20181212PAC to IIPA Attach 1d WIEC Set 2.docx

BEFORE THE PUBLIC SERVICE COMMISSION OF WYOMING
IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION FOR AN ORDER AUTHORIZING A CHANGE IN DEPRECIATION RATES APPLICABLE TO ELECTRIC PROPERTY
DOCKET NO. 20000-539-EA-18
(Record No. 15095)WYOMING INDUSTRIAL ENERGY CONSUMERS’
SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
The Wyoming Industrial Energy Consumers (“WIEC”), an unincorporated association comprised of industrial energy consumers, by and through its undersigned counsel, Holland & Hart LLP,respectfully submits itssecond set ofdata requests to Rocky Mountain Power, a division of PacifiCorp (“Company” or “Rocky Mountain Power”). The following response date, definitions, and instructions apply to this set of data requests:
RESPONSE DATEPlease respond to these data requests within 7calendar days, i.e., by December7, 2018, unless an earlier date is specified by the Wyoming Public Service Commission or by agreement of the parties.
DEFINITIONS AND INSTRUCTIONSPlease refer to the Definitions and Instructions included in WIEC’s First Set of Data Requests to Rocky Mountain Power in the above-captioned docket, which are incorporated by reference here.
SECOND SET OF DATA REQUESTS
Please provide a copy of all the Company’s responses to existing and future datarequests submitted to the Company in the proceedings for the Company’s pending depreciation cases inUtah (18-035-36), Idaho (PAC-E-18-08), Washington (UE-180778), and Oregon (UM 1968)by any and all otherparties, including the states’ respective Public Service Commissions or their Staff. To the extent the Companycannot provide this information, please provide WIEC with a copy of the original data requests and the reasons for withholding.
Referring to Mr. Teply’s Direct Testimony at p.12, lines 11-12, please provide the “updated decommissioning cost studies” including all supporting documents and analyses, with any formulae intact.
Referring to Mr. Teply’s Direct Testimony at p.12, lines 22-23, please provide the “baseline decommissioning studies” including all supporting documents and analyses, with any formulae intact.
Referring to the terminal dollar net salvage estimates in Section VIII of Exhibit JJS-2 and the estimated unit decommissioning costs in the Company’s response to WIEC 1.23, please answer the following questions:
Please provide all documents, studies, analyses, and other support upon which RMP relied for these cost estimates.
Please state whether such amounts represent present value or future value estimates. If such amounts represent future value estimates, please provide the present value estimates as well as the escalation rate / growth rate and the term or time period over which each present value estimate was escalated.
Please provide the detailed costs comprising each decommissioning cost estimate, including direct costs, indirect costs, labor costs, and scrap value.
Please state whether any contingency costs were included in the decommissioning cost estimates and provide the amount of such contingency costs for each generating unit. Please explain the Company’s rationale for including or excluding such cost estimates.
Referring to Appendix A of Exhibit JJS-2, please describe in detail how the projected plant and reserve balances as of December 31, 2020 were estimated. Please provide all supporting documents and calculations, with any formulae intact.
Respectfully submitted this 30th day of November, 2018.
HOLLAND & HART LLP
By: Abigail C. Briggerman, #7-5476Michelle Brandt King #7-5173
Holland & Hart LLP
6380 South Fiddlers Green Circle, Suite 500Greenwood Village, CO 80111
Telephone: (303) [e-mail]@hollandhart.comATTORNEYS FOR WIEC
CERTIFICATE OF SERVICE
I hereby certify that, on this 30th day of November, 2018the WYOMING INDUSTRIAL ENERGY CONSUMERS’ SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER was served via electronic mail or U.S. Mail, addressed to the following:
Stacy Splittstoesser
Wyoming Regulatory Affairs Manager
Rocky Mountain Power
315 W. 27th Street
Cheyenne, WY 82001
[e-mail]
D. Matthew Moscon (#6947)
Lauren Shurman (#11243)
Stoel Rives, LLP
201 South State Street, Suite 1100
Salt Lake City, UT 84111
[e-mail]
[e-mail]
Christopher Leger
Office of Consumer Advocate
2515 Warren Avenue, Suite 304
Cheyenne, WY 82002
[e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]
Shannon Anderson
Powder River Basin Resource Council
934 N. Main Street
Sheridan, WY 82801
[e-mail]
s/ Adele C. Lee
11694764_1