20181226PAC to PIIC 1-7.pdf

1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
December 26,2018
Ronald L. Williams
Williams Bradbury, P.C.
Pacifi Corp Idaho Industrial Customers
802 W. Bannock St., Suite 900
Boise,ldaho 83702
[e-mail] (C)
RE ID PAC-8.18.08
PIIC 1't Set Data Request (1-7)
Please find enclosed Rocky Mountain Power's Responses to PIIC l't Set Data Requests 1-7.
Also provided is Attachment PIIC 2.
Sincerely,
Jr4
J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Diane Hanian/IPUC [e-mail] (C)
Edward Jewell/PUC Edward j ewell@nuc. idaho. gov (C)
Brad Mullins/?llC brmull ins@mwanalytics. com (e-mail only)
Jim DukelPIIC i [e-mail]
Kyle Williams/PIIC williamsk@byui. edu
Val Steiner/PIIC val. steiner@,itafos. com
Maurice Brubaker/Monsanto [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
Eric Olsen/IIPA [e-mail] (C)
Dr. Lance Kaufman/IIPA lance@.ae gisinsi ght. com (C)
Anthony Yankel/IIPA [e-mail] (C)
Matthew Gerhart/S i erra Club matt. eerhart@ sierraclub. org
Ana Boyd/Sierra Club [e-mail]
Randall C. BudgeAvlonsanto rcb@racinelaw,net (C)
Thomas J. BudgeAvlonsanto tj b@racinelaw.n"t (CXW)
PAC-E-18-08 / Rocky Mountain Power
December 26,2018
PIIC I't Set Data Request 1
PIIC Data Request I
Please provide all questions and answers to all prior data requests between RMP
and all other parties in this case, including questions and answers that contain
confi dential information.
Response to PIIC Data Request I
Please refer to IIPA 1.1.
Recordholder: Kaley McNay
Sponsor: Not Applicable
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
PIIC lst Set Data Request 2
PIIC Data Request 2
Please provide RMP's 2017 results of operations in Excel format with all
formulas intact.
Response to PIIC Data Request 2
Please refer to Attachment PIIC 2 for copies of the Idaho December 20i7 result of
operations report.
Recordholder: Steve McDougal
Sponsor: Steve McDougal
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
PIIC I't Set Data Request 3
PIIC Data Request 3
Reference PAC/202, Spanos/43-44: For each production plant identified in the
life span tables on the referenced pages, please identify the total embedded cost of
the resource in 2015, 2016, and 2017. Please detail the embedded cost by FERC
account.
By "embedded cost" PIIC means the total "revenue requirement" of the unit,
excluding variable power costs. The power cost data is requested in a separate
request. The cost data should be based on PacifiCorp's results of operations for
2015,2016, and20L7. PIIC would like PacifiCorp to provide the revenue
requirement data by unit and FERC account using the same methodology
PacifiCorp is proposing to use in the CLEAR plan for resource valuation in the
context of the Multi-State Process. The cost categories would include
Depreciation Expenses, Non-NPC Operating Cost, Fuel Stock, ADIT, EDFIT,
Gross Plant, Accumulated Depreciation, and any other category of costs
PacifiCorp believes is relevant when considering the cost of the respective
resources.
Response to PIIC Data Request 3
PacifiCorp objects to this request as overly broad and not reasonably calculated to
lead to the discovery of admissible evidence. Total revenue requirement is based
on state specific policy issues, and includes costs that are not broken down on a
resource by resource basis.
Recordholder: Yvonne Hogle
Sponsor: Not Applicable
PAC-E-I8-08 / Rocky Mountain Power
December 26,2418
PIC 1't Set Data Request 4
PIIC Data Request 4
Please provide total-Company actual net power costs detailed on a monthly basis
for calendar years 2008 through 2017. Please include the database entries and all
fuel supply cost calculations for the period in their native format, including any
mapping necessary to assign the database and fuel accounts to line items in the
power cost report, as well as all links between the database and fuel data to the
actual net power cost report.
Response to PIIC Data Request 4
PacifiCorp objects to this request as overly broad and not reasonably calculated to
lead to the discovery of admissible evidence. The depreciation study addresses
fixed costs, not variable costs.
Recordholder: Yvonne Hogle
Sponsor: Not Applicable
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
PIIC 1't Set Data Request 5
PIIC Data Request 5
Please provide total-Company actual net power costs in the manner described in
AWEC Data Request No. 0024, but for calendar years 2018 and 2019 through the
most recent month available. Please update this report and the underlying data on
a monthly basis through the pendency of this proceeding.
Response to PIIC Data Request 5
The Company assumes that the reference to "AWEC Data Request No. 0024" is
in error and that the correct and intended reference is to "P[C Data Request 4."
Based on the foregoing assumption, the Company responds as follows:
PacifiCorp objects to this request as overly broad and not reasonably calculated to
lead to the discovery of admissible evidence. The depreciation study addresses
fixed costs, not variable costs.
Recordholder: Yvonne Hogle
Sponsor: Not Applicable
PAC-E-18-08 / Rocky Mountain Power
December 26,2018
PIC lst Set Data Request 6
PIIC Data Request 6
Please provide a copy of PacifiCorp's most recent 1O-year business plan,
including all supporting work papers with all links and formulas intact.
Response to PIIC Data Request 6
PacifiCorp objects to this request as overly broad, not reasonably calculated to
lead to the discovery of admissible evidence, and as requesting disclosure of
information protected by the attomey-client privilege or the attorney work-
product doctrine. Without waiving these objections, the company responds as
follows:
Non-privileged portions of PacifiCorp's l0-year business plan are considered
highly confidential and commercially sensitive. PacifiCorp requests special
handling. Please contact Ted Weston at [phone] to discuss arrangements
to review PacifiCorp's most recent l0-year business plan.
Recordholder: Ted Weston
Sponsor: Ted Weston
PAC-E-I8-08 / Rocky Mountain Power
December 26,2018
PIIC 1't Set Data Request 7
PIIC Data Request 7
Please provide access to the GRID model used to develop PacifiCorp's most
recent l0-year business plan, including all input and output work papers that are
used to develop the forecast.
Response to PIIC Data Request 7
PacifiCorp objects to this request as overly broad, not reasonably calculated to
lead to the discovery of admissible evidence, and as requesting disclosure of
information protected by the attomey-client privilege or the attorney work-
product doctrine. Without waiving these objections, the company responds as
follows:
Please refer to the company's response to PIIC Data Request 6 for additional
information regarding access to the company's 10-year business plan.
Recordholder: Ted Weston
Sponsor: Ted Weston