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Home My WebLink About20210615Bayer 1-33 to PAC.pdfRandall C. Budge,ISB No. 1949 Thomas J. Budge,ISB No. 7465 RACINE OLSON, PLLP P.O. Box l39l;201E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 randy@racineolson. com tj@racineolson.com IN THE MATTER OF THE APPLICATION OF ROCKY MOT]NTAIN POWER FOR AUTHORITY TO INCREASE ITS RATES AIYD CHARGES IN IDAHO AI\ID APPROVAL OF PROPOSED ELECTRIC SERVICE SCHEDI'LES AIYD REGI]LATIONS ,:: -; -,,,i i 5 Pl{ ffi, I 2 .,': r. '-. ,,_ ...i,*]-,': i:,:;,:. ij+_:rll'jriiS$i0li Attorneysfor Intervenor P4 Production, L.L.C., an afiliate of Bayer Corporation BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. PAC-E-2I.07 BAYER CORPORATION'S CORRECTED FIRST DATA REQITESTS TO ROCKY MOUNTAIN POWER P4 Production, L.L.C., an affiliate of Bayer Corporation (hereinafter "Bayer"), by and through its attorneys, hereby submits this First Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility Commission's Rules of Procedure, IDAPA 31.01.01. This Data Request is to be considered continuing, and Rocky Mountain Power is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents or information produced. Please provide answers to each question, supporting workpapers that provide detail or are the source of information used in calculations, and the name, job title and telephone number of the person preparing the documents. Please identiff the name, job title, location and telephone number of the record holder. In addition to the written copies provided as response to the requests, please provide all Excel and electronic files on CD with formulas activated. BAYER CORPORATION'S CORRECTED FIRST DATA REQTJESTS TO ROCKY MOLJNTAIN POWER.I Bayer Set I Request No. l: Please provide a copy of all data requests received from Commission Staff and other parties. Please consider this to be a continuing request and supplement your response as additional requests are received. Request No. 2: Please provide a copy of your responses to the data requests from Commission Staff and otherparties. Please considerthis to be acontinuing request and supplement your response as additional requests are received. Request No. 3: Please provide a copy of your responses to requests conveyed to Rocky Mountain Power other than through formal data requests from Commission Staffand other parties. Please consider this to be a continuing request and supplement your response as additional requests are received. Request No.4: Please provide a copy ofthe workpapers supporting the testimony of Gary W. Hoogeveen. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 5: Please provide a copy of the workpapers supporting the testimony of Joelle R. Steward. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 6: Please provide a copy of the workpapers supporting the testimony ofNikki L. Kobliha. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 7: Please provide a copy of the workpapers supporting the testimony of Ann E. Bulkley. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 8: Please provide a copy of the workpapers supporting the testimony of Rick T. Link. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 9: Please provide a copy of the workpapers supporting the testimony of Timothy J. Hemstreet. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 10: Please provide a copy of the workpapers supporting the testimony of fuchard A. Vail. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 11: Please provide a copy of the workpapers supporting the testimony of Robert Van Engelenhoven. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. BAYER CORPORATION'S CORRECTED FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER. 2 Request No. 12: Please provide a copy of the workpapers supporting the testimony of James C. Owen. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 13: Please provide a copy of the workpapers supporting the testimony of Craig M. Eller. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 14: Please provide a copy of the workpapers supporting the testimony of Michael G. Wilding. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 15: Please provide a copy of the workpapers supporting the testimony of Melissa S. Nottingham. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 16: Please provide a copy of the workpapers supporting the testimony of Steven R. McDougal. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 17: Please provide a copy of the workpapers supporting the testimony of Robert M. Meredith. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 18: If not included in the responses to other data requests, please provide the jurisdictional allocation model ("JAM") in executable native format with all formulas intact. Request No. 19: If not included in the responses to other data requests, please provide the class cost of service allocation model in executable native format with all formulas intact. Request No. 20: Please provide a copy of all rate design workpapers. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact. Request No. 21: Please provide Bayer's actual hourly load data for the test year and all adjustrnents made to that actual hourly load data for purposes of: The jurisdictional allocations. The class cost of service allocations. Request No. 22: If not provided in response to other data requests, please provide all workpapers and supporting data showing the derivation of each extemal allocation factor for the jurisdictional allocation model. BAYER CORPORATION'S CORRECTED FIRST DATA REQUESTS TO ROCKY MOT'NTAIN POWER. 3 Request No. 23: If not provided in response to other data requests, please provide all workpapers and supporting data showing the derivation of each external allocation factor for the class cost of service allocation model. Request No. 24: Please provide a history of all curtailments and/or intemrptions made to Bayer load for the years 2010 through2020, inclusive. Please detail the time and date of the curtailment or intemrption, the amount in MW and reason (economic curtailment, operating reserves, system integrity, etc.). Please provide in Excel format. Request No. 25: If not provided in response to other data requests, please provide all pre-filed exhibits in executable native format with all formulas intact, where available. Request No. 26: Please fully explain the basis upon which Rocky Mountain Power determines that Bayer's entire load should be treated as firm in this rate case filing for the allocation of jurisdictional costs. Request No. 27: Please provide a copy of the most recent contract Rocky Mountain Power has with Nucor, including the intemrptibility provisions, as well as Nucor's intemrption history for the years 2010 through 2020, inclusive. Request No. 28: Please explain how Nucor's intemrptible load has been treated for purposes of the jurisdictional allocation model and provide Nucor's 12 monthly coincident peaks included in the Utah jurisdiction of the JAM study used in this filing. Request No. 29: Please provide a copy of the most recent intemrptible contract Rocky Mountain Power has with Magcorp, including the intemrptibility provisions, as well as Magcorp's intemrption history for the years 2010 through 2020, inclusive. Request No. 30: Please explain how Magcorp's intemrptible load has been treated for purposes of the jurisdictional allocation model, and provide Magcorp's 12 monthly coincident peaks included in the Utah jurisdiction of the JAM study. Request No. 31: Please provide the PacifiCorp system coincident peak load by hour for the past 5 years in which data is available. In the response, please provide the date, the hour as defined below, and the system coincident peak load total for each hour in an Excel spreadsheet. Please use the format as shown below for providing the response in Excel format. Year Month Day Hour System Coincident Load vvvv film dd 0100 MW Ilrm dd 0200 MW Yyyy mm dd 0300 etc MW Provide the hour in 0100-2400 Mountain Prevailing Time basis and indicate what hour is BAYER CORPORATION'S CORRECTED FIRST DATA REQTJESTS TO ROCKY MOLTNTAIN POWER - 4 represented by clock time 8AM-9AM for reference. Request No. 32: Please provide the Bayer load during the same period in response to Request No. 30 by hour for the S-year period and in the same format. Request No. 33: Please provide the jurisdictional allocation model with Bayer loadatzero during the system 6 CP for cost allocation. For the 6 CP, use the specific months of June, July, August, September, December and January based on the filed allocation assumptions remaining the same except for the Bayer load dropped to zero during the system coincident peaks. Please provide the cost difference in allocation to Idaho under those conditions compared to the filed rate case cost allocation to ldaho. DATED this 15m day of June,2O2l. RACINE OLSON, PLLP By c. RANDALL C. BUDGE BAYER CORPORATION'S CORRECTED FIRST DATA REQI.'ESTS TO ROCKY MOUNTAIN POWER.5 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this l5s day of June,202l,l caused to be served a true and correct electronic copy of the foregoing document upon the following individuals in the manner indicated below: RACINE OLSON, PLLP By:AL,' RANDALL C. BUDGE Jan Norkyuki Commission Secretary Idaho Public Utilities Commission P.O. Box 83720, Boise lD 83720-0074 11331 W. Chinden Blvd, Bldg. 8, Suite 201-A Boise,ID 83714 Jan.noriyuki@puc. idaho. qov Ted Weston Idaho Regulatory Affairs Manager Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, UT 841l6 ted. we sto n @pac i f-r corp. c oni Data Request Response Center PacifiCorp 825 NE Multnomah St., Suite 2000 Portland, OR97232 datareq u est @pac i f-r c orp. c onl Anthony Yankel 12700 Lake Avenue, Unit 2505 Lakewood, Ohio 44107 tony@yankel.net Karl Klein Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) PO Box 83720 Boise,ID 83720 karl.klein@puc. idaho. gov Emily L. Wegener Matthew D. McVee Assistant General Counsel Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, UT 84116 Emily.we gener@pacifi corp.com Matthew.mcvee@pacifi com.com Eric L. Olsen Attorney for ldaho Irrigation Pumper s Association, Inc. ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello,Idaho 83205 elo@echohawk.com Ronald L. Williams Attorney for P acifiC orp ldaho Industrial Customers WILLIAMS BRADBURY, P.C. P.O. Box 388 Boise,ID 83701 ron@williarnsbradbury.com BAYER CORPORATION'S CORRECTED FIRST DATA REQUESTS TO ROCKY MOI.JNTAIN POWER - 6 Bradley Mullins MW Analytics, Energy & Utilities brmullins@mwanalytics. com James R. Smith Bayer Corporation P4 Production, L.L.C. 371 S. 3rd West Soda Springs, Idaho 83276 i im.r. smith@icloud.com Brian C. Collins Maurice Brubaker Brubaker & Associates 16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017 bcollins@consultbai.com mbrubaker@ consultbai. com PIIC Electronic Service Only: Val Steiner: Val. Steiner@.itafos.com Kyle Williams: williamsk@byui.edu Adaur Gardner: AGardner@idahoan. com Mike Veile Bayer Corporation P4 Production, L.L.C. P.O. Box 816 Soda Springs, Idaho 8327 6 mike.veile@bayer.com Kevin C. Higgins Energy Strategies I I I East Broadway, Suite 1200 Salt Lake City, Utah 841I I khiegins@energystrat.com Lance Kaufrnan Aegis Insight 2623 NW Bluebell Place Corvallis, Oregon 97330 lance@ae gisinsi ght.com BAYER CORPORATION'S CORRECTED FIRST DATA REQIJESTS TO ROCKY MOI'NTAIN POWER - 7