20181105PAC to Monsanto 1-28.pdf

ROCKY MOUNTAIN
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
November 5,2018
Randall 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- I 391
[e-mail]
[e-mail]
RE: ID PAC-E-18-08
Monsanto I't Set Data Request (l-28)
Please find enclosed Rocky Mountain Power's Responses to Monsanto 1tt Set Data Requests I .1-
1 ,28, excluding Monsanto 1.6 and 1.26. These responses will be provided separately. AIso
provided are Attachments Monsanto 1, 2, 3, 4, 5, 7, 9, lA, I 1, I 3, 14, 17, and 28.
If you have any questions, please feel free to call me at [phone].
Sincerely,
Enclosures
C.c.: Diane Hanian/IPUC [e-mail] (C)
Jim Duke/PIIC i [e-mail]
Kyle Williams/PIIC williamsk@byui,edu
Val Steiner/PIIC [e-mail]
Maurice Brubaker/Ivlonsanto [e-mail]
Katie Iverson/Monsanto [e-mail]
B en Otto/ICL [e-mail]
Eric Olsen/IIPA elo@.echohawk. com
Anthony Yankel/IIPA [e-mail]
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Jfal,urtulh,
J. Ted Weston
Manager, Regulation
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto 1't Set Data Request I
Monsanto Data Request I
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.
Response to Monsanto Data Request I
Please refer to Attachment Monsanto I to this response. Gannett Fleming does
not maintain a database of currently approved service life and net salvage
estimates. lnstead, Gannett Fleming maintains a database of estimates from
depreciation studies performed by Gannett Fleming.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto I't Set Data Request 2
Monsanto Data Request 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.
Response to Monsanto Data Request 2
Please refer to Attachments Monsanto 2-1 through Monsanto 2-6 to this response
for the requested information.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto 1s Set Data Request 3
Monsanto Data Request 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.
Response to Monsanto Data Request 3
Please refer to Attachments Monsanto 3-1 through Monsanto 3-4 to this response
for the requested information. A description of transaction codes has been
provided in Attachment Monsanto 2-5 of the response to Monsanto Data Request
2^
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-18-08 / Rocky Mountain Power
November 5,2018
Monsanto I't Set Data Request 4
Monsanto Data Request 4
Please provide in Excel format or.csv format, the calculation of remaining life
depreciation accrual for all accounts presented in Part IX Detailed Depreciation
Calculations of the depreciation study filed as Exhibit No. 2. If not available in
the requested format, Microsoft Word format will suffice.
Response to Monsanto Data Request 4
Please refer to Attachments Monsanto 4-1 and Monsanto 4-2 to this response for
the requested information.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto l't Set Data Request 5
Monsanto Data Request 5
Please provide in Microsoft Excel format the currently approved Average Service
Life/Iowa Curve and net salvage rate for each account.
Response to Monsanto Data Request 5
Please refer to Attachment Monsanto 5-1 for the 2Al7 Comparison Schedule and
Attachment Monsanto 5-2 for the 2020 Comparison Schedule to this response for
the requested information.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-18-08 / Rocky Mountain Power
November 5,2018
Monsanto l't Set Data Request 7
Monsanto Data Request 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.
Response to Monsanto Data Request 7
Please refer to the Attachments Monsanto 7-1 and Monsanto 7-2.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto I't Set Data Request 8
Monsanto Data Request 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 retirernent
pricing. In addition, please explain any and all changes to RMP's retirement
pricing policies that have occurred since 1918.
Response to Monsanto Data Request 8
PacifiCorp recognizes the FERC Code of Federal Regulations (CFR) as the
authority regarding the retirement of assets and RMP's formal policy follows the
precepts outlined in the CFR. The retirement of assets must meet the criteria
listed within the policy. Please refer to Attach Monsanto 9 for the policy
regarding plant removal guidelines in section six. PacifiCorp does not retain past
written policies since they adhere with the FERC CFR. There have been no
changes to those policies since the last depreciation study.
Recordholder: Dean Wirick
Sponsor: Nikki Kobliha
Monsanto Data Request 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.
PacifiCorp recognizes the FERC Code of Federal Regulations (CFR) as the
authority regarding the capitalization policy and RMP's formal policy follows the
precepts outlined in the CFR. Retirement units must meet the criteria listed
within the policy, Please refer to Attachment Monsanto 9 for the policy regarding
retirement units. PacifiCorp does not retain past written policies since they
adhere with the FERC CFR. There have been no changes to those policies since
the last depreciation study.
Recordholder: Dean Wirick
Sponsor: Nikki Kobliha
PAC-E-I8-08 / Rocky Mountain Power
November 5,2018
Monsanto I't Set Data Request 9
Response to Monsanto Data Request 9
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto lst Set Data Request 10
Monsanto Data Request 10
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.
Response to Monsanto Data Request 10
Please refer to Attachment Monsanto l0 for the current list of Property
Retirement Units (PRU's). The PRU's are not necessarily attached as a one-to-
one relationship with the FERC plant accounts. Many can be used in multiple
functional accounts while others are obviously used for certain functions. The
primary criteria for capitalization is the asset meeting the definition of an asset as
per FERC and PacifiCorp's capitalization policy.
Recordholder: Dean Wirick
Sponsor: Nikki Kobliha
PAC-E-I8-08 / Rocky Mountain Power
November 5,2018
Monsanto 1't Set Data Request 1l
Monsanto Data Request 11
For each FERC account studied in the depreciation study filed as Exhibit No. 2,
please identify and explain all adjustments Mr. Spanos or Cannett 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.
Response to Monsanto Data Request 11
Please refer to Attachments Monsanto 1l-1, Monsanto 11-2, Monsanto I l-3 and
Monsanto I l-4 to this response for the data used to compile the "Summary of
Book Salvage" pages filed in the Depreciation Study. Data for years prior to
2012 is the same as in the previous study unless otherwise noted.
Please see below for a summary of each transaction code in these files.
Transaction codes 5, 6, 8 and 9 were excluded from the net salvage analysis.
Additionally, the transactions in the "Other" column were excluded from the net
salvage analysis. These transactions include adjustments to the reserve, including
recoveries from insurance, net book value transferred to/from account 102 - plant
purchased and sold, and the reallocation ofreserves.
The type codes in the attached file are as follows:
I - normal salvage and removal activity
2 - retirement adjustments - such as balances remaining without
quantities
4 - relocation due to highway construction or customer requests
5 - sale of company property
6 - recovery for damage to company property
7 - Asset Retirement Obligation costs spent (for tracking purposes
only - treat as type I )
8 - reserve adjustments, insurance proceeds, etc. (potential
exclusion for net salvage analysis)
9 - hydro decommissioning and/or terminal plant removal
P - estimated retirements - specific asset not yet identified
Additional transactions recorded since the previous depreciation study that were
not included in the net salvage analysis are provided in Attachments Monsanto
1l-5 and Monsanto 1l-6 this response.
Attachment Monsanto I l-7 to this data request includes the historical retirement
values as recorded by the Company used in the service life analysis Attachment
Monsanto 1l-9 is an explanation of the layout of the files showing the memo and
type codes used to describe the data. The table below indicates which codes were
PAC-E-18-08 / Rocky Mountain Power
November 5, 2018
Monsanto l't Set Data Request l1
Memo
A
C
E
M
P
S
Recordholder: John Spanos
Sponsor: John Spanos
included and which codes were excluded as retirements in the development of the
Retirement amounts. For transactions since the previous depreciation study,
additional transactions that were not included as retirements are provided in
Attachment Monsanto 11-8 to this response.
Include/Exclude
Excluded
Included
Included
Included
Included
Excluded
PAC-E-18-08 / Rocky Mountain Power
November 5,2018
Monsanto 1'r Set Data Request 12
Monsanto Data Request 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."
Response to Monsanto Data Request L2
The interim retirements in column (8) were calculated using Gannett Fleming's
depreciation software based on the current plant balances, estimated interim
survivor curves until the estimated retirement dates of each facility from the
depreciation study. The interim retirements represent the portion of current plant
in service forecast to retire prior to the estimated retirement date based on the
estimated interim survivor curves. There are no specific workpapers for these
calculations, as they were performed with computer software based on the
retirement and survivor ratios from the estimated interim survivor curves.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-18-08 / Rocky Mountain Power
November 5, 2018
Monsanto I't Set Data Request 13
Monsanto Data Request 13
Please provide in Excel format or .csv format, the calculation of remaining life
depreciation accrual for all accounts similar to those presented in Part 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.
Response to Monsanto Data Request 13
Please refer to Attachments Monsanto 13-l and Monsanto 13-2 for the requested
calculations. These calculations are provided in native MS Word format.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5,2018
Monsanto 1'r Set Data Request 14
Monsanto Data Request 14
Please provide all workpapers that support the estimated depreciation accruals,
retirements, additions, gross salvage and cost of removal for the period between
1213112017 and 1213112020. Please provide in Microsoft Excel format with all
formulas and links intact.
Response to Monsanto Data Request 14
Please refer to Attachments Monsanto 14-1 through Monsanto l4-6 for the
requested information.
Recordholder: John Spanos
Sponsor: Johl Spanos
PAC-E-18-08 / Rocky Mountain Power
November 5, 2018
Monsanto I't Set Data Request l5
Monsanto Data Request 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."
Response to Monsanto Data Request 15
Please refer to Attachments Monsanto 14-1 and Monsanto 14-2 of the response to
Monsanto Data Request 14. The changes to the book depreciation reserve for the
years 2018 through 2020 were calculated on an annual basis, not a monthly basis.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5,2018
Monsanto 1't Set Data Request 16
Monsanto Data Request 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."
Response to Monsanto Data Request 16
Please refer to Attachments Monsanto 14-l and Monsanto l4-2 of the response to
Monsanto Data Request 14. The changes to the original cost for the years 2018
through 2020 were calculated on an annual basis, not a monthly basis.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-18-08 / Rocky Mountain Power
November 5, 2018
Monsanto l't Set Data Request 17
Monsanto Data Request 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.
Response to Monsanto Data Request 17
Please refer to Attachments Monsanto I 7- 1 and Monsanto 17 -2 to this response,
which provide the original life tables analyzed as well as preliminary
mathematical curve fitting results for each life table. Please note that these are
only the preliminary curve fitting results. Additional visual and mathematical
curve matching was performed using Gannett Fleming's depreciation software.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto l't Set Data Request 18
Monsanto Data Request 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 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.
Response to Monsanto Data Request 18
Historically, labor associated with the retirement and removal of any production
plant and mass property assets is not included in O&M labor that is recovered
through RMP's tariff rates. Labor associated with the retirement and removal of
assets would be capitalized and recovered through depreciation expense.
Recordholder: Nick Highsmith
Sponsor: Steve McDougal
PAC-E-18-08 / Rocky Mountain Power
November 5, 2018
Monsanto I'r Set Data Request 19
Monsanto Data Request 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.
Response to Monsanto Data Request 19
To minimize net salvage costs, PacifiCorp typically issues requests for proposals
(RFP) for interim net salvage or retirement projects of significant scope that are
not otherwise completed by internal labor utilizing local waste management /
scrap services. ln either case, any salvageable parts or commodities that can be
sold as scrap contribute to reducing costs of the retirement and removal activity.
Recordholder: Kent Ipson for net salvage rates for production plants, procurement
records from ARIBA is held by procurement, Joe Hickey's team
Sponsor: Dana Ralston / Chad Teply
PAC-E-18-08 / Rocky Mountain Power
November 5,2018
Monsanto 1't Set Data Request 20
Monsanto Data Request 20
Refening to the interim net salvage analyses for the steam production accounts
shown on pages VIII-14 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.
Response to Monsanto Data Request 20
Costs associated with the terminal retirement of the Carbon plant as recorded on
the Company's books were excluded from the net salvage analysis shown on
pages VIII-14 through VIII-23 of Exhibit No.2.
Recordholder: John Spanos
Sponsor: John Spanos
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto I't Set Data Request 2l
Monsanto Data Request 21
For the coal plants RMP is proposing to retire early (Cholla 4, Jim Bridger 1 and
2, Craig I and 2, 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.
Response to Monsanto Data Request 21
The interim survivor curves were developed at the account level for each steam
plant account and apply to each generating station in the steam production
function. Because the life span method is used and because the interim survivor
curves reflect the expected interim retirements by age, the overall level of interim
retirements in a given year for each interim survivor curve is a function of the age
of the assets at each facility. The total level of interim retirements forecast by the
survivor curve is a function of both the interim survivor curve and the age at
which the estimated final retirement will occur. The use of truncated interim
survivor curves provides a consistent method of estimating interim retirements
that takes into account when the final retirement of each facility is expected to
occur.
Recordholden John Spanos
Sponsor: John Spanos
PAC-E-18-08 / Rocky Mountain Power
November 5, 2018
Monsanto l't Set Data Request 22
Monsanto Data Request 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 1 and 2. For all Microsoft
Excel files provided, please leave all formulas and links intact.
Response to Monsanto Data Request 22
PacifiCorp has not made a final determination to accelerate the retirement of Jim
Bridger Units 1 and2. As described in testimony, Jim Bridger Unit 1 and Jim
Bridger Unit 2 are required by the United States (U.S.) Environmental Protection
Agency (EPA), Wyoming Regional Haze State Implementation Plan (SIP), to
install a selective catalytic reduction (SCR) system by December 31, 2022 and
December 3 l, 2021, respectively. For both the 2017 lntegrated Resource Plan
(lRP) and the20l7 IRP Update, PacifiCorp performed an analysis of the
implementation of the SCRs on both units assuming original retirement at the end
of depreciable life in2037 against potential early retirement of the units in 2028
and2032, respectively, assuming PacifiCorp could successfully negotiate a
Regional Haze compliance altemative to avoid installation of the SCRs on the two
units in exchange for a date-certain commitment to remove the resource from
coal-fueled service. The installation of SCRs on the units in 2022 and 2021 to
enable compliance to the Wyoming Regional Haze SIP and allow the units to
operate through 2Q37 has been assessed to result in higher costs to customers
versus the removal of the units from coal-fueled service in2028 and2032.
Please refer to the latest analysis results and discussion in the 2017 IRP Update
(page 73 through 75), The 2017 IRP Update is publicly available and can be
accessed by utilizing the following website link:
http://www.pacificorp.coln/lontent/dam/pacificorp/doc/Energy Sources/InteBrate
d-Resource-Plan/20 I 7%20IRP%20Update/20 I 7-IRP-Uodate.pdf
Recordholder: Irene Heng /lRP - Shay LaBray
Sponsor: Chad Teply / Rick Link
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto l't Set Data Request 23
Monsanto Data Request 23
Please refer to Mr. Teply's testimony at page 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.
Response to Monsanto Data Request 23
PacifiCorp has not made a final determination to accelerate the retirement of
Craig Unit 2. As described in testimony, the joint-owners of Craig Unit I reached
a settlement with environmental stakeholders, the Colorado Department of Public
Health and Environment, and the United States (U.S.) Environmental Protection
Agency (EPA) in December 2016. The settlement was approved effective August
6,2018, by the EPA to retire Craig Unit I at the end of Decernber 37,2025, or
otherwise convert the unit to a natural gas-fueled resource. Please refer to
hyperlink to Federal Register in reference to the EPA approval and effective date
for Craig Unit 1:
https://www. qpo. gov/fdsys/pkg/FR-20 I 8-07-05/pdfl20 1 8- I 43 87.pdf
Once Craig Unit I is retired or converted, Craig Unit 2 will have to bear a higher
percentage share of common costs incurred at Craig Generation Station, as well as
any associated fuel cost ramifications, that will be passed on to PacifiCorp as a
joint-owner. Accelerating the depreciable life of Craig Unit 2 from 2034 to 2026
will facilitate PacifiCorp's ability to plan for potential early retirement of the unit
in support of least-cost, least risk planning and decision making for the benefit of
customers. This approach positions PacifiCorp to respond in timely fashion to the
potential decisions of the other joint owners of the unit during the period of time
in and around retirement or conversion of Craig Unit 1. The supporting economic
analysis, documents, and studies associated with any final decision-making will
be developed contemporaneously.
Recordholder: Kent Ipson for 2018 Depreciation study reflecting the accelerated
life. There are no analysis of early retirement of Craig Unit 2 for
2026.
Sponsor: Chad Teply
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto I't Set Data Request 24
Monsanto Data Request 24
Please refer to Mr. Teply's testimony at page 10, lines 10-20. Please provide all
supporting 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.
Response to Monsanto Data Request 24
PacifiCorp has not made a final determination to accelerate the retirement of
Craig Unit 2. As described in testimony,, the joint-owners of Colstrip Unit I and
Colstrip Unit 2 reached a court settlement in July 2016 with environmental
stakeholders to retire Colstrip Unit I and Colstrip Unit 2 no later than July 2022.
Also, as stated in Mr. Teply's testimony beginning on page 9, line 19, certain
joint-owners have reached agreements with Washington to establish 2027 as the
new depreciable life for Colstrip Unit 3 and Colstrip Unit 4. Upon retirement of
Colstrip Unit I and Colship Unit 2 in2A22, Colstrip Unit 3 and Colstrip Unit 4
will bear all common costs for Colstrip Generation Station that will be passed
along to joint-owners of the two units. Accelerating the depreciable life of
Colstrip Unit 3 and Colship Unit 4 will facilitate PacifiCorp's ability to plan for
potential early retirement of the units in support of least-cost, least risk planning
and decision making for the benefit of customers should the joint-owners that
total 50 percent ownership share that have already established202T as the units
final depreciation year, choose to retire the units in2027. This approach positions
PacifiCorp to respond in timely fashion to the potential decisions of the other joint
owners of the unit during the period of time in and around 2027.The supporting
economic analysis, documents, and studies associated with any final decision-
making will be developed contemporaneously.
Note: PacifiCorp is undertaking an early retirement analysis of Colstrip Unit 3
and Colstrip Unit 4 reflecting the 2027 early retirement year as part of the 2019
Integrated Resource Plan (lRP). PacifiCorp's 2019 IRP is targeted to be filed in
April20l9.
Recordholder: Irene Heng
Sponsor: Chad Teply
l
PAC-E-I8-08 / Rocky Mountain Power
November 5,2018
Monsanto 1't Set Data Request 25
Monsanto Data Request 25
Please refer to Mr. Teply's testimony at page 11, lines 21 through page lZ,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.
Response to Monsanto Data Request 25
PacifiCorp is not currently undertaking maintenance investments specifically
focused on extending the economic lives of its natural gas combined cycle plants
beyond 40 years. PacifiCorp, however, does regularly engage with its facility
original equipment manufacturers (OEMs) and industry subject matter experts to
remain aware of maintenance practice improvements and technological
advancements that have the potential to improve equipment performance, reduce
costs, and most effectively maintain our generation resources. That awareness, in
conjunction with our ongoing prudent maintenance practices, would form the
foundation upon which to assess the availability and viability of future useful life
extensions.
Recordholder: Kent Ipson
Sponsor: Chad Teply
PAC-E-I8-08 / Rocky Mountain Power
November 5,2018
Monsanto l't Set Data Request 27
Monsanto Data Request 27
Please refer to Mr. Hemstreet's testimony at page T,lines l4-16. 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.
Response to Monsanto Data Request 27
The proposed life of a generation asset, including the wind assets, needs to
consider factors including economic obsolescence due to improvements in
technology that render investments in new plant more economic than continued
investment in existing assets. Depreciable lives are also informed by the design
lives of the assets, operating history, and the ability of those assets to
economically remain in service when maintenance costs become more significant
after the design lives of the equipment are exceeded. For these reasons, higher
certainty around generation offtake and maintenance funding is not the sole factor
informing the Company's proposed asset lives. Further, the Company's cost
recovery for ongoing maintenance costs is not assured, and is made less certain if
lower-cost alternatives exist than continuing to invest in legacy assets rather than
retiring those assets when economically justified.
Recordholder: Tim Hemstreet
Sponsor: Tim Hemstreet
PAC-E-I8-08 / Rocky Mountain Power
November 5, 2018
Monsanto I't Set Data Request 28
Monsanto Data Request 28
The following questions refer to RMP Exhibit No. 3.
(a) Please provide all work papers, with formulas and links intact, which support
the $3,214,547 of costs allocated to Idaho for the ending of excess reserve
amortizations.
(b) Please provide all work papers, 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.
Response to Monsanto Data Request 28
(a) Please refer to Attachment Monsanto 5-2 for the 2020 Comparison Schedule
which includes reserve amortization amounts by function and plant as
proposed in this Depreciation Study. Please refer to RMP Exhibit No. 3 for
the Idaho allocated balances of these reserve amortizations.
(b) The incremental increase from the 2013 depreciation study of approximately
$2.0 million was based on the monthly Idaho accruals. Please refer to
Attachment Monsanto 28-1 for work papers supporting the September 2018
deferral of $ 162,037, or approximately $ I .9mlyear.
(c) Please refer to Attachment Monsanto 28-2 for RMP Exhibit No. 3 in
Microsoft Excel format and please refer to Attachment Monsanto 5-2 for the
impact for the production, transmission, and distribution goups by FERC
account.
Recordholder: Nick Highsmith
Sponsor: Steve McDougal