20181207PAC to Monsanto 29-34.pdf

ROCKY MOUNTAIN
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
December 7,2018
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE & BUDGE, CHARTERED
P.O. Box l39l;201 E. Center
Pocatello, Idaho 83204-1391
[e-mail] (C)
[e-mail] (CXW)
RE ID PAC-E-I8.08
Monsanto 2'd Set Data Request (29-34)
Please find enclosed Rocky Mountain Power's Responses to Monsanto 2nd Set Data Requests 29-
34. Monsanto 32 will arrive under separate cover. Provided on a Confidential CD is
Confidential Attachment Monsanto 33. Also provided are Attachments Monsanto 3l and
Monsanto 34.
Confidential information is provided subject to the non-disclosure agreement between Monsanto
and PacifiCorp.
Sincerely,
J .t*t lur/-h,* /l^
J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Diane Hanian/IPUC diane.holt@.ouc.idaho.eov (C)
Edward Jewell/PUC Edward.iewell@.puc.idaho.eov
Ronald L. Williams/PIIC [e-mail] (C)
Brad Mullins/PIIC [e-mail] (e-mail only)
Jim Duke/PIIC [e-mail]
Kyle WilliamslPllC [e-mail]
Val Steiner/PIIC [e-mail]
Mauri ce Brubaker/Monsanto mbrubaker@consultbai. com (C)
Ben Otto/lCL [e-mail] (C)
Eric Olsen/llPA [e-mail] (C)
Dr. Lance Kaufrnan/IIPA lance@aeeisinsi ght.com (C)
Anthony Yankel/IIPA [e-mail] (C)
Matthew GerharUS ierra Club matt. gerhart@si erracl ub.ore
Ana Boyd/Si erra Club ana. bovd @si erracl ub. ors
PAC-E-I8-08 / Rocky Mountain Power
December 7,2018
Monsanto 2nd Set Data Request 29
Monsanto Data Request 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-18-08
(b) Public Utility Commission of Oregon Docket No. UM 1968.
(c) Washington Utilities and Transportation Commission Filing UE-180778.
(d) Wyoming Public Service Commission Docket No. 20000-539-EA-18.
(e) Utah Public Service Commission Docket No. l8-035-36.
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.
Response to Monsanto Data Request 29
Please refer to the Company's response to IIPA Data Request LI.
The Company does not have a SharePoint site or similar online repository for data
requests at this time.
Recordholder: Kaley McNay i Danny Martinez
Sponsor: Ted Weston
PAC-E-18-08 / Rocky Mountain Power
December 7,2018
Monsanto 2nd Set Data Request 30
Monsanto Data Request 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' work paper titled, "PacifiCorp -2020 Production Net Salvage - East
Plants.xlsx."
Response to Monsanto Data Request 30
As noted in the Company's response to Monsanto Data Request l2,the interim
retirements shown in column 8 of the referenced work paper are calculated based
on a statistical aging procedure, the balances as of the depreciation calculation
date and the estimated interim survivor curves and probable retirement dates. For
a given depreciable goup (i.e., generating unit and plant account), the procedure
to calculate the estimated interim retirements is performed as follows:
l. The plant balances by vintage as of the date of the depreciation calculations
are used as the starting point for the calculation.
2. The estimated interim survivor curve is used to calculate the retirements for
each year prior to the estimated retirement date of the depreciable group as
follows:
Based on the estimated interim survivor curve, percent surviving values
for the specific survivor curve are determined for one year intervals
beginning at aget/2.
From this curye, survivor ratios are computed and applied, by vintage, to
the previous year's aged ending balance. For each vintage, the survivor
ratio is determined as the quotient of the percent surviving at its age at
the end of the test year divided by the percent surviving at the beginning
of the test year or, for the test year additions, at age zero which is 100
percent.
iii. The aged retirements during the test year are derived by subtracting the
calculated survivors at the end of the test year, by vintage, from the
survivors at the end ofthe previous year.
l.
lt.
lv.The process is repeated for each test year within the test period (i.e.,
from the year immediately following the year of the depreciation
calculations to the year immediately preceding the estimated retirement
date).
PAC-E-I8-08 / Rocky Mountain Power
December 7,2018
Monsanto 2nd Set Data Request 30
3. The total interim retirements are equal to the sum of the calculated retirements
from the year subsequent the year of the depreciation calculations to the year
immediately preceding the estimated retirement date
Recordholder:John Spanos
John SpanosSponsor:
PAC-E-I8-08 / Rocky Mountain Power
December 7,2018
Monsanto 2nd Set Data Request 3l
Monsanto Data Request 3l
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 $ I 73 .2 million for the total company, with $ I 0.8 million allocated
to Idaho. Please provide a version of this exhibit that shows the increase for all
FERC accounts, 3l l-316, for each power plant, if possible. Do this in a similar
manner for the hydro production, other production, transmission, and distribution
accounts.
Response to Monsanto Data Request 3l
The Company objects to the request on the basis that the requested document does
not exist and is not in the custody, possession or control of the Company.
Without waiving the objection, please refer to the Company's response to
Monsanto Data Request 28, specifically subpart (c) and Attachment Monsanto 28-
2 which included the allocation factor by Federal Energy Regulatory Commission
(FERC) functional Soup in Microsoft Excel column D, and Idaho allocation
factors in Microsoft Excel columns M and S, Please also refer to the Company's
response to Monsanto Data Request 5, specifically Attachment Monsanto 5-2 for
the requested FERC Account and the proposed Total Company increase by plant.
This information is provided in Microsoft Excel columns A and Z. To calculate
the requested information, which the Company had not prepared, Monsanto
would have been able to apply the allocation factor and percentage to the
proposed Total Company increase by plant. To assist in this effort, the Company
has consolidated both exhibits and prepared this information as Attachment
Monsanto 31. Specifically, Microsoft Excel columns AB and AD are new
columns added to the previously provided Attachment Monsanto 5-2, and include
the allocation factor and Idaho allocation portion of the proposed Total Company
increase by plant for each requested category.
Recordholder: Nick Highsmith
Sponsor: Steve McDougal
PAC-E-I8-08 / Rocky Mountain Power
December 7,2018
Monsanto 2nd Set Data Request 33
Monsanto Data Request 33
Referring to the file provided as "Attach l4-l-Production and Transmission
Rollforward - 2020.x1sx," please answer the following:
(a) Please provide all supporting studies, work papers, 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, work papers, documents, etc. that
support the $318,522,000 of 2020 additions for the Ekola Flats Wind Farm.
Please also provide all documents that support the2020 in-service date.
(c) Please provide all supporting studies, work papers, documents, etc. that
support the $286,005,000 of 2020 additions for the Cedar Springs Wind Farm.
Please also provide all documents that support the2020 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, and2020 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.
Response to Monsanto Data Request 33
PacifiCorp objects to this request as overly broad, unduly burdensome and not
reasonably calculated to lead to the discovery of admissible evidence. Without
waiving these objections, the Company provides the following:
(a) PacifiCorp's Energy Vision 2020 filing (Case PAC-E-I7-07) included the TB
Flats I and II project initial capital costs presented in CONF Exhibit 47, to the
Teply 2nd Supplemental Direct Testimony. An indicative project critical path
schedule was provided in CONF Exhibit 2-6. Please refer to Confidential
Attachment Monsanto 33 for copies of these exhibits.
(b) PacifiCorp's Energy Vision 2020 filing (Case PAC-E-17-07) included the
Ekola Flats project initial capital costs presented in CONF Exhibit 47, to the
Teply 2nd Supplemental Direct Testimony. An indicative project critical path
schedule was provided in CONF Exhibit I -6. Please refer to Confidential
Attachment Monsanto 33 for copies of these exhibits.
PAC-E-I8-08 / Rocky Mountain Power
December 7,2018
Monsanto 2nd Set Data Request 33
Recordholder:John Spanos / Richard Goff
To Be Determined
(c) PacifiCorp's Energy Vision 2020 filing (Case PAC-E-17-07) included the
Cedar Springs II (BTA) project initial capital costs presented as CONF
Exhibit 47,to the Teply 2'd Supplanental Direct Testimony. An indicative
project critical path schedule was provided in CONF Exhibit 3l-3. Please
refer to Confidential Attachment Monsanto 33 for copies of these exhibits.
(d) The proposed net salvage rates represent the current estimate of what future
net salvage will be as a percentage of retirements, whereas the currently
approved net salvage rates were based on a settlement and do not incorporate
more recent data. Accordingly, the proposed net salvage rates represent the
best estimate of the net salvage the Company will experience for the years
2018,2019 and2020 and should be used to project net salvage for these years.
(e) The 2018,2019 and2020 retirements were determined using the same
statistical aging process described in the company's response to Monsanto
Data Request 30 (with the test period being 2018 through 2020). For the
statistical aging procedure, the retirements were calculated for each year using
the proposed survivor curves, not the currently approved survivor curves. The
proposed survivor curves were used for similar reasons to those discussed in
the Company's response to subpart (d) above. The proposed survivor curves
represent the best estimate of the level of retirernents that will occur for each
year based on the currently available information.
Confidential information is provided subject to the non-disclosure agreement
between Monsanto and PacifiCorp.
Sponsor:
PAC-E-18-08 / Rocky Mountain Power
December 7,2018
Monsanto 2'd Set Data Request 34
Monsanto Data Request 34
In RMP's technical conference presentation in Utah Docket No. l8-035-36, on
slides 6-7, RMP states that it will update its depreciation study to incorporate the
applicable terms of a settlement in Docket No. l7-035-69. 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 ldaho.
(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.
Response to Monsanto Data Request 34
(a) Please refer to Attachment Monsanto 34
(b) The settlement agreement in Utah will have no impact on the ldaho allocated
increase proposed in this docket.
(c) The Company does have excess deferred income tax (EDIT) regulatory
liability balances that could be used to "buy down" plant balances. These
balances have been submitted as Data Request PIIC 3 2nd Supplemental in
CaseNo. GNR-U-18-01.
Recordholder: Kaley McNay / Nick Highsmith / Deanna Fladstol
Sponsor: To Be Determined