20181115Monsanto 29-34 to PAC.pdf

IN TIIE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR
AUTHORIZATION TO CHAI\GE
DEPRECIATION RATES
APPLICABLE TO ELECTRIC
PROPERTY
f il ifi liill,' i 5 Pl,l 12: 55
CASE NO. PAC.E.18.O8
MONSAI\TO COMPANY'S SECOND
DATA REQUESTS TO ROCKY
MOUNTAIN POWER
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMI\{ISSION
MONSANTO COMPANY, by and through their attorneys, hereby submits this Second
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 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.
MONSANTO COMPANY'S SECOND DATA REQUESTS TO ROCKY MOUNTAIN POWER - I
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE & BUDGE, CHARTERED
P.O. Box l39I;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
rcb(rDracinelaw.net
lib(dracinelaw.net
RECEI\,/ED
Monsanto Set 2
Request No. 29: Please provide all data requests submitted to RMP by any party and the
corresponding responses to those data requests from the following proceedings for RMP's
Depreciation Study:
a. Idaho Public Utilities Commission Case No. PAC-E-I8-08
b. Public Utility Commission of Oregon Docket No. UM 1968
c. Washington Utilities and Transportation Commission Filing UE-l80778
d. Wyoming Public Service Commission Docket No. 20000-539-EA-18
e. Utah Public Service Commission Docket No. 18-035-36
If RMP doesn't establish a SharePoint site, or similar online repository for all of the data requests
and response in these proceedings, please provide copies ofall data requests and responses directly
to Monsanto at the same time the requests are received and the responses are supplied to the
requesting party. This is an ongoing request.
Request No. 30: Please refer to RMP's response to Monsanto Data Request 12. Please
provide a detailed explanation of the exact process or procedure employed by Gannett Fleming's
software that calculates the interim retirements shown in column 8 of Mr. Spanos' workpaper
titled, "PacifiCorp - 2020 Production Net Salvage - East Plants.xlsx."
Request No. 31: Please refer to RMP's response to Monsanto Data Request 28-C. The
file provided was not the file that was requested. The request was for an excel file that is similar
to RMP Exhibit 3, that shows the impact for the production, transmission, and distribution groups
by FERC account, and if possible by generating unit. As an example, RMP Exhibit 3, shows that
the increase for steam production is $173.2 million for the total company, with $10.8 million
allocated to Idaho. Please provide a version of this exhibit that shows the increase for all FERC
accounts, 3l I -316, for each power plant, if possible. Do this in a similar manner for the hydro
production, other production, transmission, and distribution accounts.
Request No. 32: Referring to the file provided as "Attach Monsanto l4-3 - 2018-2020
Estimated Additions.xlsx," please answer the following:
a. Please provide all studies, workpapers, documents, etc. that support the level of wind
additions, totaling S I . I 36 billion over 2018-2020.
b. Please provide all studies, workpapers, documents, etc. that support the level of wind
retirements, totaling $1.278 billion over 2018-2020.
c. Please provide all studies, workpapers, documents, etc. that support the level of
transmission additions, totaling $1.294 billion over 2018-2020 for the wind facilities.
MONSANTO COMPANY'S SECOND DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2
Request No. 33: Referring to the file provided as "Attach l4-l-Production and
Transmission Rollforw ar d - 2020.xlsx," p lease answer the fo I lowin g :
a. Please provide all supporting studies, workpapers, documents, etc. that support the
$591,391,000 of 2020 additions for the TB Flats Wind Farm. Please also provide all
documents that support the 2020 in-service date.
b. Please provide all supporting studies, workpapers, documents, etc. that support the
$318,522,000 of 2020 additions for the Ekola Flats Wind Farm. Please also provide
all documents that suppofithe2O20 in-service date.
c. Please provide all supporting studies, workpapers, documents, etc. that support the
$286,005,000 of 2020 additions for the Cedar Springs Wind Farm. Please also provide
all documents that supportthe2020 in-service date.
d. Please explain why the net salvage assumed in this file is based on RMP's proposed
net salvage rates, rather than the currently approved net salvage rates.
e. Please explain how the 2018,2019, and 2020 retirements were determined. Please
provide proof that these retirements were calculated consistent with RMP's currently
approved survivor curves, rather than with RMP's proposed survivor curves.
Request No. 34: 1. In RMP's technical conference presentation in Utah Docket No. 18-
035-36, on slides 6-7, RMP states that it will update its depreciation study to incorporate the
applicable terms of a settlement in Docket No. 17-035-69. Please answer the following:
a. Please provide a copy of the stipulation agreement in Docket No. 17-035-69.
b. Please explain how the settlement agreement will affect RMP's proposal in the instant
proceeding; i.e. the proposed increase in Idaho.
c. Please explain if there is an excess of ADIT in Idaho that could be utilized to "buy
down" the plant balances for Idaho, as in Utah.
DATED this 15ft day of November, 2018
RACINE, OLSON, NYE
& BUDGE, CHARTERED
By:
BUDGE
c
C.
MONSANTO COMPANY'S SECOND DATA REQUESTS TO ROCKY MOUNTAIN POWER - 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 15fr day of November, 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 84116
E-mail : wonne. ho gl e(@pac i flcory. com
E-mail: ted. weston(@pacifi corp.com
Rocky Mountain Power
D. Matthew Moscon
Lauren Shurman
Stoel Rives, LLP
201 South State Street, Suite 1100
Salt Lake City, Utah 84111
Telephone: [phone]
Facsimile: (801 ) 578-6999
Email: matt.moscon(rl,stoel.com
Email: lauren. shurman(4stoel.com
Rocky Mountain Power
Data Request Response Center
Pacificorp
825 NE Multnomah, Suite 2000
Portland, OR97232
E-mail: datarequest(glpaci fi corp.com
Brubaker & Associates
16690 Swingley Ridge Road, #140
Chesterfield, MO 63017
E-Mail: rn brubaker(rDconsultbai. com
[e-mail]
Monsanto Company
Diane Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
E-mail: diane.holt(atpuc. idaho. qov
Commission Staff
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MONSANTO COMPANY'S SECOND DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4
Brandon Karpen
Deputy Attorney General
Idaho Public Utilities Commission
472 W . Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Email: brandon.karpen(g)puc.idaho. sov
Commission Staff
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise,Idaho 83701
Email: ron(4williamsbradburv.com
PtrC
Jim Duke
Idahoan Foods
357 Constitution Way
Idaho Falls, ID 83742
E-Mail: i duke(ru idahoan.com
PIIC
Kyle Williams
BYU Idaho
Email: williamsk(g)byui.edu
PIIC
Val Steiner
Nu-West Industries, lnc.
Email: val.steiner(giasrium.com
PtrC
Eric L. Olsen
Echo Hawk & Olsen, PLLC
P.O. Box 6l 19
505 Pershing Ave., Ste. 100
Pocatello, Idaho 83205
elo(a)echohawk.cont
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MONSANTO COMPANY'S SECOND DATA REQUESTS TO ROCKY MOUNTAIN POWER - 5
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
tony(4yankel.net
IIPA
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MONSANTO COMPANY'S SECOND DATA REQUESTS TO ROCKY MOUNTAIN POWER - 6