20180307PAC to Staff UT OCS Set 13 (1-16).pdf

1407 W.North Temple
ROCKY MOUNTAIN Salt Lake City,UT 84116
POWER
A DIVISION OFPACIFICORP
February 23,2018
Béla Vastag
Office of Consumer Services
160 East 300 South
Salt Lake City,Utah 84111
[e-mail](C)
RE:UT Docket No.17-035-40
OCS 13*Set Data Request (1-16)
Please find enclosed Rocky Mountain Power's Responses to OCS 13*Set Data Requests 13.1-
13.16.Provided on the enclosed Confidential CD is Confidential Attachment OCS 13.13.
Confidential information is provided subject to Public Service Commission of Utah Rule 746-1-
602 and 746-1-603.
If you have any questions,please call me at [phone].
Sincerely,
Jana Saba
Manager,Regulation
Enclosures
C.c.Erika Tedder/DPU [e-mail] utah.gov (C)
Dan Kohler/DPU [e-mail](C)
Dan Peaco/DPU [e-mail] (C)(W)
Aliea Afnan/DPU [e-mail] (W)
[e-mail] (W)
Philip Hayet/OCS [e-mail] (C)
Gary A.Dodge/UAE [e-mail] (C)
Phillip Russell/UAE [e-mail] (C)
Kevin Higgins/UAE [e-mail] (C)
Neal Townsend/UAE [e-mail](C)(W)
Kate Bowman/UCE kate utahcleanenergy.org(C)
Emma Rieves/UCE [e-mail](C)(W)
Lisa Tormoen Hickey/[e-mail] (C)
Mitch Longson/Interwest [e-mail] (C)
Nancy Kelly/WRA [e-mail](C)
Jennifer Gardner/WRA [e-mail](C)
Penny Anderson/WRA [e-mail] (W)
Peter J.Mattheis/Nucor [e-mail] (C)
Eric J.Lacey/Nucor [e-mail] (C)(W)
William J.Evans/UIEC [e-mail]
Vicki M.Baldwin/UIEC [e-mail](W)
Chad C.Baker/UIEC [e-mail] (W)
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.1
OCS Data Request 13.1
Refer to the Supplemental Direct Testimony of Joelle R.Steward,page 15,lines 325 -
328,in which Ms.Steward indicates that the Commission has previously approved
resource acquisitionsbased on their economic benefits to customers and has allowed cost
recovery for the Cholla,Craig and Hayden and Chehalis power plants.
(a)Does the Company agree that the Commission did not establish a resource tracking
mechanism for any of these referenced resource acquisitions?
(b)Please describe how each of the above identified resource acquisitions were
recovered from customers (i.e.,normal rate case process,deferral mechanism,etc.).
(c)Please provide a citation to each Commission order approving the above identified
resource acquisitions and each Commission order addressing the recovery of the
associated costs from customers.
Response to OCS Data Request 13.1
(a)Yes.
(b)Please refer to Utah Public Service of Utah (UPSC)order Docket 97-035-01.The
Cholla,Craig and Hayden plants were included in the Company's rate case filing.
The inclusion of these plants was not contested in this case.The Commission order
doesn't specifically mention Cholla,Craig and Hayden plants.These plants have been
included in all subsequent rate cases.
Please refer to UPSC order Docket 08-035-35.The significant energy resource
decision to acquire the Chehalis plant was approved August 1,2008.Please refer to
UPSC order Docket 08-035-38.The Chehalis plant was included in the Company's
rate case filing.The rate case was resolved through a stipulation.Neither the
stipulation nor the Commission order approving the stipulation specifically mention
the Chehalis plant.The Chehalis plant has been included in all subsequent rate cases.
(c)See response to part (b)
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.2
OCS Data Request 13.2
Refer to Exhibit RMP_(JRS-2SD).
(a)Does the Company agree that if the Company files a base rate case using a test year
of 2021,under its proposal,the higher "Net Rate Base"amount on page 2,line 4
would be incorporated in the revenue requirements,all else being equal,and
customers would not receive the benefits of the reduced rate base amount for each
year thereafteruntil a future rate case that uses a test year of 2022 or later due to the
projects no longer being included in the proposed RTM once incorporated in base
rates (with the exception of the PTC impacts)?
(b)Considering page 1,Table 1,shows the highest revenue requirement impact for 2021,
which then declines each subsequent year,would the Company consider leaving the
projects in the proposed RTM mechanism after the next base rate case?If no,
explain,in detail,why not.
Response to OCS Data Request 13.2
(a)Similar to wind projects in the past or any other past capital investment,a general rate
case will establish the amount of net assets in rate base for a test period that will be
used to establish customer rates.Althoughthe assets in rate base will not change until
the next regulatory rate review,consistent with all prior general rate cases the
Company will continue to depreciate current assets and place in service other assets
that will benefit customers but will not get included in rate base until the next
regulatory rate review.
(b)No.The RTM is intended to be a short-term mechanism to properly match costs and
benefits in the interim period between project in-service and the full inclusion of costs
and benefits in rates through a general rate case.The inclusion of the Combined
Projects in base rates will eliminate the administrative need of annuallycompiling
and auditing the on-going calculation of the incremental benefits and costs associated
with the Combined Projects for an extended period.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.3
OCS Data Request 13.3
Refer to the Supplemental Direct Testimony of Joelle R.Steward in Docket No.17-035-
39,at page 4,figure 1.Also please refer to Exhibit RMP (JRS-2SD)at page 1,Table 1
in this proceeding.Since the Company is proposing an RTM in both dockets,please
provide a revised version of the "Estimated Revenue Requirement Cost (Benefit)"for
each year,2019 through 2023,that includes both the "Combined Projects"at issue in this
docket and the Repowering projects at issue in Docket No.17-035-39.
Response to OCS Data Request 13.3
Please refer to the submitted work paper files "17-035-39 RMP WP-Steward-Exhibits
2SD-4SD 2-1-18"and "17-035-40 RMP workpapers-Steward 1-16-18",tab "Savings
Summary"for an electronic spreadsheet version of the referred to "Estimated Revenue
Requirement Cost (Benefit)".These spreadsheets provide the information needed to
produce the requested revised version of the "Estimated Revenue Requirement Cost
(Benefit)"table.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.4
OCS Data Request 13.4
The Company has proposed an RTM in both this docket and in Docket No.17-035-39.
Please specify if two separate Resource Tracking Mechanisms will be used or of one
combined RTM will be used that incorporates the impacts of the projects considered in
both dockets.If one combined RTM will be used,please explain,in detail,how the
information will be presented in the annual reviews of the RTM (i.e.,all projects
combined,amounts separated between Repowering projects and the Combined Projects,
etc.).
Response to OCS Data Request 13.4
The Company proposes that two separate Resource Tracking Mechanisms be used.See
Exhibit RMP_(JKL-5)in both filings.In this docket,the Company proposed Schedule
97B to implement the RTM for the Combined Projects;in Docket No.17-035-39,the
Companyproposed Schedule 97 to implement the RTM for the wind repowering.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.5
OCS Data Request 13.5
Would the Companybe willing to implement an RTM that includes a cap such that if the
RTM or the deferrals proposed in the RTM would cause the Company to earn in excess
of its currentlyauthorized rate of return,then the amount either deferred or flowing
through the RTM would exclude the portion that would cause the Company to earn in
excess of its authorizedrate of return?If no,explain,in detail,why not.
Response to OCS Data Request 13.5
No.The Companybelieves that this would result in an asymmetrical earnings test
specifically targeted to keep equity earnings below currentlyauthorized returns without
the possibility of a similar opportunityto increase equity under-earnings up to the
currentlyauthorized return when so warranted.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.6
OCS Data Request 13.6
Refer to Exhibit RMP_(JRS-2SD),page 2,in this docket and Exhibit RMP (JRS-2SD)
in Docket No.17-035-39,both of which present "Example Annual RTM Deferral
Calculation -Revenue Requirement."Please provide a revised version of Exhibit
RMP_(JRS-2SD)that incorporates the impacts of both the Combined Projects at issue in
this case AND the Repowering Projects at issue in Docket No.17-035-39.
Response to OCS Data Request 13.6
Please refer to the submitted work paper files "17-035-39 RMP WP-Steward-Exhibits
2SD-4SD 2-1-18"and "17-035-40 RMP workpapers-Steward1-16-18",tab "JRS-2SS"
for an electronic spreadsheet version of the referred to "Example Annual RTM Deferral
Calculation -Revenue Requirement".These spreadsheets provide the information needed
to roduce the re uested revised version of Exhibit RMP 'JRS-2SD).
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.7
OCS Data Request 13.7
Refer to Exhibit RMP_(JRS-3SD)in this docket and Exhibit RMP_(JRS-3SD)in
Docket No.17-035-39,both of which present "Example Monthly RTM Deferral
Calculation -Revenue Requirement."Please provide a revised version of Exhibit
RMP (JRS-3SD)that incorporates the impacts of both the Repowering projects at issue
in Docket No.17-035-39 AND the Combined Projects at issue in this docket.
Response to OCS Data Request 13.7
Please refer to the submitted work paper files "17-035-39 RMP WP-Steward-Exhibits
2SD-4SD 2-1-18"and "17-035-40 RMP workpapers-Steward 1-16-18",tab "JRS-3SD"
for an electronic spreadsheet version of the referred to "Example Monthly RTM Deferral
Calculation -Revenue Requirement".These spreadsheets provide the information needed
to produce the requested revised version of Exhibit RMP_(JRS-3SD).
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.8
OCS Data Request 13.8
In the Supplemental Direct Testimony of Joelle R.Steward in Docket No.17-035-39,at
lines 106 -109,she states:"However,in light of the changes in the near-term rate
impacts due to tax reform,the Company proposes to separately defer the net costs in
excess of the cap associated with tax law changes,and seek recovery through an offset to
the deferral for the impacts from tax reform,pending in Docket No.17-035-69."Does
the Company intend to make a similar proposal in this docket?If so,indicate when the
Company intends to make a similar proposal in this proceeding.
Response to OCS Data Request 13.8
No.The RTM cap is only applied in Docket No.17-035-39 and not in Docket No.17-
035-40;therefore,making an additional adjustment for tax law changes in Docket No.
17-035-40 would not be warranted.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.9
OCS Data Request 13.9
What is the Company's current best estimate of when it will file its next general base rate
case proceedingin Utah,and what is the current best estimate of the base year and test
year that will be used in the filing?
Response to OCS Data Request 13.9
The specifics surrounding the next general rate case filing are still under consideration,
but the Company currentlyanticipates that it will file its next general base rate case
during calendar year 2020 with a 2021 test year.The base period that is to be used has
not yet been identified.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.10
OCS Data Request 13.10
Please provide all memos,analysis,evaluations,reports and studies prepared by the
Company from January 2017 to date regarding:(a)whether a general base rate case
should be filed in Utah;(b)timing of a general base rate case filing in Utah;and (c)the
base year and test year to be used in the next base rate case filing in Utah.
Response to OCS Data Request 13.10
The Company objects to the request on the basis that it seeks information that is not
relevant to and is not reasonablycalculated to lead to the discovery of admissible
evidence in the proceeding.The Company further objects to the extent the request seeks
information that is protected by the attorney-client privilege,the attorney work product
doctrine or both.Without waiving the objection,please see Attachment OCS 13.10 which
indicates the Company's expectations on the timing of prospective general rate cases.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.11
OCS Data Request 13.11
Please provide the most recent version of the Company's 5-year and 10-year strategic
plan in the most detailed format available.
Response to OCS Data Request 13.11
The most recent version of the Company's 5-year and 10-year strategic plan is highly
confidential and can be viewed on-site only.Please contact Jana Saba at [phone]
or Yvonne Hogle at [phone] to make arrangements for review.
17-035-39 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.15
OCS Data Request 13.12
Please provide a copy of the Company's budget and forecast for 2018 and each year
subsequent to 2018 for which budgets or forecasts have been prepared.Please provide on
a total Company basis and on a Utah jurisdictionalbasis if available.
Response to OCS Data Request 13.12
The Company's budget and forecast for 2018 and each year subsequent to 2018 for which
budgets or forecasts have been prepared are highly confidential and can be viewed on-site
only.Please contact Jana Saba at [phone] or Yvonne Hogle at [phone] to
make arrangements for review.
This Fall 2017 Plan Financial Summary and Assumptions Document ("Fall 2017 Plan")
is work product produced as part of the annual business plan process wherein PacifiCorp
reviews actual and forecast results and accomplishments for the current year (e.g.,2017)
and presents current projections for the subsequent 10-year period.This time consuming
and extensive annual process is unique to PacifiCorp and the other subsidiaries of
Berkshire Hathaway Energy (for the purpose of this notice,collectivelyreferred to as
"PacifiCorp").This annual process,includingthe substantial work product resulting
therefrom,confers a significant competitive advantage upon,and represents independent
economic value to PacifiCorp.The forecast and projections contained in the Fall 2017
Plan contain highly sensitive and uncertain assumptions,calculations and other
information ("Assumptions")based on a single snapshot in time.
The Fall 2017 Plan contains trade secrets or otherwise privileged and confidential
information owned by PacifiCorp.Access to the process used to prepare the 2017 Plan
and the substantial work product produced thereby,is strictly limited and controlled by
PacifiCorp.Such trade secrets may not be used or disclosed outside of PacifiCorp's
facilities except under appropriate precautions to maintain the confidentialityhereof,and
may not be copied,disseminated or otherwise used without the express permission of
PacifiCorp's general counsel.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.13
OCS Data Request 13.13
Please provide the 2017 annual operating and capital budget variance reports in the most
detailed format available.If the 2017 annual variance reports are not yet available,then
please provide the most recent monthlyreports available.
Response to OCS Data Request 13.13
Please refer to Confidential Attachment OCS 13.13 for the 2017 annual operating and
capital budget variance report in the most detailed format available.
Confidential information is provided subject to Public Service Commission of Utah Rule
746-1-602 and 746-1-603.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.14
OCS Data Request 13.14
Please provide a copy of the instructions provided to executives,managers and
employees for purposes of preparing the most recent budget and forecast in the most
detailed format available.
Response to OCS Data Request 13.14
Instructions provided to executives,managers and employees for purposes of preparing
the most recent budget and forecast do not exist.
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.15
OCS Data Request 13.15
With regards to the Board of Directors of the Company,PacifiCorp's parent company's,
and any affiliates of PacifiCorp,please provide the followinginformation:
(a)A copy of all presentations made to and reports provided to the Board of Directors
regarding the projects at issue in this docket;
(b)A copy of all presentations made to and reports provided to the Board of Directors
regarding the timing of general rate case filings in Utah over the period January 2016
to date;
(c)A copy of all presentations made to and reports provided to the Board of Directors
regarding the Resource Tracking Mechanism proposed by the Company in this docket
and Docket No.17-035-39.
(d)A copy of all presentations made to and reports provided to the Board of Directors
regarding PacifiCorp's projected earnings for 2018 and each subsequent year for
which such projections have provided to the Board of Directors.
(e)A copy of the section of the Board of Directors meeting minutes in which each of the
items in subparts (a)through (d)above was addressed.
Response to OCS Data Request 13.15
(a)-(d)No such presentations or reports were given to the boards of directors for
PacifiCorp or Berkshire Hathaway Energy.
(e)N/A
17-035-40 /Rocky Mountain Power
February 23,2018
OCS Data Request 13.16
OCS Data Request 13.16
Please provide the Company's projected rate of return on a total Company and on a Utah
jurisdictionalbasis for each year for which such projections have been made.If alternate
projections have been prepared under different scenarios,then please provide each of the
alternative projections and a description of each of the scenarios.Also please indicate the
assumptions included in such projections with regards to the following:
(a)Repowering projects at issue in Docket No.17-035-39;
(b)New wind/new transmission projects at issue in this docket;
(c)Timing of rate case proceedings in each jurisdiction and implementation date of new
rates from such proceedings;and
(d)Whether or not the proposed RTM mechanism is implemented.
Response to OCS Data Request 13.16
The Company objects to the entire request on the basis that it seeks information that is
not relevant to and is not reasonably calculated to lead to the discovery of admissible
evidence in the proceeding.The Company further objects to the extent the request seeks
information that is protected by the attorney-client privilege,the attorney work product
doctrine or both.Without waiving the objection,the Company states as follows:
(a)See the Company's response to OCS Data Request 13.18 in Docket No.17-035-39.
(b)See the general objection above.
(c)See the general objection above.
(d)See the general objection and subsection (a)above.