20170912Wyoming_WIEC Set 3 (1-12).DOCX

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AN ORDER APPROVING NONTRADITIONAL RATEMAKING RELATED TO WIND REPOWERING.
DOCKET NO. 20000-519-EA-17
(Record No. 14780)WYOMING INDUSTRIAL ENERGY CONSUMERS’
THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
The Wyoming Industrial Energy Consumers (“WIEC”), an unincorporated association comprised of industrial energy consumers, by and through its undersigned counsel, Holland & Hart LLP, respectfully submits its third set of data requests to Rocky Mountain Power, a division of PacifiCorp (“Company” or “Rocky Mountain Power”). The following response date, definitions, and instructions apply to this set of data requests:
RESPONSE DATEPlease respond to these data requests within 10 calendar days, i.e., by September 11, 2017, unless an earlier date is specified by the Wyoming Public Service Commission or by agreement between WIEC and Rocky Mountain Power.
DEFINITIONS AND INSTRUCTIONSPlease refer to the Definitions and Instructions included in WIEC’s First Set of Data Requests to Rocky Mountain Power in the above-captioned docket.
THIRD SET OF DATA REQUESTS
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
For 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 Wyoming allocated basis for each year used in RMP’s levelization analysis as shown in the Status Quo portion of the workpapers. Please provide this information in electronic format, preferably Excel, with formulas intact.
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.
Respectfully submitted this 1st day of September, 2017.
HOLLAND & HART LLP
By: Abigail C. Briggerman, #7-5476
Holland & Hart LLP
6380 South Fiddlers Green Circle, Suite 500Greenwood Village, CO 80111
Telephone: (303) [e-mail] FOR WIEC
CERTIFICATE OF SERVICE
I hereby certify that, on this 1st day of September, 2017 the WYOMING INDUSTRIAL ENERGY CONSUMERS’ THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER was served via electronic mail or U.S. Mail, addressed to the following:
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
315 W 27th Street
Cheyenne, WY 82001
[e-mail]
Paul Hickey
Hall & Evans, LLP
P.O. Box 467
Cheyenne, WY 82003-0467
[e-mail]
Wyoming Public Service Commission
2515 Warren Avenue, Suite 300
Cheyenne, WY 82002
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Crystal J. McDonough
McDonough Law, LLC
1635 Foxtrail Dr. #327
Loveland, CO 80538
[e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
[e-mail]
Katherine McDowell
Adam C. Lowney
McDowell Rackner & Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
[e-mail]
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]
Ivan H. Williams
Christopher Leger
Wyoming Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[e-mail]
[e-mail]
Lisa Tormoen Hickey
14 N. Sierra Madre
Colorado Springs, CO 80903
[e-mail]
s/ Patti Penn
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