20200220PAC to IIPA UT Sierra Club Set 1.pdf

February 13, 2020 Ana Boyd
Julian Aris
Gloria D. Smith Sierra Club Environmental Law Program 2101 Webster, Suite 1300 Oakland, CA 94612
[e-mail] (C)
[e-mail] (C)(W) [e-mail] (C)(W) Ezra Hausman
Ezra Hausman Consulting
77 Kaposia St. Auburndale, MA 02466 [e-mail] (C)
RE: UT Docket No. 18-035-36
Sierra Club 1st Set Data Request (1-3) Please find enclosed Rocky Mountain Power’s Responses to Sierra Club 1st Set Data Requests 1.1- 1.3. Provided on the enclosed CD is Attachment Sierra Club 1.1-1. Provided via encryption
is Confidential Attachment Sierra Club 1.1-2. Confidential information is provided subject to
Public Service Commission of Utah Rule 746-1-602 and 746-1-603. Attachments are requests for copies and are provided to the requesting party only. If you have any questions, please call me at [phone].

Sincerely, ___/s/___
Jana Saba
Manager, Regulation Enclosures
C.c. Cheryl Murray/OCS [e-mail] (C)
Donna Ramas/OCS [e-mail] (C) Nancy Kelly/WRA [e-mail] (C) Sophie Hayes/WRA [e-mail] (C) Gary A. Dodge/UAE [e-mail] (W)
Phillip J. Russell/UAE [e-mail] (C)
Salt Lake City, UT 84116
Kevin Higgins/UAE [e-mail] (C) Neal Townsend/UAE [e-mail] (C)(W) Courtney Higgins/UAE [e-mail] (C)(W)
Justin Bieber/UAE [e-mail] (C)(W)
Hunter Holman/UCE [e-mail] (C) Sarah Wright/UCE [e-mail] (C) Division of Public Utilities [e-mail] (C) Roxie McCullar/DPU [e-mail] (C)

18-035-36 / Rocky Mountain Power February 13, 2020
Sierra Club Data Request 1.1 Sierra Club Data Request 1.1 Please provide a copy of all responses to existing and future data requests submitted to
Rocky Mountain Power in this proceeding by any and all other parties, including the Utah Public Service Commission or its Staff. Response to Sierra Club Data Request 1.1
Please refer to Attachment Sierra Club 1.1-1 and Confidential Attachment Sierra Club 1.1-2. Going forward, Sierra Club will be provided copies of outgoing data responses.
The Company does not waive any objections related to the data request responses included in the attachments. Confidential information is provided subject to Public Service Commission of Utah Rule 746-1-602 and 746-1-603.

18-035-36 / Rocky Mountain Power February 13, 2020
Sierra Club Data Request 1.2 Sierra Club Data Request 1.2 Please refer to page 8, lines 157-67, of the Direct Testimony of Charles A. Teply, which
states, in describing the “emerging policy and market drivers [that] affect the estimated depreciable lives of generation resources”, that “[o]ne notable public policy example is Oregon Senate Bill 1547-B, which was signed into law by the governor of Oregon on March 8, 2016”.
(a) Please explain specifically how Oregon Senate Bill 1547-B affected RMP’s assumed depreciable lives for each of PacifiCorp’s coal plants. Please be specific with respect to RMP’s assumed depreciable lives in Utah. (b) The Washington Clean Energy Transformation Act (E2SSB 5116), also known as
CETA, states that “[o]n or before December 31, 2025, each electric utility [serving Washington customers] must eliminate coal-fired resources from its allocation of electricity.” S.B. 5116, 66 Leg., Reg. Sess. (Wash. 2019). Does CETA constitute an example of an “emerging policy and market driver[] affect[ing] the estimated depreciable lives of generation resources”?
(c) Please explain how CETA affected RMP’s assumed depreciable lives for each of PacifiCorp’s coal plants. If CETA was not considered in setting the depreciable lives of PacifiCorp’s coal plants due to the timing of the act relative to the current depreciation study, please explain how the depreciable lives of PacifiCorp’s coal
plants would be updated if this law were to be taken into account. (d) The Idaho Power Company’s (IPC) 2019 Integrated Resource Plan (IRP) set depreciable end-of life dates for the Jim Bridger Plant Units 1, 2, 3, and 4 at 2022,
2026, 2028, and 2030, respectively. Does this IRP constitute an example of an
“emerging policy and market driver”? Please explain how the depreciable lives filed under IPC’s 2019 IRP affected RMP’s assumed depreciable lives for each of the Jim Bridger units. If this IRP was not considered in setting the depreciable lives of the Jim Bridger units due to timing relative to the current depreciation study, please explain
how the depreciable lives of PacifiCorp’s coal plants would be updated if this IRP
were to be taken into account. (e) The PacifiCorp 2020 Multi-State Protocol (MSP), as filed in Utah docket 19-035-42, includes provisions for individual state commissions to issue “exit orders”, leading to
removal of the benefits and costs of individual coal units that state’s energy mix and
rate base. Does this aspect of the 2020 MSP constitute an example of an “emerging policy and market driver”? Please explain how the potential for “exit orders” for PacifiCorp’s coal units affected RMP’s assumed depreciable lives for each of PacifiCorp’s coal plants. If this aspect of the 2020 MSP was not considered in setting
the depreciable lives of PacifiCorp’s coal plants due to timing relative to the current
depreciation study, please explain how the depreciable lives of PacifiCorp’s coal plants would be updated if the 2020 MSP were to be taken into account.
18-035-36 / Rocky Mountain Power February 13, 2020
Sierra Club Data Request 1.2 Response to Sierra Club Data Request 1.2 The Company assumes that the reference to “the Direct Testimony of Charles A. Teply” is intended to be a reference to the direct testimony of Company witness, Chad A. Teply in this proceeding. Based on the foregoing assumption, the Company responds as follows:
(a) Oregon Senate Bill (SB) 1547-B did not affect the depreciable lives assumed for each PacifiCorp coal plant assumed for Utah. (b) Yes, the Washington Clean Energy Transformation Act (E2SSB 5116), also known as CETA, would constitute an example of an “emerging policy and market driver
affecting the estimated depreciable lives of generation resources”, but CETA was still in preliminary phase of development when the 2018 Depreciation Study was filed. (c) CETA did not impact the 2018 Depreciation Study as the legislation was passed May 2019 after the depreciation study was filed. PacifiCorp is participating in the CETA
rulemaking that is in progress in the state of Washington. The CETA rules, when completed, will impact Colstrip Unit 4 and Jim Bridger Plant units only for Washington depreciable lives. (d) PacifiCorp objects to the request relative to Idaho Power Company’s (IPC) 2019
Integrated Resource Plan as PacifiCorp is not able to comment on another independent company, IPC. IPC is not within the purview of PacifiCorp. Notwithstanding the foregoing objection, the Company responds as follows:
PacifiCorp did not have view of IPC’s 2019 IRP when PacifiCorp’s 2018
Depreciation Study was filed September 11, 2018. (e) Exit Orders as defined in the Multi-State Process (MSP) 2020 Protocol do not constitute an example of an “emerging policy and market driver”. Exit Orders, as
defined in the MSP 2020 Protocol, are used to establish Exit Dates related to the
allocation of costs and benefits between states. They will not be used to set Utah’s depreciable lives.
18-035-36 / Rocky Mountain Power February 13, 2020
Sierra Club Data Request 1.3 Sierra Club Data Request 1.3 Please refer to the MSP mentioned in Question 1.2-d. The MSP sets forth expected or
recommended exit dates for specific PacifiCorp units that, in some cases, are inconsistent with the depreciable end-of-life as set forth in Exhibit RMP___(CAT-1) to Mr. Teply’s direct testimony. Specific differences are identified in the table below:
(a) Were the anticipated and recommended exit dates in the 2020 Protocols shown in the table above taken into account in estimating the depreciable lives of each of the units
listed? If so, please explain how. If not, please explain why not.
(b) Does RMP anticipate revising its depreciation schedules in response to the exit dates identified in the 2020 Protocols.

18-035-36 / Rocky Mountain Power February 13, 2020
Sierra Club Data Request 1.3 Response to Sierra Club Data Request 1.3 (a) No, the exit dates in the 2020 Inter-Jurisdictional Cost Allocation Agreement (2020
Protocol) stated in Sierra Club’s table were not taken into account in estimating the depreciable lives of each of the units listed because the 2020 Protocol was still being negotiated at time of the 2018 Depreciation Study filing that occurred in September 2018.
(b) No. Exit Dates, as defined in the 2020 Protocol, are related to the allocation of costs and benefits to states issuing Exit Orders. They will not be used to update Utah’s depreciation study.