20180307PAC to Staff WY WIEC Set 15 (1).pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
February 9,2018
Abigail C.Briggerman,#7-5476
Holland &Hart LLP
6380 South Fiddlers Green Circle,Suite 500
Greenwood Village,CO 80111
[e-mail](C)
RE:Wyoming Docket 20000-520-EA-17
WIEC 15th Set Data Request (1)
Please find enclosed Rocky Mountain Power's Response to WIEC 15th Set Data Request 15.1.
Provided on the enclosed Confidential CD is Confidential Attachment WIEC 15.1.Confidential
information is provided subject to the terms and conditions of the protective agreement in this
proceeding.
If you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.C.:Meridith Bell/WPSC [e-mail](C)
Lori L.Brand/WPSC [e-mail] (W)
John Burbridge/WPSC [e-mail](W)
Michelle Bohanan/WPSC [e-mail] (W)
Kara Seveland/WPSC [e-mail](W)
Morgan Fish/WPSC [e-mail] (W)
Dave Walker/WPSC [e-mail] (W)
Perry McCollom/WPSC [e-mail](W)
Patti Penn/WIEC [e-mail](W)
Thor Nelson/WIEC [e-mail] (C)(W)
Emanuel Cocian/WIEC [e-mail] (W)
Adele Lee/WIEC [e-mail] (W)
Nik Stoffel/WIEC [e-mail] (C)(W)
Christopher Leger/OCA [e-mail] (C)
Crystal J.McDonough/[e-mail] (C)
Callie Capraro/NLRA [e-mail]
Lisa Tormoen Hickey/[e-mail] (C)
Brandon L.Jensen/RMSC [e-mail] (C)
Roxane Perruso/TOTCO [e-mail]
Jane M.France/TOTCO [e-mail] (C)
Constance E.Brooks/Anadarko [e-mail] (C)
Danielle Bettencourt/Anadarko [e-mail](C)(W)
Paul Kapp/Anadarko [e-mail] (C)
Lisa Christian/TOTCO [e-mail] (C)
J.Kenneth Barbe/[e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 15.1
WIEC Data Request 15.1
Please refer to "Table 2-SD,Table 3-SD,Figure 5 FSL Results Summary File",Exhibit 5
tab,and "JRS Exhibits 2SD-4SD Combined Projects WY 1.16.18 Work Papers".|
(a)Please reconcile the annual Capital Recovery -Wind amounts provided on the
Exhibit 5 tab of "Table 2-SD,Table 3-SD,Figure 5 FSL Results Summary File"with
the amounts provided on the JRS-3SD (Wind)tab of "JRS Exhibits 2SD-4SD
Combined Projects WY 1.16.18 Work Papers."For example,the former states that
2020 Capital Recovery -Wind is $25.382 million,while the latter indicates that the
2020 pre-tax return on rate base is $9.662 million and 2020 depreciation expense is
$7.531 million (for a total of $17.193 million).Why aren't the annual wind capital
costs provided in Exhibit 5 (RTL-5SD)and the JRS-3SD (Wind)tab the same?
(b)Were the Capital Recovery -Wind amounts provided on the Exhibit 5 tab (RTL-
5SD)derived from rate base amounts that are consistent with those provided on the
"Rate Base for Exh RTL-5 (Wind)"tab of "JRS Exhibits 2SD-4SD Combined
Projects WY 1.16.18 Work Papers"?If so,please demonstrate how the annual
Capital Recovery -Wind amounts from Exhibit 5 are derived from the rate base
amounts on the "Rate Base for Exh RTL-5 (Wind)"tab,using an Excel format work
paper.If not,please explain why the basis for the Capital Recovery -Wind amounts
in Exhibit 5 differs from the rate base amounts on the "Rate Base for Exh RTL-5
(Wind)"tab.
(c)Please provide a breakdown,in Excel format,of the annual dollar amounts of each
cost category included in the Capital Recovery -Wind amounts provided on the
Exhibit 5 tab (RTL-5SD)of "Table 2-SD,Table 3-SD,Figure 5 FSL Results
Summary File."For example,please provide the annual net rate base,return on rate
base,depreciation expense,taxes,and any other category of costs included in the
Capital Recovery -Wind amounts.
(d)Please reconcile the annual the Transmission Project Capital Recovery amounts
provided on the Exhibit 5 tab of "Table 2-SD,Table 3-SD,Figure 5 FSL Results
Summary File"with the amounts provided on the JRS-3SD (Trans)tab of "JRS
Exhibits 2SD-4SD Combined Projects WY 1.16.18 Work Papers."For example,the
former states that 2020 Transmission Project Capital Recovery is $11.721 million,
while the latter indicates that the 2020 pre-tax return on rate base is $5.015 million
and 2020 depreciation expense is $2.071 million (for total of $7.086 million).Why
aren't the annual transmission capital costs provided in Exhibit 5 (RTL-5SD)and the
JRS-3SD (Trans)tab the same?
(e)Were the Transmission Project Capital Recovery amounts provided on the Exhibit 5
tab (RTL-5SD)derived from rate base amounts that are consistent with those
provided on the "Rate Base for Exh RTL-5 (Trans)"tab of "JRS Exhibits 2SD-4SD
Combined Projects WY 1.16.18 Work Papers"?If so,please demonstrate how the
annual Transmission Project Capital Recovery amounts from Exhibit 5 are derived
from the rate base amounts on the "Rate Base for Exh RTL-5 (Trans)"tab,using an
Excel format work paper.If not,please explain why the basis for the Transmission
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 15.1
Project Capital Recovery amounts in Exhibit 5 differs from the rate base amounts on
the Rate Base for Exh RTL-5 (Trans)"tab.
(f)Please provide a breakdown,in Excel format,of the annual dollar amounts of each
cost category included in the Transmission Project Capital Recovery amounts
provided on the Exhibit 5 tab (RTL-5SD)of "Table 2-SD,Table 3-SD,Figure 5 FSL
Results Summary File."For example,please provide the annual net rate base,return
on rate base,depreciation expense,taxes,and any other category of costs included in
the Transmission Project Capital Recovery amounts.
(g)Is the capital cost component included in the Network -Wind amounts provided on
the Exhibit 5 tab (RTL-5SD)derived from rate base amounts that are consistent with
those provided on the "Rate Base for Network Upgrades"tab of "JRS Exhibits 2SD-
4SD Combined Projects WY 1.16.18 Work Papers"?If so,please demonstrate how
the annual capital cost component included in the Network -Wind amounts are
derived from the rate base amounts on the "Rate Base for Network Upgrades"tab,
using an Excel format work paper.If not,please explain why the basis for the capital
cost component included in the Network -Wind amounts in Exhibit 5 (RTL-5SD)
differs from the rate base amounts on the "Rate Base for Network Upgrades"tab.
(h)Please provide a breakdown,in Excel format,of the annual dollar amounts of each
cost category included in the Network -Wind amounts provided on the Exhibit 5 tab
of "Table 2-SD,Table 3-SD,Figure 5 FSL Results Summary File."For example,
please provide the annual net rate base,return on rate base,depreciation expense,
taxes,and any other category of costs included in the Network -Wind amounts.
Response to WIEC Data Request 15.1
(a)The annual Capital Recovery-Wind amounts provided on the "Exhibit 5"tab of the
confidential work paper "Table 2-SD,Table 3-SD,Figure 5 FSL Results Summary
File"provided with the supplemental direct testimony of Company witness,Rick T.
Link were calculated as follows:
i.13-month average rate base.
ii.Total Company pre-tax rate of return of 9.168 percent.
iii.Property taxes of 0.75 percent of rate base;that is,original cost less
accumulated depreciation and accumulated deferred income tax (ADIT).
The amounts provided on the "JRS-3SD (Wind)"tab of the non-confidential work
paper "JRS Exhibits 2SD-4SD Combined Projects WY 1.16.18 Work Papers"
provided with the supplemental direct testimony of Company witness,Joelle R.
Steward were calculated as follows:
i.Monthly calculation based on the prior month ending rate base.
ii.Wyoming pre-tax rate of return of 9.001 percent based on the approved capital
structure and cost from Docket 20000-469-ER-15.
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 15.1
iii.Property taxes of 0.77 percent of net book value (NBV);that is,original cost
less accumulated depreciation.
(b)The Capital Recovery -Wind amounts provided in Exhibit RMP_(RTL-5SD)were
derived from the same rate base amounts with those provided on the "Rate Base for
Exh RTL-5 (Wind)"tab of the non-confidential work paper "JRS Exhibits 2SD-4SD
Combined Projects WY 1.16.18 Work Papers".The calculated amounts are different
for the reasons stated in the Company's response to subpart (a)above.
(c)Due to the ongoing nature of the 2017R Request for Proposals (2017R RFP),the final
shortlist (FSL)financial models containing the requested information associated with
the 2017R RFP are considered commercially sensitive and highly confidential.The
Company does not typically permit access to commercially sensitive 2017R RFP
documentation until the RFP has been concluded.Please contact Stacy Splittstoesser
at [phone] or Yvonne Hogle at [phone] to make arrangements for
review.
(d)The Transmission Project Capital Recovery amounts provided on the "Exhibit 5"tab
of the confidential work paper "Table 2-SD,Table 3-SD,Figure 5 FSL Results
Summary File"were calculated as follows:
i.13-month average rate base.
ii.Total company pre-tax rate of return of 9.168 percent.
iii.Property taxes of 0.75 percent of rate base.
The amounts provided on the "JRS-3SD (Trans)"tab of the non-confidential work
paper "JRS Exhibits 2SD-4SD Combined Projects WY 1.16.18 Work Papers"were
calculated as follows:
i.Monthly calculation based on the prior month ending rate base.
ii.Wyoming pre-tax rate of return of 9.001 percent based on the approved capital
structure and cost from Docket 20000-469-ER-15.
iii.Property taxes of 0.77 percent of NBV.
(e)The Transmission Project Capital Recovery amounts provided in Exhibit
RMP RTL-5SD)were derived from the same rate base amounts with those
proviÌd on the "Rate Base for Exh RTL-5 (Trans)"tab of the non-confidential work
paper "JRS Exhibits 2SD-4SD Combined Projects WY 1.16.18 Work Papers".The
calculated amounts are different for the reasons stated in the Company's response to
subpart (d)above.
(f)Please refer to Confidential Attachment WIEC 15.1,which provides a breakdown of
each cost category included in the Transmission Project Capital Recovery amounts
provided in Exhibit RMP (RTL-5SD),specifically the "Generic"tab,rows 1691
through 1711.
(g)The Network Wind amounts provided in Exhibit RMP_(RTL-5SD)were derived
from the same rate base amounts with those provided on the "Rate Base for Network
20000-520-EA-17 /Rocky Mountain Power
February 9,2018
WIEC Data Request 15.1
Upgrades"tab of "JRS Exhibits 2SD-4SD Combined Projects WY 1.16.18 Work
Papers".
The Network Wind amounts provided on the "Exhibit 5"tab of "Table 2-SD,Table
3-SD,Figure 5 FSL Results Summary File"were calculated as follows:
i.13-month average rate base.
ii.Total company pre-tax rate of return of 9.168 percent.
iii.Property taxes of 0.75 percent of rate base.
The amounts provided on the "JRS-3SD (Network)"tab of "JRS Exhibits 2SD-4SD
Combined Projects WY 1.16.18 Work Papers"were calculated as follows:
i.Monthly calculation based on the prior month ending rate base.
ii.Wyoming pre-tax rate of return of 9.001 percent based on the approved capital
structure and cost from Docket 20000-469-ER-15.
iii.Property taxes of 0.77 percent of NBV.
(h)Due to the ongoing nature of the 2017R Request for Proposals (2017R RFP),the final
shortlist (FSL)financial models containing the requested information associated with
the 2017R RFP are considered commercially sensitive and highly confidential.The
Company does not typically permit access to commercially sensitive 2017R RFP
documentation until the RFP has been concluded.Please contact Stacy Splittstoesser
at [phone] or Yvonne Hogle at [phone] to make arrangements for
review.
Confidential information is provided subject to the protective order issued in this
proceeding.
Respondent:Ron Scheirer /Mark Paul /Craig Stelter
Witness:Rick Link