20181109IIPA 1-18 to PAC.pdf

Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: (208) 47 8-167 0
Email: [e-mail]
Attorney for Intervenor ldaho lrrigation Pumpers Association, Inc.
*-r-i-!rlfrtilt'\i'-.-*'i-Iv r'-u
:"r,"l.r'i -9 |.lii 9' l2
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR
AUTHORIZATION TO CHANGE
DEPRECIATION RATES APPLICABLE TO
ELECTRIC PROPERTY
CASE NO. PAC-E-18-08
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST SET
OF DATA REQUESTS
Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its first Data
Requests to Rocky Mountain Power, pursuant to Commission Rule 225, as follows:
IIPA 1-1: Please provide copies of any and all data requests submitted to you by any party
to the following proceedings and your corresponding responses to those data requests. This
is an ongoing request:
a. Public Utility Commission of Oregon Docket No. UM 1968
b. Washington Utilities and Transportation Commission Filing UE-180778
c. Idaho Public Utilities Commission Case No. PAC-E-18-08
d. Wyoming Public Service Commission Docket No. 20000-539-EA-18
e. Utah Public Service Commission Docket No: 18-035-36
IIPA 1-2: Please provide all documents, data, and files submitted by PacifiCorp to
Ganner Fleming including but not limited to:
a. All accounting records of plant additions, retirements, transfers, sales,
and related balances identified in The Direct Testimony of John Spanos,
page 4.
b. All accounting records of plant cost of removal and gross salvage
identified in The Direct Testimony of John Spanos, page 8.
c. The life assessment study identified in The Direct Testimony of
John Spanos, page 7.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IIPA 1-3: Please refer to The Direct Testimony of John Spanos, page 5
a. Please explain why the Company has not maintained the vintage of
each transaction for most distribution assets in Idaho and Utah.
b. Does the Company intend to maintain vintage data on a going forward
basis? If no, why not?
IIPA 1-4: Please refer to The Direct Testimony of John Spanos, page 5, which states
"For each property group, I used the retirement rate data to form a life table which, when
plotted, shows an original survivor curve for that property group."
a. Please provide the data used by Mr. Spanos to calculate retirement rates.
b. Please identify all differences between PacifiCorp's accounting records
and the data provided in part a of this request, and explain the reason
for each difference.
c. Please provide the retirement rates calculated by Mr. Spanos for each
property group. Please provide such data as a computer-readable
spreadsheet.
IIPA l-5: Please refer to The Direct Testimony of John Spanos, page 5, which
States "Therefore, the simulated plant record method was utilized to determine life
characteristics."
a. Please provide the data used by Mr. Spanos to utilize the simulated
plant record method.
b. Please identify all differences between PacifiCorp's accounting records
and the data provided in part a of this request, and explain the reason
for each difference.
IIPA 1-6: Please provide all notes relied on or generated by Mr. Spanos, or any
other Gannet Fleming employee when preparing Exhibit No. 2.
IIPA 1-7: Please refer to Exhibit No. 2, page 30
a. Please provide the criteria used for mathematical matching of original
survivor curves and Iowa survivor curves.
b. Please identifl, each curve for each account which was visually examined
by Mr. Spanos, but not ultimately selected to smooth the original survivor
curves. Please include the images examined by Mr. Spanos.
IIPA 1-8: Please refer to the Direct Testimony of Chad A. Teply, page 12 which
states "The Company performed updated decommissioning cost studies in the 2014 to 2016
timeframe..." Please provide all decommissioning studies performed on PacifiCorp
generation resources from 2013 to the present. Please include all relatedworkpapers, files,
and deliverables.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQEUSTS _ Page 2
Case No. PAC-E-18-08
IIPA 1-9: Please refer to the Direct Testimony of Nikki L. Kobliha, page 7, which
states "Additions to property, plant and equipment balances, more commonly referred to as
capital additions, is one of the primary drivers that increases depreciation expense." Please
identify each referenced incremental capital addition and provide the date, unit, gross
plant and reason for the addition.
IIPA 1-10: Please refer to Exhibit No. 2. Please provide the following information related
to this depreciation study:
a. Request for proposal, if any, and all parties that such RFP was sent to.
b. Contract, terms of engagement, and all other agreements between
PacifiCorp and Gannet Fleming.
c. All invoices submitted by Gannet Fleming.
d. Please identify each person interviewed by Mr. Spanos or other Gannet
Fleming employee in preparation for the report. Please provide the name
and position of the person interviewed, the name and position of the
individual conducting the interview, the date of the interview, and all
notes or other records of interview.
e. Please identify each PacifiCorp facility inspected by Mr. Spanos. Please
provide the location and type of facilities inspected and all photos, notes
or other records of the inspection.
IIPA 1-1 1: Please refer to the Direct Testimony of Nikki L. Kobliha, page 6, which states
"I believe that the Depreciation Study is well supported by the underlying engineering and
accounting data... ." Please provide all referenced engineering and accounting data.
IIPA 1-12: Please refer to the Direct Testimony of Nikki L. Kobliha, pa9e 9, which
states "For the Depreciation Study, steam facilities are grouped by FERC account at a unit
level." Does PacifiCorp intend to book depreciation at the unit level?
IIPA 1-13: Please refer to the Direct Testimony of Nikki L. Kobliha, page 10, which
states "The Company has continued to experience interim retirements related to scheduled
overhauls on its natural gas facilities." Please provide the annual maintenance expense
since 2008 separately for each PacifiCorp generating resource.
IIPA I - 14: Please refer to the Direct Testimony of Steven R. McDougal, page 5, which
states"... the Company will continue to recognize the stipulated life of Klamath through
a regulatory adjustment in the relevant filings made in Idaho." Please provide a detailed
description of the regulatory adjustments PacifiCorp intends to make for the Klamath River
hydro facilities.
IIPA 1-15: Please refer to Exhibit No. 3.
a. Please provide these data as an electronically-readable spreadsheet for
each of PacifiCorp's state jurisdictions.
b. Please provide these data for plant balances as of December, 2017 -
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQEUSTS _ Page 3
Case No. PAC-E-I8-08
IIPA 1-16: Please refer to Direct Testimony of Chad A. Teply, page 8, which states
"One notable public policy example is Oregon Senate Bill 1547-8, which was signed into
law by the governor of Oregon on March 8,2016." Has SB 1547 affected PacifiCorp's
estimated economic lives of any generation facilities? If yes, how? If no, why not?
IIPA 1-17: Please refer to Direct Testimony of Chad A. Teply, page 11, which states
"The original equipment manufacturer's year useful life recommendation has not
changed and remains consistent with the 2013 depreciation study." Please provide
documentation of the original equipment manufacturer's useful life recommendations
and maintenance recommendations. Please provide such data for each of PacifiCorp's gas
generation units.
IIPA 1-18: Please refer toExhibit No. 5 at the column named "Recommended End
of Depreciation Year".
a. Please provide these data for every generating unit, including hydro
and wind facilities, in each of PacifiCorp's state jurisdictions.
b. For each unit or facility with the recommended end of depreciation
year differing between states, please identify the year that PacifiCorp
plans to retire the unit or facility.
DATED thi" alkyof November,2018.
OLSEN
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQEUSTS _ Page 4
Case No. PAC-E-18-08
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this iD day of November, 2OI8,I served a true, correct
and complete copy of Idaho Irrigation Pumpers Association, Inc. First Set of Data Requests to
each of the following, via U.S. Mail or private courier, email or hand delivery, as indicated below:
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise,ID 83720-0074
[e-mail]. eov
Yvonne R. Hogle
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Email: [e-mail]
Email : ted.weston@pacifi corp. com
Stoel Rives, LLP
D. Matthew Moscon
Lauren Shurman
201 South State Street, Suite I100
Salt Lake City, Utah 84111
Email: [e-mail]
Email : lauren. [e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
Email : datarequest@pacifi com.com
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
xtrtrtrx
trtrtrtrx
trtrntrx
trtrtrtrx
IDAHO IRRIGATION PUMPERS ASSOCIATION, tNC. FIRST SET OF DATA REQEUSTS _ Page 5
Case No. PAC-E-I8-08
Attorney for ldaho Conservation League
Benjamin J. Otto
710 N 6th Street
Boise,ID 83701
Email : botto @idahoconservation. org
Attorneys for Monsanto Company
Racine Olson, PLLP
Randall C. Budge
Thomas J. Budge
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1391
Email: [e-mail]
Email: [e-mail]
Brubaker & Associates for Monsanto
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
Email: [e-mail]
Email: [e-mail]
Idaho Irrigation Pumpers Association, Inc.
Dr. Lance D. Kaufman
4801 W. Yale Ave.
Denver, CO 80219
Email: [e-mail]
Attorney for PacificCorp Idaho Industrial
Customers
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise,ID 83701
Email: [e-mail]
PIIC Customer
Idahoan Foods
Jim Duke
Email: [e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Ovemight Mail
Telecopy (Fax)
Electronic Mail (Email)
trTtrtrx
ntrtrtrx
trtrtrtrx
trtrTtrx
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQEUSTS _ Page 6
Case No. PAC-E-18-08
PIIC Customer
BYU Idaho
Kyle Williams
Email: [e-mail]
PIIC Customer
Nu-West Industries, Inc.
Val Steiner
Email: [e-mail]
Attorney for Sierra Club
Matthew Gerhart
1536 Wynkoop St., Suite 200
Denver, CO 80202
Email : matt. [e-mail]
Sierra Club
Ana Boyd
2101 Webster St., Suite 1300
Oakland, CA94612
Email: [e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
U.S. Mail
Hand Delivered
Ovemight Mail
Telecopy (Fax)
Electronic Mail (Email)
trtrtrIx
trtrtrtrx
trtrtrtrx
trtrntrx
&,U***ArnL
Rebecca Berls, Paralegal
Echo Hawk & Olsen. PLLC
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQEUSTS _ Page 7
Case No. PAC-E-f8-08