20190508PAC to PIIC 1-10.pdf

Y ROCKY MOUNTAIN
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RECEIVED
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
May 7,2019
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
ron(rDwi I liamsbradbury.com (C)
Bradley G. Mullins
333 S.W. Taylor, St 400
Portland, OR97204
brmullins(rDmwanalytics. com (C)
RE:ID PAC-E-19-04
PIIC 1't Set Data Request (l-10)
Please find enclosed Rocky Mountain Power's Responses to PIIC l't Set Data Requests l-10.
Also provided are Attachments PIIC l-1,2-1,3-1, and 5. Provided on the enclosed Confidential
CD are Confidential Attachments PIIC I-2,2-2,3-2, 4,6,7, and 9. Confidential information is
provided subject to the terms and conditions in the protective agreement between PIIC and the
Company in this proceeding.
If you have any questions, please feel free to call me at [phone]
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
EnclosuresC.c. Jim Duke/PIIC jduke(@idahoan.com (W)
Val Steiner/PIIC val. [e-mail] (W)
Kyle Williams/PlC [e-mail] (W)
Randall C. Budge/\{onsanto rcb@ rac inelaw. net randy(ZD racineolson. com (C)
Thomas J. Budge/IVlonsanto ti b@ racinel aw. net (W)
Brian C. Collins/Ivlonsanto bcol lins(E consultbai. com (C)
Maurice Brubakerilvlonsanto mbrubaker@,consultbai. com (CXW)
Diane HaniadIPUC diane.holt@puc. idaho. eov (C)
Brad Iverson-Long/IPUC [e-mail]. eov (CXW)
2019 ECAM / Rocky Mountain Power
N'4.ay 7,2019
PIIC l't Set Data Request I
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
confidential information.
The Company does not waive any objections raised in the data request responses
included in the attachments.
Confidential information is provided subject to the terms and conditions in the
protective agreement between PIIC and the Company in this proceeding.
Recordholder: KaleyMcNay
Sponsor: Not Applicable
Response to PIIC Data Request 1
Please refer to Attachment PIIC l-1 and Confidential Attachment PIIC l-2.
PIIC will be copied on all future responses in the other proceedings as
Supplemental Responses to this data request.
2019 ECAM / Rocky Mountain Power
May 7,2019
PUC l't Set Data Request 2
PIIC Data Request 2
Please provide native copies of all non-confidential and confidential work papers
supporting Rocky Mountain Power's filing, including the work papers supporting
the Direct Testimony and exhibits of Rocky Mountain Power witresses Wilding
and Meredith. Please provide the work papers in Excel format with all links,
including links to other documents, retained. To the extent that the work papers
link to another document, please provide a copy of the other document as well.
Response to PIIC Data Request 2
Native copies of the non-confidential and confidential work papers supporting the
application was provided April 23,2019. Notwithstanding please refer to
Attachment PIIC 2-1 and Confidential Attachment PIIC 2-2.
Confidential information is provided subject to the terms and conditions in the
protective agreement between PIIC and the Company in this proceeding.
Recordholder: Kaley McNay
Sponsor: Not Applicable
2019 ECAM / Rocky Mountain Power
May 7,2019
PIIC l't Set Data Request 3
PIIC Data Request 3
Please provide total-Company actual net power costs detailed on a monthly basis
for calendar years 20 1 5 through 20 I 8. In the response, please include both I ) the
energy supply management database entries and 2) the underlying fuel supply
cost calculations, supporting the actual net power cost report. Please also provide
any mapping necessary to assign the database and fuel accounts to line items in
the actual net power cost report.
Response to PIIC Data Request 3
The Company objects to this request as overly broad and not reasonably
calculated to lead to the discovery of admissible evidence given 2015 through
2017 data is not relevant to the 2019 energy cost adjustment mechanism (ECAM),
which is based on calendar year 2018 data (January l, 2018 through December
31,2018). Notwithstanding and without waiving the foregoing objections, the
Company responds as follows:
Please refer to Attachment PIIC 3-l which provides actual net power costs (NPC)
reports for calendar years 2015 through 2018. Please refer to Confidential
Attachment PIIC 3-2 which contains the actual NPC database entries, along with
their mapping and fuel supply cost calculations for calendar years 2015 through
201 8.
Confidential information is provided subject to terms and conditions of the
protective agreement between PIIC and the Company in this proceeding.
Recordholder: Amie Stevenson
Sponsor: Mike Wilding
2019 ECAM / Rocky Mountain Power
May 7,2019
PIIC I't Set Data Request 4
PIIC Data Request 4
Please provide total-Company actual net power costs in the manner described in
PIIC Request No. 3 but for calendar years 2019 through the most recent month
available. Please update this report and the underlying data on a monthly basis
over the course ofthis proceeding.
Response to PIIC Data Request 4
The Company objects to this request as overly broad and not reasonably
calculated to lead to the discovery of admissible evidence given 2019 data is not
relevant to the 2019 energy cost adjustment mechanism (ECAM), which is based
on calendar year 2018 data (January l, 2018 through December 31, 2018).
Notwithstanding and without waiving the foregoing objections, the Company
responds as follows:
Please refer to Confidential Attachment PIIC 4 which provides the actual net
power costs (NPC) report for calendar year 2019 (January 2019 through March
2019), as well as the actual NPC database entries, along with their mapping and
fuel supply cost calculations for calendar year 2019 (January 2019 through March
20re).
Notwithstanding the afore-stated objections, the Company will supplement the
response to this data request as additional information becomes available.
Confidential information is provided subject to terms and conditions of the
protective agreement between PIIC and the Company in this proceeding.
Recordholder: Amie Stevenson
Sponsor: Mike Wilding
2019 ECAM / Rocky Mountain Power
May7,2019
PIIC I't Set Data Request 5
PIIC Data Request 5
Please provide Rocky Mountain Power's 20 I 8 Idaho results of operations in
Excel format with all links and formulas intact. Please provide this information as
soon as it is available.
Response to PIIC Data Request 5
Please refer to Attachment PIIC 5.
Recordholder: Craig Larsen
Sponsor: Nick Highsmith
2019 ECAM / Rocky Mountain Power
May7,2019
PUC I't Set Data Request 6
PIIC Data Request 6
Please provide any work papers supporting the calculation of line 33 of Wilding
Exhibit No 1, regarding the Unrecovered Deer Creek Mine lnvestment, and please
also provide the amortization schedule for the Deer Creek Mine regulatory asset,
including calculation of the remaining tdaho balance.
Response to PIIC Data Request 6
Please refer to Confidential Attachment PIIC 6. The Deer Creek Mine regulatory
asset was intended to be amortized over 60 months, however due to salvage value
proceeds the net amortization period allocated to Idaho resulted in 47 months.
Confidential information is provided subject to terms and conditions of the
protective agreement between PIIC and the Company in this proceeding.
Recordholder: Amie Stevenson
Sponsor: Mike Wilding
2019 ECAM / Rocky Mountain Power
May 7,2019
PUC I't Set Data Request 7
PIIC Data Request 7
Please discuss how the FAS 106 savings associated with the Deer Creek mine
transaction are being tracked in the Deer Creek Mine regulatory asset and identifu
the total amount of FAS 106 savings recognized, on a total company and Idaho
allocated basis, since the Deer Creek Mine transaction.
Response to PIIC Data Request 7
ln accordance with Order 33304 in Case PAC-E-14-10, the Company is deferring
all Deer Creek mine closure costs, including Financial Accounting Standards
(FAS) 106 savings, and will request Idaho Public Utilities Commission (IPUC)
determination on the treatment of those items in the next general rate case (GRC)
filed by the Company in Idaho. The undepreciated Deer Creek mine investment is
being recovered through the energy cost adjustment mechanism (ECAM) as a
separate line item.
Please refer to Confidential Attachment PIIC 7 for the Company's best estimate
of the annual incremental non-fuel FAS 106 savings. The portion allocated to
Idaho is based on the system overhead (SO) allocation factors from the Idaho
regulatory results of operations (ROO) filed annually by the Company.
Confidential information is provided subject to terms and conditions of the
protective agreement between PIIC and the Company in this proceeding.
Recordholder:Amie Stevenson
Sponsor:Mike Wilding
2019 ECAM / Rocky Mountain Power
May 7,2019
PIIC l't Set Data Request 8
PIIC Data Request 8
Please provide all confidential and non-confidential Energy Balancing Account
(EBA) Filing Requirements and Additional Filing Requirements submitted in
Utah P.S.C Docket 19-035-01.
Response to PIIC Data Request 8
The Company cannot legally disclose the information PIIC seeks pursuant to
applicable Utah laws including Utah Administrative Code R746-l-602 and R746-
1-603 which prohibit the use or disclosure of confidential information other than
for the purpose of the Utah proceeding. Without waiving and notwithstanding the
objection, the public information can be accessed at the link below:
https://psc.utah. eov/20 I 9/0 I /02ldocket-no- I 9-03 5 -0 I /
Recordholder: Yvonne Hogle
Sponsor: To Be Determined
2019 ECAM / Rocky Mountain Power
N'.Iay 7,2019
PIIC I't Set Data Request 9
PIIC Data Request 9
To the extent not included in the EBA filing requirements, please provide the
2018 outage log for each of Rocky Mountain Power's thermal and hydro
resource, including a narrative description f,reld.
Response to PIIC Data Request 9
Please refer to Confidential Attachment PIIC 9
Confidential information is provided subject to terms and conditions in the
protective agreement between PIIC and the Company in this proceeding.
Recordholder: Karl Mortensen / Thomas Hickey
Sponsor: Mike Wilding
2019 ECAM / Rocky Mountain Power
May7,2019
PIIC l't Set Data Request l0
PIIC Data Request 10
Please provide the detailed results of operations for Bridger Coal Company,
supporting the Bridger Coal Company fuel costs that PacifiCorp has included in
the cost of the Jim Bridger power plant for the period.
Response to PIIC Data Request 10
Please refer to the Company's response to IPUC Audit Request l, specifically
Confidential Attachment IPUC Audit I which provides detailed operational
results by month for Bridger Coal Company (BCC) for 2018.
Recordholder: David Webb
Sponsor: Ted Weston