20241115Bayer to PAC 115-116.pdf

RECEIVED
Friday, November 15, 2024
IDAHO PUBLIC
Thomas J. Budge, ISB No. 7465 UTILITIES COMMISSION
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 SIXTEENTH 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 sixteenth set of discovery requests to Rocky Mountain Power(' MP")
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. 115: Accounting Write-Offs.
a. Please provide the total amount of write-offs of assets, by year, on a total
Company and on an Idaho jurisdictional basis, for 2019 through 2023. This
should include write-offs of CWIP, Preliminary Survey and Investigation Charges
and any other assets written-off by the Company. Please exclude any write-offs
associated with uncollectible customer accounts from this response.
BAYER'S SIXTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

b. For write-offs in the Base Year,please indicate the amount of each write-off by
account.
Request No. 116: Accounting Write-Offs. Please provide a detailed description of
material write-offs of assets and/or liabilities where material write-offs are those greater than
$250,000 from the start of the Base Year-To Date that affect the Idaho revenue requirement.
For each material write-off,please provide the following:
c. Copy of the journal entry recording the write-off,
d. Detailed description of the purpose of the write-off;
e. Copies of studies, reports or analyses done in determining whether or not to write
off the asset;
f. Amount of the write-off and identification of the accounts charged on a total
Company and an Idaho jurisdictional basis; and
g. Amount included in the projected Test Period for write-offs, if any, on a total
Company and an Idaho jurisdictional basis,by account.
h. Identify when (i.e., month and year) these costs that were written-off were
originally incurred by the Company.
DATED this 151h day of November, 2024.
RACINE OLSON, PLLP
By:
THOMAS J. BUDGE
BAYER'S SIXTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 151h day of November, 2024, 1 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 elo(& echohawk.com
secretMkpuc.Idaho.gov
Lance Kaufman, Ph.D.
Adam Triplett lancegae_isg insi_hg t.com
Deputy Attorney General
Idaho Public Utilities Commission PIIC
adam.triplett(&,puc.idaho.gov Ronald L. Williams
Brandon Helgeson
Bayer: HA WLEY TROXELL
Brian C. Collins rwilliamskhawleytroxell.com
Greg Meyer bhel eg son(d),hawleytroxell.com
Brubaker&Associates
bcollins(d),consultbai.com Bradley Mullins
gmeyer(kconsultbai.com MW Analytics
brmullins(&,mwanaltyics.com
Kevin Higgins
Neal Townsend PIIC Electronic Service Only:
Energy Strategies LLC Val Steiner: Val.Steiner&itafos.com
khiggins(d),energystrat.com Kyle Williams: williamsk(d),byui.edu
ntownsend(k energ_ystrat.com
Idaho Conservation League
PacifiCorp Matthew Nykiel
Data Request Response Center Attorney for Idaho Conservation League
datarequest(kpacificorp.com matthew.n_ k�(kgmail.com
Mark Alder Brad Heusinkveld
Idaho Regulatory Affairs Manager Idaho Conservation League
mark.alder(4pacificorp.com Regulatory Counsel
bheusinkveld(d),idahoconservation.org
Joe Dallas
Senior Attorney
Rocky Mountain Power
joseph.dallas(d),pacificorp.com
carla.scarsella(kpacificorp.com
THOMAS J. BUDGE
BAYER'S SIXTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3