20130705PAC to Staff 17,18,20.pdf

ROCKY MOUNTAIN
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July 3,2013
Jean Jewell
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Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702-5918
iean j ewell@puc. state. sov (C)
Teni Carlock
Terri.Carlock@opuc.i daho. gov (C)
RE: ID PAC-E-13-02
IPUC Data Request (17-20)
Please find enclosed Rocky Mountain Power's responses to IPUC Data Requests 17, l8 and 20.
The response to IPUC 19 will be provided separately. Also provided are Attachments IPUC 17,
and 18 <1,2, and 4). Also provided is Confidential Attachment IPIIC l8 -3. Confidential
information is provided subject to the terms and conditions of the confidentiality agreement in
this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J.Wktatm/a
J. Ted Weston
Manager, Regulation
Enclosure
C.c.: Randall C. BudgeAvlonsanto [e-mail]
James R. Smith/lr,f onsanto Company i im.r.smitl-@,.monsanto. com (C)
Brubaker & Associatesllvlonsanto [e-mail]
Jim T. S el ecky/Tvlonsanto JSelecky@consultbai. com (C )
201 Soutlr Main,Suite 2300
Salt Lake City, Uah 841 I I
PAC-E- I 3-O2lRocky Mountain Power
July 3, 2013
IPUC Data Request 17
IPUC Data Request 17
Please provide PacifiCorp responses to the following data requests from Utah and
Wyoming.
Wyoming requests
Wyoming Docket #20000-427-EA-13 (WPSC Set 2)o Data Request 2.1.8 Regarding studies utilized by PacifiCorp
o Data Request 2.1.9 Regarding cost estimates provided by PacifiCorp
Wyoming Docket #20000-427-EA-13 (WIEC Set 2)o Data Request 2-9 Regarding FERC account and survivor curveo Data Request 2-13 Regarding remaining life calculationso Data Request 2-14 Regarding FERC vs intrastate depreciation rateso Data Request 2-15 Regarding proposed changes in depreciation expenseo Data Request 2-16 Regarding probable retirement year
o Data Request 2-17 Regarding ARO'so Data Request 2-18 Regarding regulatorso Data Request 2-23 Regarding plant locations
o Data Request 2-24 Regxding plant retirementso Data Request 2-27 Regarding final retirementso Data Request 2-34 Regarding Depreciation comparison
o Data Request 2-35 Regarding Carbono Data Request 2-40 through2-46 Regarding Asset Accountingo Data Request 2-49 Regarding annual maintenanceo Data Request 2-52Regarding estimateso Data Request 2-53 through 2-55 Regarding industry statisticso Data Request 2-58 Regarding depreciation studyo Data Request 2-62Regarding replacement expenditureso Data Request 2-63 Regarding cost of removal
o Data Request 2-65 Regarding point of retirement
o Data Request 2-66 Regarding expectationsr Data Request 2-69 Regarding retirement rateo Data Request 2-70 Regarding service lifeo Data Request 2-73 Regarding life studieso Data Request 2-74 Regarding life studieso Data Request 2-75 Reguding retirements vs replacemento Data Request 2-77 Regxding?0l2lOk filingo Data Request 2-79 Regarding Carbon
Wyoming Docket # 20000-427-EA-13 (WIEC Set 3)o Data Request 3-1 Regarding Carbon asbestos abatemento Data Request 3-2 Regarding Jordan and Hale plant
PAC-E-I 3-O2lRocky Mountain Power
luly 3,2013
IPUC Data Request 17
o Data Request 3-3 Regarding Wind Farms
o Data Request 3-6 Regarding "replacenients"
o Data Request 3-7 Regarding accounting for plant replacement
Wyoming Office of Consumer Advocate (OCA Set l)
o Data Request 1.3 Regarding Klamath Falls
o Data Request 1.4 Regarding Carbon
o Data Request 1.5 Regarding Bridger mine
Please include all responses provided by you including all data sub-sets (i.e. a, b, c)
Utah requests
Office of Consumer Services (OCS Set 1)
o Data Request 1.12 Regarding company policy for recording depreciation expense
o Data Request l.l7 -1.21 Regarding Net Salvage Value
o Data Request L25 Regarding Net Salvage Valueo Data Request 1.28 Regarding Net Salvage Value
o DataRequest 1.46 Regarding Remaining Life
o Data Request 1.5 Regarding Demolition
o Data Request 1.54 Regarding Reserve
o Data Request 1.56 Regarding SPR
o Data Request 1.6 Regarding Account 311o Data Request 1.61 Regarding Account 312
Office of Consumer Services (OCS Set 3)
o Data Request 3. I Regarding follow up on Data Request I .17
o Data Request 3.14 Regarding Carbono Data Request 3.15 Regarding Carbono Data Request 3.16 Regarding Carbon
Office of Consumer Services (OCS Set 4)
o Data Request 4.1-4.2 Regarding Production Life
Division of Public Utilities (DPLI Set 2)
o Data Request 2.15 Regarding a Confolmance Index
o Data Request 2.17 Regarding Total Retirementso Data Request 2.23 Regarding Recent Studieso Data Request 2.24Regarding Carbon
o Data Request 2.25 Regarding FERC FORM 1/3Qr Data Request 2.31 Regarding Communication Equipment
o Data Request 2.33 Regarding Mine Retirement
o Data Request 2.37 Regarding Decommissioning Costs
o Data Request 2.38 Regarding Hale Plant
o Data Request 2.39 Regarding Small Plants
Division of Public Utilities (DPU Set 3)o Data Request 3.la & b Regarding coal reserves
PAC-E- I 3-O2lRocky Mountain Power
July 3, 2013
IPUC Data Request 17
o Data Request 3.3-3.5 Regarding the Enata filed on February L9,2013
o Data Request 3.16 Regarding Technical Conference
Division of Public Utilities (DPU Set 4)o Data Request 4.1 Regarding Gadsby Plant
Division of Public Utilities (DPU Set 6)o Data Request 6.3 Regarding DPU 2.25 and Carbonr Data Request 6.13 Regarding Craig
Division of Public Utilities (DPU Set 7)o Data Request 10.6 Regarding DPU 2.38 Hale plant
o Data Request 10.9 Regarding DPU 2.23 Cafion plant
o Data Request 10.10 Regarding DPU 2.23 Carbon
Division of Public Utilities (DPU Set 8)o Data Request 8.1 Regarding Craig units I and 2
Response to IPUC Data Request 17
Please refer to Attachment IPUC 17 for the requested copies.
Recordholder: Kaley McNay
Sponsor: N/A
PAC-E- I 3-O2iRocky Mountain Power
July 3,2013
IPUC Data Request l8
IPUC Data Request 18
Also, please provide us with any data requests regarding depreciation included in
the data requests from Oregon and Washington raie cases.
Response to IPUC Data Request 18
Please see Attachment IPUC l8- I for depreciation-related data requests received
by the Company in the current general rate cases in Oregon and Washington
(dockets IJE 263 and UE- 1 30043, respectively).
Please see Attachment IPUC l8-2 and Confidential Attachment IPUC l8-3 for the
Company's responses and attachments.
Please see Attachment IPUC l8-4 for the Company's responses and attachments
to data requests in Oregon docket UM 1647 and Washington docket tIE-130052.
Confidential information is provided subject to the terms and conditions of the
confidentiality agreement in this proceeding.
Recordholder:
Sponsor:
Kaley McNay
N/A
PAC-E- I 3 -02lRocky Mountain Power
July 3, 2013
IPUC Data Request 20
IPUC Data Request 20
Finally, we are still awaiting responses to our data request #14 and #15,
Data Request #14: Please provide a schedule by year showing the dollar changes
estimated for Carbon. Include all additions, retirements, depreciation, etc. Please
also provide an explanation of the additions and retirements.
Data Request #15: Please provide a schedule(s) showing the depreciation
components if Naughton Unit 3 separated from the other two units when
converted to gas. Explain assumptions and impacts.
Response to IPUC Data Request 20
Responses to Data Requests 14 and 15 were provided on May 28,2013.
Recordholder:
Sponsor:
Kaley McNay
N/A
Mark C. Moench
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2300
salt Lake city, utah 841 1l
Telephone No. (801) 22A-4014
Facsimile No. [phone]
Email: daniel.solander@pacifi corp.com
Attorneyfor Roclcy Mountain Power
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TIIE APPLICATION
OF ROCKY MOI]NTAIN POWER FORAUTHORITY TO CHANGE
DEPRECIATION RATES APPLICABLE
TO ELECTRIC PROPERTY
CASE NO. PAC.E-13.02
ATTORNEY'S CERTIFICATE
CLAIM OF CONFIDEI{TIALITY
RELATING TO DISCOYERY
RESPONSES
I, Daniel E. Solander, represent Rocky Mountain Power in the above captioned matter. I
am Senior Counsel for Rocky Mountain Power.
I make this certification and claim oflconfiaentiality regarding a confidential document
provided in response to IPUC l8 pursuant to IDAPA 31.01.01 because Rocky Mountain Power,
through its supporting workpapers, is disclosing certain information that is Confidential and
constitutes Trade Secrets as defined by ldaho Code Section 9-340 and 48-801 and protected
under IDAPA 31.01.01.067 and 31.01.01.233.
Rocky Mountain Power herein asserts that the aforementioned response is confidential in
that the information consists of a discussion of commercially sensitive coal mine reclamation
costs. Disclosing this information could give entities access to competitive information Rocky
Mountain Power believes could be used to disadvantage it and its customers.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 9-340 and 48-801, and should therefore be protected from public inspection, examination
and copying, ild should be utilized only in accordance with the terms of the Protective
Agreement between Rocky Mountain Power and Idaho Public Utilities Commission Staff
DATED this 3rd day of July,2013.
Daniel E. Solander
Attorneys for Rocky Mountain Power
oR uE-263
ICNU Data Request 1.36
Please identify whether the depreciation rate for the Carbon plant has cha4gefl-frqm the
Company's last general rate case, and, if so, please identify the total Compiny ana -
Oregon revenue requirement impact of the change.
wA uE-130043
PC Data Request 48
Please provide per books unadjusted Plant in Service on a total PacifiCorp and
Washington retail jurisdictional assigned/allocated basis by detailed FERC subaccount at
June 30, 2012. If current/existing and Docket UE-130052-proposed depreciation rates
have been developed/are being proposed in a more specific, or in a greater level of detail,
than the FERC plant subaccount basis (i.e., production generating plant-specific basis),
please additionally provide Plant in Service balances at June 30,2012 at such below-the-
subaccount basis as may be applicable. This request seeks Plant in Service values in
sufficient detail so as to permit a calculation of annualized Washington retail
jurisdictional depreciation expense associated with test year end Plant in Service at
current/existing depreciation rates as well as utilizing Docket UE-130052-proposed
depreciation rates.
PC Data Request 49
For any Plant in Service subaccounts for which related depreciation expense is
capitalized in whole or in part (as opposed to full reflection as depreciation or
amortization expense on the Company's income statement), please provide total
depreciation calculated for the entire test year associated with each such Plant in Service
balance as well as breakout of such amount of depreciation that was reflected as
depreciationlamortrzation expense on the income statement versus the amount that was
capitalized during the historic test year. Additionally, provide the June 30,2012 Plant in
Service value of each plant subaccount for which related depreciation expense was
capitalized in whole or in part during the historic test year.
PC Data Request 50
Please confirm that the Company has not proposed a proforma or restating adjustment
that annualizes Washington retail jurisdictional depreciation expense based upon June 30,
2012 end-of-test-year balances. Alternatively, please specify exactly where within
workpapers provided such annualization adjustment can be observed and the Washington
retail jurisdictional value of such adjustment.
PC Data Request 51
Please provide current/existing depreciation rates as well as depreciation rates as
proposed within Docket No. UE-130052 (and presumably used to develop proforma
adjustment 6.3 in the current docket) by detailed FERC subaccount. If such rates are
developed in more specific or greater detail than the FERC plant subaccount basis (i.e.,
production generating plant-specific basis), provide such additional detailed delineation
below-the-subaccount basis as may be applicable.
PC Data Request 55
Reference the Company's Adjustment 6.3 (Proposed Depreciation Rates-
Expense) and Adjustment 6.3.1 (Proposed Depreciation Rates- Reserve) as well
as the underlying spreadsheet workpaper entitled "6.3 Proposed Depreciation
Rates.xlsx." Please answer/provide the following regarding the noted adjustment
and supporting workpapers:
a. Please explain the conceptual purpose underlying each noted adjustment.
b. Does the posting of the Depreciation Reserve and Accumulated Deferred Income Tax
Reserve adjustments represent the theoretical value of the Depreciation Reserve and
related ADIT Reserve balance that would exist at June 30, 2OI2if the depreciation
rates being proposed within Docket UE-130052 had been in place throughout the
historic test year? If no, please state what such values represent.
c. When an order is issued within Docket No. UE-130052, when would such
depreciation rate changes be used in calculating depreciation expense for financial
statement reporting purposes?
d. Does PacifiCorp envision, and has it requested authority to, retroactively post
adjustments to the Accumulated Depreciation Reserve and related ADIT Reserve
once any order approving a change in depreciation rates within Docket UE-130052 is
issued to reflect what values would exist in those accounts if the revised depreciation
rates had been in effect in periods preceding the issuance of the order? If yes, provide
all support for such position.
e. Reference Tab 6.3.2 of the spreadsheet workpaper entitled "6.3 Proposed
Depreciation Rates.xlsx."
i. Please provide all support for the "Proposed Rate" and "Current Rate" values
shown.
ii. Does the total "DEPE Adjustment" in the amount of $136,301,757 rcpresent the
estimated annual increase in Total Company depreciation expense that would have
been recorded for the twelve months ending June 30, 2012 if the depreciation rates
being proposed within Docket UE-130052 had been in effect throughout such
twelve month reporting period? If not, please state/discuss exactly what such
value represents.
iii. Does the"41010" value of -$5I,727 ,880 represent the estimated total company
annual decrease in deferred income tax expense that would be expected to have
been recorded for the twelve months ending June 30, 20L2lf depreciation rates
being proposed within Docket UE-130052 had been in effect through the twelve
month reporting period? If no, please state/describe exactly what such value
represents.
iv. Assuming subpart (c) (iii) confirms that the value of -$5I,727,88O represent the
estimated total company annual decrease in deferred income tax expense that
would be expected to have been recorded for the twelve months ending June 30,
2012 it depreciation rates being proposed within Docket UE-130052 had been in
effect through the twelve month reporting period, does such calculation assume
that the change in book depreciation rates will create a change in tax straight line
depreciation expense? If yes, please state and show specifically where such
change is considered anywhere within this calculation or in any other
restating/proforma adjustment being proposed by the Company. If no, please
explain why such revision is unnecessary or inappropriate.
f. Reference Tab 6.3 of spreadsheet workpaper entitled "6.3 Proposed Depreciation
Rates.xlsx""
v. Please provide the source for, and explain the derivation of the factor, I .35L7o that
is applied to "Total Company" Schedule M Additions, Deferred Income Tax
Expense, and the Deferred Income Tax Balance to derive Washington
jurisdictional valuations of each.
vi. Please explain/discuss conceptually how it is possible that an $801,076 change in
Washington retail jurisdictional book depreciation expense attributable to a
change in authorized depreciation rates can generate a related decrease in
Washington retail jurisdictional Deferred [ncome Tax expense in the amount of
$3,802,663.
WUTC Data Request 68
Requestor: Chris McGuire
Re: Major Plant Additions/ Sheet 8.4
Referring to Exhibit No. _ (SRM-3), sheet 8.4, Depreciation Expense and Accumulated
Reserve for hydro additions, please explain why the Depreciation Expense value in cell
F20 ($5,237,8I3) does not equal the Accumulated Reserve value in cell F15
($5,774,8r4).
WUTC Data Request226
Requestor: Eric Russell
Re: Exhibit No.-(ALK-1), Klamath Hydroelectric Project
On page 3 of Ms. Kelly's direct testimony, a statement is made that the Company is
seeking Commission approval of a depreciation schedule that would depreciate "all
costs" associated with the Klamath facilities on a straight line basis so the net book value
reaches zero by December 31,2019, to coincide with the target date for decommissioning
and facilities removal.
Please explain in detail what is meant by "all costs". Does this refer to all costs
spent on the relicensing effort to the end of test year in this general rate case, or
all costs through December 3I,2019, or some other time period?
Please specify the actual costs, or confirm that the costs are those outlined in the
present value revenue requirement analysis (Exhibit No._(ALK-5C)).
WUTC Data Request 233
Requestor: David Nightingale
Re: Exhibit No._(SRM-1T), pagelT, Hydro Decommissioning
Mr. McDougal states on page 17, lines l5-I7 of his direct testimony that, based on a2007
depreciation study approved by the Commission in Order 0l Docket UE-071795, an
additional $19.4 million is required for decommissioning of various hydro facilities.
1. Please provide all supporting documentation for the statement that the additional
depreciation amount is "based on" the 2007 study that the Commission approved. Please
include in your response all citations in that Order 01 where this additional depreciation
is approved or required.
2. Is the $19.4 million mentioned by Mr. McDougal based solely on the 2007 depreciation
study or is it adjusted to include the results of the 201 I depreciation study from Docket
UE-130052, Exhibit No. _ (JJS-3)? Please explain in detail.
3. Please reconcile the $19.4 million in Mr. McDougal's testimony with the results of the
2007 versus 2011 depreciation studies. Please include all supporting workpapers in fully
functioning format with all formulae intact. Please explain the reconciliation, including
reference to any FERC requirements and other considerations.
WUTC Data Request23{
Requestor: David Nightingale
Re: Exhibit No._(SRM-1T), pagelT, Hydro Decommissioning
Please provide:
1. A listing of all West Control Area hydro resources indicating which resources are
scheduled for decommissioning and when, and which resources are not scheduled for
decommissioning.
2. For each West Control Area hydro resource scheduled for decommissioning:
a. Any proposed change in depreciation remaining life span in years and the
rationale for each change.
b. An explanation of when any new depreciation remaining life span is being
proposed to be applied as a revised accrual schedule.
1.
2.
c. Depreciation accruals for the test year ending, June 30, 2012, using the2OOT
study.
d. Depreciation accruals for the test year ending, June 30, 2012, using the 2011
study, if different than the 2007 study, or state that there is no difference.
e. The cumulative difference between use of the 2007 versus 201 1 depreciation
studies from June 30,2012 through the proposed pro-forma period, December
30,2013.
For all West Control Area hydro projects scheduled for decommissioning, the
cumulative differences between 2007 and 2011 depreciation assumptions.
A reconciliation between the West Control Area projects scheduled for decommissioning
total cumulative differences provided above in part 3 and the $19.4 million additional
depreciation expense cited by Mr. McDougal on page 17 ,line 17 of his direct testimony.
WUTC_OnSite Data Request 2
Please provide a detailed description, along with supporting workpapers or references to
workpapers already provided, for the changes in depreciation expense and reclamation
expense referenced in Exhibit No.-(GND-1CT), page l4,lines 8-12).
J.
4.