20210406PAC to Staff 3-6.pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
April 6,2021
Jan Noriyuki
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702-5918
¡an.noriyuki puc.idaho.cov (C)
RE:ID PAC-E-21-01
IPUC Set 2 (3-6)
Please find enclosed Rocky Mountain Power's Responsesto IPUC 2""Set Data Requests 3-6.Also provided is Attachment IPUC 4-1.Provided via encryption are ConfidentialAttachmentsIPUC4,42,4-3,5-1,and 5-2.Confidential information is provided subject to protected under
IDAPA 31.01.01.067 and 31.01.01.233,the Idaho Public Utilities Commission's Rules of
Procedure No.67 -Information Exempt from Public Review,and further subject to any
subsequent Non-Disclosure Agreement (NDA)executed in this proceeding.
If you have any questions,please feel free to call me at [phone].
Sincerely,
/s/
J.Ted Weston
Manager,Regulation
Enclosures
C.c.:Eric L.Olsen/IIPA elo echohawk.com
Anthony Yankel/IIPA tonv vankeLnet
PA C-E-2 1-0 1 /Rocky Mountain Power
April 6,2021
IPUC Data Request 3
IPUC Data Request 3
Please provide all work papers in Excel format with all formulae enabled used in
the economic analysis provided in Hemstreet Exhibit No.3.Please also include
the following:
(a)A detailed description of each work paper and how it was used in the study.
(b)The Relicense FERC Alternative and Final Settlement Alternative scenario
files used in the analysis.A list of all the assumptions and inputs included in
each alternative scenario,and a summary of the parameters that were changed
for each alternative scenario performed.
Response to IPUC Data Request 3
Please refer to Confidential Attachment IPUC 3 which provides the preliminary
economic analysis (PEA)files supporting the Direct Testimony of Company
witness,Timothy J.Hemstreet,specifically Exhibit No.3.
These PEA files are structured so that file "PEA Klamath-
FERCRelicensing_Settlement 20100201 CONF"provides the assumed
protection,mitigation and enhancement measures ("PM&E")and calculates the
required costs for each facility associated with these measures under either the
scenario of relicensing the project under the likely terms and conditions of a new
license based on the Federal Energy Regulatory Commission (FERC)Final
Environmental Impact Statement (FEIS)relicensing scenario (see tab "Sl -FERC
Relicensing"),or the scenario of implementing the Klamath Hydroelectric
Settlement Agreement (see tab "S2 -Final Settlement").The cost estimates and
assumptions for each of the PM&E measures at specific facilities and for various
categories of improvements are detailed on subsequent tabs within the above
referenced file.This file provides the estimated costs associated with various
facilities improvements and associated operations and maintenance (O&M)costs,
as well as the estimated impacts to project generation.
The other two files provided in Confidential Attachment IPUC 3,"PEA
FA1 Klamath-2009P44R-FinalSettlement-FA1 CONF"and "PEA
FA2 Klamath-2009P44R-FinalSettlement-FA2¯CONF"
are the financial analysis
models of the two scenarios.These files are structurally identical and include a
variety of inputs and assumptions including income tax rates,inflation rates,
market power prices,capital and O&M costs for project operations and license or
settlement implementation measures,capacity,project generation in megawatt-
hours (MWh),peak and off-peak production,etc.The different assumptions for
the models are summarized in the "Sl -FERC Relicensing"and "S2 -Final
Settlement"tabs of the "PEA Klamath-
FERCRelicensing_Settlement 20100201 CONF"file.
PAC-E-21-01 /Rocky Mountain Power
April 6,2021
IPUC Data Request 3
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,the Idaho Public Utilities Commission's Rules of
Procedure No.67 -Information Exempt from Public Review,and further subject
to any subsequentNon-Disclosure Agreement (NDA)executed in this proceeding.
Recordholder:Timothy J.Hemstreet
Sponsor:Timothy J.Hemstreet
PA C-E-2 1-0 1 /Rocky Mountain Power
April 6,2021
IPUC Data Request 4
IPUC Data Request 4
Regarding the Company's response to Production Request No.1,please provide
in Excel format a detailed list of all expenses the Company currently has deferred
to the regulatoryasset for relicensing costs.Please include vendor name,invoice
number,invoice amount,invoice date,payment date,and a brief description of the
expense.
Response to IPUC Data Request 4
Please refer to Attachment IPUC 4-1 which provides a summary of the Klamath
relicensing and settlement process costs.Particular invoices and certain details
associated therewith have not been retained for the periods in question in
accordance with the Company's records retention policy.
Please refer to Confidential Attachment IPUC 4-2 and ConfidentialAttachment
IPUC 4-3 which provide a detailed listing of the Klamath relicensing and
settlement process costs,as well as information regarding outside contracts /
vendors.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,the Idaho Public Utilities Commission's Rules of
Procedure No.67 -Information Exempt from Public Review,and further subject
to any subsequentNon-Disclosure Agreement (NDA)executed in this proceeding.
Recordholder:Demian Ebert
Sponsor:Timothy J.Hemstreet
PAC-E-21-01 /Rocky Mountain Power
April 6,2021
IPUC Data Request 5
IPUC Data Request 5
Regarding the Company's responseto Production Request No.2,please provide
any and all documentation supporting the necessity of any planned capital
expenditures for 2022 and beyond.
Response to IPUC Data Request 5
Please refer to ConfidentialAttachment IPUC 5-1 and ConfidentialAttachment
IPUC 5-2 for support for the planned capital expenditures for 2022 and beyond.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,the Idaho Public Utilities Commission's Rules of
Procedure No.67 -Information Exempt from Public Review,and further subject
to any subsequent Non-Disclosure Agreement (NDA)executed in this proceeding.
Recordholder:Gary Tawwater
Sponsor:Timothy J.Hemstreet
PA C-E-2 1-0 1 /Rocky Mountain Power
April 6,2021
IPUC Data Request 6
IPUC Data Request 6
Please identify the entity responsible to pay for any capital expenditures for the
Lower Klamath Project after approval of transfer to Klamath River Renewal
Corporation.
Response to IPUC Data Request 6
PacifiCorp will continue to be responsible for capital expenditures for the Lower
Klamath Project up until the time the facilities are decommissioned (disconnected
from the electric grid)and during the period that the facilities are still being
operated for the benefit of PacifiCorp's customers,consistent with Section 7.1.6
of the Klamath Hydroelectric Settlement Agreement (KHSA),as amended.
Recordholder:Timothy J.Hemstreet
Sponsor:Timothy J.Hemstreet