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Home My WebLink About20181015Monsanto 1-28 to PAC.pdfRandall C. Budge, ISB No. 1949 Thomas J. Budge, ISB No. 7465 RACINE, OLSON, NYE & BUDGE, CHARTERED P.O. Box l39l;201E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 rcb(nrracinelaw.nqt tjb(D,racinelaw.net Attorneys for Intervenor Monsanto Company BEFORE THE IDAHO PUBLIC UTILITIES COMI\{ISSION 'l_r\rrr.-rir' " I i-: !J l- I 1I i - rrLi,.i L-Ll Ijitfi:t lS FH Z:3t+ i:it.^.. ..!- i !/j .':lQCl.1 ! I,... ,;.uJ.Ul,i 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 MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER MONSANTO COMPANY, by and through their attorneys, hereby submits this First Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility Commission's Rules of Procedure, IDAPA 31.01.01. This Data Request is to be considered 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 the person preparing the documents. Please identift the name, job title, location and telephone number ofthe 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. MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - I Monsanto Set I Request No. 1: Please provide Gannett Fleming's most recent version of the database it maintains for the Service Life and Net Salvage Statistics by FERC Account, currently approved for U.S. Electric Utilities, in Microsoft Excel format. Request No. 2: Please provide all data utilized to create the original life tables presented in the depreciation study, as well as any applicable transaction or location code keys. Additionally, Please provide in Excel format or .csv format, the original life tables for all accounts presented in Part VII of the depreciation study filed as Exhibit No. 2. If not available in the requested format, Microsoft Word format will suffice. Request No. 3: Please provide all data utilized to create the summary of book salvage for all accounts presented in the depreciation study, as well as any applicable transaction or location code keys. Additionally, Please provide in Excel format or .csv format, the summary of book salvage tables for all accounts presented in Part VIII of the depreciation study filed as Exhibit No. 2. If not available in the requested format, Microsoft Word format will suffice. Request No. 4: Please provide in Excel format or .csv format, the calculation of remaining life depreciation accrual for all accounts presented in Part D( Detailed Depreciation Calculations of the depreciation study filed as Exhibit No. 2. If not available in the requested format, Microsoft Word format will suffice. Request No. 5: Please provide in Microsoft Excel format the currently approved Average Service Life/[owa Curve and net salvage rate for each account. Request No. 6: Please provide all correspondence between Gannett Fleming and Rocky Mountain Power as it pertains to the depreciation study filed as Exhibit No. 2. This includes all data requests from Gannett Fleming to RMP, all data responses from RMP to Gannett Fleming, all email correspondence, any and all phone call notes, any and all meeting notes, etc. Request No. 7: Please provide all notes, documents, and photographs that were created due to Mr. Spanos' or Gannett Fleming's site visits and company interviews that took place in preparation for the depreciation study filed as Exhibit No. 2. Request No. 8: For each FERC account studied in the depreciation study filed as Exhibit No. 2, please provide the current RMP accounting or capitalization policy for retirement pricing. In addition, please explain any and all changes to RMP's retirement pricing policies that have occurred since 1918. Request No. 9: For each FERC account studied in the depreciation study filed as Exhibit No. 2, please provide the current RMP accounting or capitalization policy that determines the retirement units. In addition, please explain any and all changes to RMP's retirement unit policies that have occurred since 1918. MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2 Request No. l0: For each FERC account studied in the depreciation study filed as Exhibit No. 2, please identify the retirement units based on RMP's current accounting or capitalization policy. Request No. 1l: For each FERC account studied in the depreciation study filed as Exhibit No. 2, please identi$ and explain all adjustments Mr. Spanos or Gannett Fleming made to RMP's accounting data prior to conducting the life and net salvage analyses that are presented in sections VII and VIII of the depreciation study filed as Exhibit No. 2. Request No. 12: Please provide a detailed narrative explaining the procedure used by Mr. Spanos or Gannett Fleming to estimate the interim retirements shown in column 8 of Mr. Spanos' workpaper titled, "PacifiCorp - 2020 Production Net Salvage - East Plants.xlsx." Request No. 13: Please provide in Excel format or .csv format, the calculation of remaining life depreciation accrual for all accounts similar to those presented in Parl IX Detailed Depreciation Calculations of the depreciation study filed as Exhibit No. 2, but for the RMP's proposed depreciation rates that are presented in the Appendix of the Exhibit No. 2. If not available in the requested format, Microsoft Word format will suffice. Request No. 14: Please provide all workpapers that support the estimated depreciation accruals, retirements, additions, gross salvage and cost of removal for the period between l2l3l/2017 and 1213112020. Please provide in Microsoft Excel format with all formulas and links intact. Request No. 15: Please provide a fully functional electronic workpaper, for each FERC account, that demonstrates the change to Book Depreciation Reserve, on a monthly basis, from the values shown in Mr. Spanos' workpaper titled "PacifiCorp - 2017 Depreciation Schedule - West Plants.xlsx" to the values shown in Mr. Spanos' workpaper titled "PacifiCorp - 2020 Depreciation Schedule - West Plants.xlsx." Request No. 16: Please provide a fully functional electronic workpaper, for each FERC account, that demonstrates the change to Original Cost, on a monthly basis, from the values shown in Mr. Spanos' workpaper titled "PacifiCorp - 2017 Depreciation Schedule - West Plants.xlsx" to the values shown in Mr. Spanos' workpaper titled "PacifiCorp - 2020 Depreciation Schedule - West Plants.xlsx." Request No. 17: For each FERC account studied in the depreciation study filed as Exhibit No. 2, please provide the results of all additional life analyses conducted by Mr. Spanos or Gannett Fleming. These additional analyses would be those conducted on original life tables that have experience and placement bands that differ from those presented in the depreciation study. Request No. 18: Referring to the interim net salvage rates for the production plants and the net salvage rates for the mass property accounts that RMP is proposing, please explain how MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 3 the labor expense associated with the cost of removal of these retirements would not already be recovered from RMP's customers through O&M expense recovered through RMP's tariffrates. Request No. 19: Referring to the interim net salvage rates for the production plants and the net salvage rates for the mass property accounts that RMP is proposing, please explain what actions RMP has taken in an attempt to minimize net salvage costs. Request No. 20: Referring to the interim net salvage analyses for the steam production accounts shown on pages VIII- l4 through VIII-23 of Exhibit No. 2, please explain if there are any costs included associated with any terminal retirement costs of the Carbon plant. Request No. 21 : For the coal plants RMP is proposing to retire early (Cholla 4, Jim Bridger I and2, Craig I andZ, and Colstrip 3 and 4), please provide a detailed narrative explaining why the interim retirement curves assumed for these plants should be the same as the coal plants that are not retiring early. Request No. 22: Please refer to Mr. Teply's testimony at page 9, lines 7-19. Please provide all supporting economic analyses, documents, studies, etc. that support RMP's decision to accelerate the retirement of Jim Bridger I and 2. For all Microsoft Excel files provided, please leave all formulas and links intact. Request No. 23: Please refer to Mr. Teply's testimony atpage 10, lines 3-9. Please provide all supporting economic analyses, documents, studies, etc. that support RMP's decision to accelerate the retirement of Craig Unit 2. For all Microsoft Excel files provided, please leave all formulas and links intact. Request No. 24: Please refer to Mr. Teply's testimony at page 10, lines 10-20. Please provide all supponing economic analyses, documents, studies, etc. that support RMP's decision to accelerate the retirement of Colstrip 3 and 4. For all Microsoft Excel files provided, please leave all formulas and links intact. Request No. 25: Please refer to Mr. Teply's testimony at page I l, lines 2l through page l2,line 2. Please provide a detailed narrative explaining what maintenance investments RMP is currently undertaking to extend the economic lives of its natural gas combined cycle plants past 40 years. Further, please explain when RMP expects technological advancements to become available that would extend the life of its natural gas combined cycle plants, and describe these technological advancements. Request No. 26: The following questions relate to RMP Exhibit No. 6 which shows the proposed decommissioning costs for each generating unit. a. Please identify the third-party that conducted these analyses MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4 b. Please provide any and all correspondence between RMP and this third-party, including all data requests, data responses, emails, meeting notes, memos, reports, etc. c. Please provide all studies, reports, and workpapers that support the costs shown in this exhibit. d. Please explain if any of the costs included in this exhibit are included in RMP's Asset Retirement Obligations, (ARO) for its coal plants. e. Please explain the level of site restoration that is included in these cost estimates. f. Please explain if RMP has any legal obligation to demolish the power plants and restore the sites consistent with assumptions used to determine these cost estimates. Request No. 27: Please refer to Mr. Hemstreet's testimony at page 7, lines 14-16. Please provide a detailed narrative explaining what uncertainty there is for the generation offtake and maintenance funding for RMP's wind assets that prevents RMP from proposing a life for wind assets longer than 40 years. Request No. 28: The following questions refer to RMP Exhibit No. 3. a. Please provide all workpapers, with formulas and links intact, which support the $3,214,547 of costs allocated to ldaho for the ending of excess reserye amortizations. b. Please provide all workpapers, with formulas and links intact, which support the $2,000,000 of costs allocated to Idaho for the incremental impact of the 2013 depreciation study not in rates. c. Please provide a version of this exhibit, in Microsoft Excel format, that shows the impact for the production, transmission, and distribution groups by FERC account, and if possible by generating unit. DATED this 15ft day of October, 2018. RACINE, OLSON, NYE & BUDGE, CHARTERED By: BUDGE c C MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 5 CERTIFICATB OF MAILING I HEREBY CERTIFY that on this 156 day of October, 2018, I caused to be served a true and correct copy of the foregoing document upon the following individuals in the manner indicated below: Yvonne R. Hogle Ted Weston Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 841l6 E-mail: wonne.ho gle(atpacificorp.com E-mail: ted. weston(g)paci fi com.com Rocky Mountain Power D. Matthew Moscon Lauren Shurman Stoel Rives, LLP 201 South State Street, Suite 1100 Salt Lake city, Utah 84111 Telephone: (801) 578-6985 Facsimile: (801 ) 578-6999 Email: rnatt.mclscon(r0stoel.com Email: lauren.shurman(lt)stoel.com Rocky Mountain Power Data Request Response Center Pacificorp 825 NE Multnomah, Suite 2000 Portland, OR97232 E-mail: datarequest(gpacillcorp.com Brubaker & Associates 16690 Swingley Ridge Road, #140 Chesterfield, MO 63017 E-Mail: mbrubaker(dconsultbai.com bco I I i ns (@ consultbai. com Monsanto Company Diane Hanian, Secretary Idaho Public Utilities Commission P.O. Box 83720 Boise,ID 83720-0074 E-mail: diane.hol t(atpuc. idaho. sov Commission Staff Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express f Electronic Transmission Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission I Electronic Transmission trtr Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission trtrtrnx ! Hand Delivery E US Mail (postage prepaid) Facsimile Transmission Federal Express I Electronic Transmission MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 6 Brandon Karpen Deputy Attorney General Idaho Public Utilities Commission 472 W . Washington (837 02) P.O. Box 83720 Boise, ldaho 837 20-007 4 Email: brandon.karpen(gtpuc. idaho. qov Commission Staff Ronald L. Williams Williams Bradbury, P.C. P.O. Box 388 Boise,Idaho 83701 Email: ron(rDwilliarnsbradburv.com PIIC Jim Duke Idahoan Foods 357 Constitution Way Idaho Falls, ID 83742 E-Mail: iduke(4 idahoan.com PtrC Kyle Williams BYU Idaho Email: williarnsk(@byui.edu PtrC Val Steiner Nu-West lndustries, lnc. Email: val.steiner(g2agrium.com PIIC Eric L. Olsen Echo Hawk & Olsen, PLLC P.O. Box 6119 505 Pershing Ave., Ste. 100 Pocatello, Idaho 83205 elo(gr.echohawk.com TIPA Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission I Uand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission ! Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission E Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission trx Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express I Electronic Transmission MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 7 Anthony Yankel 12700 Lake Avenue, Unit 2505 Lakewood, Ohio 44107 tony(0),ankel.net IIPA Hand Delivery US Mail (postage prepaid) Facsimile Transmission Federal Express Electronic Transmission RANDALL BUDGE TI TIx MONSANTO COMPANY'S FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 8