20170912Utah_UAE Set 2 (1-12).DOCX

Gary A. Dodge (0897)
Phillip J. Russell (10445)
HATCH, JAMES & DODGE, P.C.
10 West Broadway, Suite 400
Salt Lake City, Utah 84101
Telephone: [phone]
Facsimile: [phone]
Email:[e-mail]
[e-mail]
Counsel for Utah Association of Energy UsersBEFORE THE PUBLIC SERVICE COMMISSION OF UTAH
IN THE MATTER OF THE VOLUNTARY REQUEST OF ROCKY MOUNTAIN POWER FOR APPROVAL OF RESOURCE DECISION TO REPOWER WIND FACILITIES
Docket No. 17-035-39
SECOND DATA REQUEST OF THE UTAH ASSOCIATION OF ENERGY USERS TO ROCKY MOUNTAIN POWER
The Utah Association of Energy Users (UAE) hereby submits its second data request in this docket to Rocky Mountain Power (RMP):
2.1For the existing Leaning Juniper Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.2For the existing Goodnoe Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.3For the existing Marengo 1 Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.4For the existing Marengo 2 Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.5For the existing Glenrock 1 Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.6For the existing Glenrock 3 Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.7For the existing Rolling Hills Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.8For the existing Seven Mile Hill 1 Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.9For the existing Seven Mile Hill 2 Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.10For the existing High Plains Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.11For the existing McFadden Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
2.12For the existing Dunlap Wind Plant assets that will be replaced by repowered assets and which RMP intends to remove from plant in service, but continue to earn a return on, please provide the following information on both a total company and Utah allocated basisfor each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers:
a.The average annual rate base associated with the replaced assets.
b.The annual rate of return using the same return as used in RMP’s levelization analysis.
c.The annual book depreciation amount using current depreciation rates applicable to the rate base identified in a. above.
d.The annual current income tax expense related to the rate of return identified in b. above.
e.The annual deferred income taxes related to the rate base identified in a. above.
Please provide your responses to the following:
Gary A. Dodge
Phillip J. Russell
HATCH, JAMES & DODGE
10 West Broadway, Suite 400
Salt Lake City, Utah 84101
Telephone: [phone]
Facsimile: 801-363-6666
Email:[e-mail]@hjdlaw.com
Kevin Higgins
Neal Townsend
ENERGY STRATEGIES
215 S. State Street, #200
Salt Lake City, UT 84111
Telephone: [phone]
Facsimile: 801-521-9142
E-mail: [e-mail] [e-mail]
This request includes a request for any responsive confidential or proprietary information. Each counsel and consultant for UAE who will be given access to confidential information has executed or will prior to such access execute a Nondisclosure Agreement under Rule R746-100-16 and/or an Appendix A to any protective order entered in this docket, and the requested information will be treated in accordance with the terms of said rule and/or protective order.DATED this 31stday of August 2017.
HATCH, JAMES & DODGE
/s/ ________________________
Gary A. Dodge
Attorneys for UAE
Certificate of Service
Docket No. 17-035-39
I hereby certify that a true and correct copy of the foregoing was served by email this day 31stday of August 2017 on the following:
ROCKY MOUNTAIN POWER
Jeff [e-mail]
Yvonne [e-mail]
Bob [e-mail]@pacificorp.com
DIVISION OF PUBLIC UTILITIES
Patricia Schmid [e-mail]
Justin Jetter [e-mail]
Chris Parker [e-mail]
William Powell [e-mail]
OFFICE OF CONSUMER SERVICES
Steven [e-mail]
Robert Moore [e-mail]
Michele Beck [e-mail]
Cheryl Murray [e-mail]
NUCOR STEEL
Peter J. [e-mail]
Eric J. [e-mail]
Jeremy R. [e-mail]
Interwest Energy Alliance
Mitch M. [e-mail]
Lisa Tormoen Hickey [e-mail]
UTAH CLEAN ENERGY
Sophie [e-mail]
Kate [e-mail] /s/ _____