile
tinracineolson.com ❑ iCourt
Brian C. Collins ❑ U.S. Mail, Postage Prepaid
Greg Meyer ❑ Hand Delivered
Brubaker&Associates ❑ Overnight Mail
16690 Swingley Ridge Rd., #140 0 E-mail:
Chesterfield, MO 63017 ❑ Facsimile
bcollins(&,consultbai.com ❑ iCourt
gmeer(&,consultbai.com
Kevin Higgins ❑ U.S. Mail, Postage Prepaid
Neal Townsend ❑ Hand Delivered
Energy Strategies LLC ❑ Overnight Mail
khiggins(kenergystrat.com 0 E-mail:
ntownsend(iy�,energystrat.com ❑ Facsimile
❑ iCourt
Brad Heusinkveld ❑ U.S. Mail, Postage Prepaid
Idaho Conservation League ❑ Hand Delivered
710 N. 6 h St. ❑ Overnight Mail
Boise, ID 83702 0 E-mail:
bheusinkveld&idahoconservation.org ❑ Facsimile
❑ iCourt
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 8
59501.0004.17804723.1

Val Steiner ❑ U.S. Mail, Postage Prepaid
Itafos Conda, LLC ❑ Hand Delivered
val.steiner(i6tafos.com ❑ Overnight Mail
Q E-mail:
❑ Facsimile
❑ iCourt
Kyle Williams ❑ U.S. Mail, Postage Prepaid
BYU Idaho ❑ Hand Delivered
williamskkbb. u�i.edu ❑ Overnight Mail
0 E-mail:
❑ Facsimile
❑ iCourt
Dated: November 6, 2024.
A l V414"
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
PIIC Third Production Request to RMP, Case No. PAC-E-24-04—p. 9
59501.0004.17804723.1