20181031Staff 1-11 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t4
IDAHO BAR NO. 10446
F"ECEIVED
::tXllfl'1I 3l Pt{ 2: 35
', r'r, i ,j.'-rjtstct't
Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORIZATION TO CHANGE
DEPRECIATION RATES APPLICABLE TO
ELECTRIC PROPERTY.
CASE NO. PAC.E.18.O8
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
NOVEMBER 21,2018.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
)
)
)
)
)
)
)
)
)
I ocroBER 31,2018
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Regarding the Cholla Unit 4 plant, please provide the following:
a. The annual revenue requirement impact for each year on a non-levelized basis,
starting in 2019 , of accelerating the depreciable life of Cholla Unit 4 from 2042 to
2025.
b. The revenue requirement impact on a levelized basis and provide the range of
years to which the levelized result applies.
c. The annual revenue requirement calculations for the two end of life cases (2042
and2025). This detail should include the estimated annual revenue requirement
by year and the levelized revenue requirement (where the range of years is
specified).
REQUEST NO. 2: Regarding the Jim Bridger Unit 1 plant, please provide the
following:
a. The annual revenue requirement impact for each year on a non-levelized basis,
starting in20l9, of accelerating the depreciable life of Jim Bridger Unit I from
2037 to2028.
b. The revenue requirement impact on a levelized basis and provide the range of
years to which the levelized result applies.
c. The annual revenue requirement calculations for the two end of life cases (2037
and2028). This detail should include the estimated annual revenue requirement
by year and the levelized revenue requirement (where the range of years is
specified).
FIRST PRODUCTION REQUEST
TO ROCKY MOLiNTAIN POWER 2 ocroBER 31,2018
REQUEST NO.3: Regarding the Jim Bridger Unit2 plant, please provide the
following:
a. The annual revenue requirement impact for each year on a non-levelized basis,
starting in2019, of accelerating the depreciable life of Jim Bridger Unit 2 from
2037 to2032.
b. The revenue requirement impact on a levelized basis and provide the range of
years to which the levelized result applies.
c. The annual revenue requirement calculations for the two end of life cases (2037
and2032). This detail should include the estimated annual revenue requirement
by year and the levelized revenue requirement (where the range of years is
specified).
REQUEST NO. 4: Regarding the Craig Unit 1 plant, please provide the following:
a. The annual revenue requirement impact for each year on a non-levelized basis,
starting in2019, of accelerating the depreciable life of Craig Plant Unit from 2034
to 2025,
b. The revenue requirement impact on a levelized basis and provide the range of
years to which the levelized result applies.
c. The annual revenue requirement calculations for the two end of life cases (2034
and2025). This detail should include the estimated annual revenue requirement
by year and the levelized revenue requirement (where the range of years is
specified).
REQUEST NO. 5: Regarding the Craig Unit2 plant, please provide the following:
a. The annual revenue requirement impact for each year on a non-levelized basis,
starting in2019, of accelerating the depreciable life of Craig Plant Unit 2 from
2034 to 2026.
b. The revenue requirement impact on a levelized basis and provide the range of
years to which the levelized result applies.
c. The annual revenue requirement calculations for the two end of life cases (2034
and2026). This detail should include the estimated annual revenue requirement
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 1J ocToBER 31,2018
by year and the levelized revenue requirement (where the range of years is
specified).
REQUEST NO. 6: Regarding the Colstrip Unit 3 plant, please provide the following:
a. The annual revenue requirement impact for each year on a non-levelized basis,
starting in2019, of accelerating the depreciable life of Colstrip Unit 3 from2046
to 2027.
b. The revenue requirement impact on a levelized basis and provide the range of
years to which the levelized result applies.
c. The annual revenue requirement calculations for the two end of life cases (2046
and2027). This detail should include the estimated annual revenue requirement
by year and the levelized revenue requirement (where the range of years is
specified).
REQUEST NO. 7: Regarding the Colstrip Unit 4 plant, please provide the following:
a. The annual revenue requirement impact for each year on a non-levelized basis,
starting in2019, of accelerating the depreciable life of Colstrip Unit 4 from2046
to2027.
b. The revenue requirement impact on a levelized basis and provide the range of
years to which the levelized result applies.
c. The annual revenue requirement calculations for the two end of life cases (2046
and2027). This detail should include the estimated annual revenue requirement
by year and the levelized revenue requirement (where the range of years is
specified).
REQUEST NO. 8: Please provide a detailed list of all capital improvements added for
each steam production plant from 2013 to 2018. Please also provide a list of any additional
improvements planned to be added from now until2020 for each plant.
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 4 ocroBER 31,2018
REQUEST NO. 9: Please provide all journal entries made to the 2013 depreciation
regulatory asset between January 1,2016 and October 1,2018. Please provide additional entries
each month as they occur.
REQUEST NO. 10: For each Colstrip Unit, please provide the total "original cost"
values of the Colstrip Generating Station identified on page VI-4, column 5 of the Gannett
Fleming Depreciation Study dated December 17 ,2017 and a breakdown of this value for each
operating partner.
REQUEST NO. 1l: For each Colstrip Unit, please provide details of any "Asset
Retirement Obligation"(ARo) associated with the closure of the plant. Details should include:
a. a description of the ARO;
b. the legal obligation or reason why the ARO was initiated;
c. calculations supporting the ARO amount; and
d. the FERC account associated with the ARO.
DATED at Boise, Idaho, this 3(tY day of October 2018.
Deputy General
i:umisc:prodreq/pace I 8.8ejbebl prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER
Ed
5 ocToBER 31,2018
Technical Staff: Bentley Erdwurm (1-7)
Brad Iverson-Long (8-9)
Rick Keller (10-11)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31't DAY OF OCTOBER 2018,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-I8-08, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
YVONNE R HOGLE
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I I6
E-MAIL : Ivonne.ho gle@pacif-rcorp. com
ted. weston@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@paci fi corp. com
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON PLLP
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
tjb@,racinelaw.net
ERIC L OLSEN
ECHO HAWK & OLSEN
PO BOX 6119
POCATELLO ID 83205
E-MAIL: elo@.echohawk.com
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-MAIL : [e-mail]
ELECTRONIC ONLY
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
D MATTHEW MOSCON
LAUREN SHURMAN
STOEL RIVES LLP
201 S MAIN ST STE 11OO
SALT LAKE CITY UT 84I11
E-MAIL: matt.moscon@,stoel.com
lauren. shurman@stoel. com
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#t40
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
[e-mail]
ANTHONY YANKEL
LrNIT 2505
I2]OO LAKE AVENUE
LAKEWOOD OH 44107
E-MAIL: [e-mail]
ELECTRONIC ONLY
JIM DUKE
IDAHOAN FOODS
E-MAIL: [e-mail]
ELECTRONIC ONLY
VAL STEINER
NU-WEST INDUSTRIES INC
E-MAIL : val. steiner(@itafos.eem
CERTIFICATE OF SERVICE
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE TD 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE