20180514PAC to Monsanto 1-4.pdf

Y ROCKY MOUNTAIN
POWER
A ilVISKIN OF
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RECEIVED
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1407 W No(h Temple, Suite 330
Sall Lake City, Utah 84116
May 14,2018
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE & BUDGE, CHARTERED
P.O. Box 1391;201 E. Center
Pocatello, Idaho $244-1391
[e-mail]
[e-mail]
Brubaker & Associates
16690 Swingley Ridge Rd #140
Chesterfield, MO 63017
[e-mail]
[e-mail]
RE:ID PAC.E.I8-OI
Monsanto I't Set f)ata Request (14)
Please find enclosed Rocky Mountain Power's Responses to Monsanto Dak Requests 1.1-1.4.
Also provided are Attachments Monsanto I .l -1, I .2, and 1.4. Confidential Attachment
Monsanto L l -2 will be provided upon receipt of signatory pages. Attachments to Monsanto 1.1
are requests tbr copies and are being provided to the requesting party only.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J.rrlwrro'u /o*,
J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Diane Haniar/tPUC [e-mail] (C)
PAC-E-I8-01 / Rocky Mountain Power
May 14,2018
Monsanto I st Set Data Request l.l
Monsanto Data Request l.l
Please provide copies of responses to all data requests (whether formal or
informal) that have been supplied to date and continue to do so when additional
information is supplied to other parlies. To the extent applicable, please provide
executable versions in native format rryith all formula intact, and include work
papers.
Response to Monsanto Data Request I.l
Please refer to Attachment Monsanto 1.1 - I and Con-fidential Attachment
Monsanto 1.1 -2.
Monsanto will be copied on all future responses in the other proceedings as
Supplemental Responses to this data request.
The Company does not waive any objections raised in the data request responses
included in the attachments.
Confidential information is provided subject to the terms and conditions of the
protective agreement in this proceeding.
Recordholder: Kaley McNay
Sponsor: Not applicable
PAC-E-I8-01 / Itocky Mountain Power
May 14,2018
Monsanto lst Set Data Request L2
Monsanto Data Request 1.2
In the previous II,CAM filing, Case No. PAC-E-17-02, RMP presented the results
of calculated ECAM rates under two scenarios: (i) without making a contribution
to the depreciation balance (Exhibit No. 3), and (ii) under the alternative rate plan
which provided $4 million towards the amortization of the deferred depreciation
balance (Exhibit No. 5). Please provide similar exhibits for this ECAM filing
under the two scenarios, that is, with and without making a $4 million
contribution to the depreciation balance,
Response to Monsanto Data Request 1.2
Please ref'er to Attachment Monsanto 1.2.
Recordholder: James Zhang
Sponsor: Robert Meredith
PAC-E-I8-01 I Rocky Mountain Power
May i4,2018
Monsanto I't Set Data Request 1.3
Monsanto Data Request 1.3
In the previous ECAM filing, Case No. PAC-E-17-02, RMP offered an
"altemative rate plan", however, it appears in this filing that RMP is not offering
an "alternative", but instead desires to maintain last year's "alternative rate plano'
in place for another year. Is it RMP's belief that the20lT "altemative rate plan"
agreed to by the parties and ordered by Commission was for more than a single
year? Please fully explain your responsc.
Response to Monsanto Data Request 1.3
It is the Company's position that the incremental $4 million referenced in the
"alternative rate plan" should be used to amortize the depreciation balance until
that balance is recovered. Llowever, as part of &e l'ax Reform stipulation parties
agreed to apply $3.5 million of tax savings to offset the estimated balance as of
May 31, 2018, which would enable a52.2 million reduction to the energy cost
adjustment mechanism (ECAM) rate with $1.8 million of the $4 million
continuing to be recovered through the ECAM to offset the ongoing depreciation
deferral.
Recordholder: Ted Weston
Sponsor: To Be Determined
PAC-E-I8-01 / Rocky Mountain Power
May 14,2018
Monsanto I't Set Data Request 1.4
Monsanto Data Request 1.4
Please provide all work papers identi{ying the inuemental changes to the
Commission approved depreciation deferral from January 2Al4 through
December 2018 (as estimated) showing amounts debited and credited to the
balance. Please provide work papers in Excel format with formulae inlact.
Response to Monsanto Data Request 1.4
Please refer to Attachment Monsanto 1.4.
Recordholder: Kent Ipson
Sponsor: To Be Determined