20241118Bayer to PAC 117-119.pdf

RECEIVED
Monday, November 18, 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 SEVENTEENTH SET
APPROVAL OF PROPOSED ELECTRIC OF 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 seventeenth 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. 117: Legal Expenses. For the unadjusted 2023 Base Period, please identify
the Total Company and Idaho Allocated amount of RMP's legal expenses, including outside
legal services and litigation expenses,by FERC account and allocation factor included in RMP's
direct filing. Please identify the location within RMP's filing work papers where these amounts
are included or are identified.
BAYER'S SEVENTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER I

Request No. 118: Legal Expenses. Please provide the total recorded legal expenses,
including outside legal services and litigation expenses, on a total Company and on an Idaho
jurisdictional basis, for 2019 through 2022 and 2024 to date comparable to Question 117 above.
Request No. 119: Legal Expenses. For the forecasted 2024 Test Year, please identify
the Total Company and Idaho Allocated amount of RMP's legal expenses, including outside
legal services and litigation expenses for which RMP is seeking recovery, by FERC account and
allocation factor included in RMP's direct filing. Please identify the location within RMP's filing
work papers where these amounts are included or are identified
DATED this 181h day of November, 2024.
RACINE OLSON, PLLP
THOMAS J. BUDGE
BAYER'S SEVENTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 181h 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 SEVENTEENTH SET OF DISCOVERY REQUESTS TO ROCKY MOUNTAIN POWER 3