20210706PAC to Bayer 1-33.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
July 6, 2021 Randall C. Budge/Bayer [e-mail] (C) Thomas J. Budge/Bayer [e-mail] (W)(C) Brian C. Collins/Bayer [e-mail] (W)(C)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer [e-mail] (C) Lance Kaufman/Bayer [e-mail] (C) James R. Smith/Bayer [e-mail] (C)
RE: ID PAC-E-21-07 Bayer Set 1s (1-33) Please find enclosed Rocky Mountain Power’s Responses to Bayer 1st Set Data Requests 1-33. Also provided are Attachments Bayer 25-1, 28, and 31. Provided via encryption is Confidential
Attachment Bayer 25-2. 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 the Non-Disclosure Agreement (NDA) executed in this proceeding. Provided via encryption to Bayer and IPUC only are Customer-Specific Confidential Attachments Bayer 21-1, 21-2, 24, and 32. Customer-Specific Confidential Attachments contain customer-specific information and are considered business confidential. The Company requests special handling which includes destroying or returning customer-specific information within 30 days after the docket is completed. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and
31.01.01.233, the IPUC’s Rules of Procedure No. 67 – Information Exempt from Public Review,
and further subject to the 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.: Jan Noriyuki/IPUC [e-mail] (C) Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail] Adam Gardner/PIIC [e-mail] (W) Kyle Williams/PIIC [e-mail] (W)
RECEIVED
2021July 6, PM 4:44
IDAHO PUBLIC
UTILITIES COMMISSION
Val Steiner/PIIC [e-mail] (W) Eric L. Olsen/IIPA [e-mail] (C) Anthony Yankel/IIPA [e-mail] (C) Ben Otto/ICL [e-mail] (C)

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 1
Bayer Data Request 1 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.
Response to Bayer Data Request 1
Pursuant to Idaho Public Utilities Commission (IPUC) Order 35073 dated June
14, 2021, and IPUC Order 35081 dated June 22, 2021 “IT IS FURTHER ORDERED that all parties in this proceeding serve all papers hereafter filed in this matter on all parties of record”. PacifiCorp is in compliance and will be in compliance with these orders.

Recordholder: Not Applicable Sponsor: Not Applicable

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 2
Bayer Data Request 2 Please provide a copy of your responses to the data requests from Commission Staff and other parties. Please consider this to be a continuing request and
supplement your response as additional requests are received.
Response to Bayer Data Request 2
Please refer to the Company’s response to Bayer Data Request 1.
Recordholder: Not Applicable Sponsor: Not Applicable

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 3
Bayer Data Request 3 Please provide a copy of your responses to requests conveyed to Rocky Mountain Power other than through formal data requests from Commission Staff and other
parties. Please consider this to be a continuing request and supplement your
response as additional requests are received. Response to Bayer Data Request 3 Please refer to the Company’s response to Bayer Data Request 1.
Recordholder: Not Applicable Sponsor: Not Applicable

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 4
Bayer Data Request 4 Please provide a copy of the work papers supporting the testimony of Gary W. Hoogeveen. To the extent that the work papers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Bayer Data Request 4
There are no work papers supporting the direct testimony of Company witness, Gary W. Hoogeveen.
Recordholder: Mark Alder Sponsor: Gary W. Hoogeveen

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 5
Bayer Data Request 5 Please provide a copy of the work papers supporting the testimony of Joelle R. Steward. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 5
There are no work papers supporting the direct testimony of Company witness,
Joelle R. Steward. Recordholder: Mark Alder
Sponsor: Joelle R. Steward

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 6
Bayer Data Request 6 Please provide a copy of the work papers supporting the testimony of Nikki L. Kobliha. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 6
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Nikki L. Kobliha which were provided with the Company’s application and direct testimony. Recordholder: Mark Alder

Sponsor: Nikki L. Kobliha

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 7
Bayer Data Request 7 Please provide a copy of the work papers supporting the testimony of Ann E. Bulkley. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 7
There are no work papers supporting the direct testimony of Company witness,
Ann E. Bulkley. Recordholder: Mark Alder
Sponsor: Ann E. Bulkley

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 8
Bayer Data Request 8 Please provide a copy of the work papers supporting the testimony of Rick T. Link. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 8
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Rick T. Link which were provided with the Company’s application and direct testimony. Recordholder: Mark Alder

Sponsor: Rick T. Link

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 9
Bayer Data Request 9 Please provide a copy of the work papers supporting the testimony of Timothy J. Hemstreet. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 9
There are no work papers supporting the direct testimony of Company witness,
Timothy J. Hemstreet. Recordholder: Mark Alder
Sponsor: Timothy J. Hemstreet

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 10
Bayer Data Request 10 Please provide a copy of the work papers supporting the testimony of Richard A. Vail. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 10
There are no work papers supporting the direct testimony of Company witness,
Richard A. Vail. Recordholder: Mark Alder
Sponsor: Richard A. Vail

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 11
Bayer Data Request 11 Please provide a copy of the work papers supporting the testimony of Robert Van Engelenhoven. To the extent that the work papers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Bayer Data Request 11
There are no work papers supporting the direct testimony of Company witness,
Robert Van Engelenhoven. Recordholder: Mark Alder
Sponsor: Robert Van Engelenhoven

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 12
Bayer Data Request 12 Please provide a copy of the work papers supporting the testimony of James C. Owen. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 12
There are no work papers supporting the direct testimony of Company witness,
James C. Owen. Recordholder: Mark Alder
Sponsor: James C. Owen

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 13
Bayer Data Request 13 Please provide a copy of the work papers supporting the testimony of Craig M. Eller. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 13
Please refer to the work papers supporting the direct testimony of Company
witness, Craig M. Eller which were provided with the Company’s application and direct testimony. Recordholder: Mark Alder

Sponsor: Craig M. Eller

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 14
Bayer Data Request 14 Please provide a copy of the work papers supporting the testimony of Michael G. Wilding. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 14
Please refer to the confidential work papers supporting the direct testimony of
Company witness, Michael G. Wilding which were provided with the Company’s application and direct testimony. Recordholder: Mark Alder

Sponsor: Michael G. Wilding

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 15
Bayer Data Request 15 Please provide a copy of the work papers supporting the testimony of Melissa S. Nottingham. To the extent that the work papers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Bayer Data Request 15
There are no work papers supporting the direct testimony of Company witness,
Melissa S. Nottingham. Recordholder: Mark Alder
Sponsor: Melissa S. Nottingham

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 16
Bayer Data Request 16 Please provide a copy of the work papers supporting the testimony of Steven R. McDougal. To the extent that the work papers include any spreadsheets or
models, please provide in executable native format with all formulas intact.
Response to Bayer Data Request 16
Please refer to the work papers supporting the direct testimony of Company
witness, Steven R. McDougal which were provided with the Company’s application and direct testimony and supplemented with the RAM and JAM on June 23, 2021.
Recordholder: Mark Alder
Sponsor: Steven R. McDougal

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 17
Bayer Data Request 17 Please provide a copy of the work papers supporting the testimony of Robert M. Meredith. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact.
Response to Bayer Data Request 17
Please refer to the work papers supporting the direct testimony of Company
witness, Robert M. Meredith which were provided with the Company’s application and direct testimony. Recordholder: Mark Alder

Sponsor: Robert M. Meredith

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 18
Bayer Data Request 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.
Response to Bayer Data Request 18
The jurisdictional allocation model (JAM) was inadvertently omitted with the
Company’s Application. The JAM was subsequently sent to parties on June 23, 2021. Recordholder: Steve McDougal

Sponsor: Steve McDougal

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 19
Bayer Data Request 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.
Response to Bayer Data Request 19
Please refer to the Company’s response to Bayer Data Request 17.
Recordholder: Robert Meredith Sponsor: Robert Meredith

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 20
Bayer Data Request 20 Please provide a copy of all rate design work papers. To the extent that the work papers include any spreadsheets or models, please provide in executable native
format with all formulas intact.
Response to Bayer Data Request 20
Please refer to the Company’s response to Bayer Data Request 17.
Recordholder: Robert Meredith Sponsor: Robert Meredith

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 21
Bayer Data Request 21 Please provide Bayer’s actual hourly load data for the test year and all adjustments made to that actual hourly load data for purposes of:

• The jurisdictional allocations.
• The class cost of service allocations.
Response to Bayer Data Request 21
• The jurisdictional allocation factors are based on calendar year 2020 load data.

• The class cost of service (COS) allocation factors are based on calendar year 2019 load data, adjusted to 2020 energy and customer count. Please refer to
pages two through five of the direct testimony of Company witness, Robert
M. Meredith. Please refer to Confidential Attachment Bayer 21-1 which provides actual hourly load and the adjusted hourly load for 2019 and 2020. The Company apportioned 2019 monthly weather normalized cycle sales to the 2019 hourly shape for COS
allocations. Please refer to Confidential Attachment Bayer 21-1 for Bayer’s 2020
actual hourly load data informing jurisdiction allocations. Please refer to Confidential Attachment Bayer 21-2 for the adjustments made to actual hourly load for purposes of jurisdictional allocations.

Customer-Specific Confidential Attachment Bayer 24 contains customer-specific information and is considered business confidential. The Company requests special handling which includes destroying or returning customer-specific information within 30 days after the docket is completed. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and
31.01.01.233, the IPUC’s Rules of Procedure No. 67 – Information Exempt from
Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Lee Elder / Nick Highsmith Sponsor: Steve McDougal / Robert Meredith
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 22
Bayer Data Request 22 If not provided in response to other data requests, please provide all work papers and supporting data showing the derivation of each external allocation factor for
the jurisdictional allocation model.
Response to Bayer Data Request 22
Please refer to the Company’s response to Bayer Data Requests 16 and 18.
Recordholder: Steve McDougal Sponsor: Steve McDougal

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 23
Bayer Data Request 23 If not provided in response to other data requests, please provide all work papers and supporting data showing the derivation of each external allocation factor for
the class cost of service allocation model.
Response to Bayer Data Request 23
Please refer to the Company’s response to Bayer Data Request 17.
Recordholder: Robert Meredith Sponsor: Robert Meredth

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 24
Bayer Data Request 24 Please provide a history of all curtailments and/or interruptions made to Bayer load for the years 2010 through 2020, inclusive. Please detail the time and date of
the curtailment or interruption, the amount in MW and reason (economic
curtailment, operating reserves, system integrity, etc.). Please provide in Excel format.
Response to Bayer Data Request 24
The requested information is customer specific confidential information. The Company requests special handling. Please refer to Customer-Specific Confidential Attachment Bayer 24 which
provides the available curtailment and / or interruptions information associated
with Monsanto / Bayer / P4. The requested information is being provided only to the Idaho Public Utilities Commission (IPUC) and the requester / customer, Bayer.

Customer-Specific Confidential Attachment Bayer 24 contains customer-specific information and is considered business confidential. The Company requests special handling which includes destroying or returning customer-specific information within 30 days after the docket is completed. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and
31.01.01.233, the IPUC’s Rules of Procedure No. 67 – Information Exempt from
Public Review, and further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Samuel Cope / Tony Worthington Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 25
Bayer Data Request 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.
Response to Bayer Data Request 25 Please refer to Attachment Bayer 25-1 and Confidential Attachment Bayer 25-2
which provide copies of the Company’s exhibits in Microsoft Excel format. where
available. 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 the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Mark Alder

Sponsor: Ted Weston
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 26
Bayer Data Request 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.
Response to Bayer Data Request 26
Bayer is a firm retail customer that contracts to provide ancillary services to the
Company. As such, Bayer qualifies as a “Special Contract with Customer Ancillary Service Attributes” as defined in the 2020 Protocol, which Bayer is a signatory to and was approved by the Idaho Public Utilities Commission (IPUC): “For allocation purposes, Special Contracts with Customer
Ancillary Service attributes are viewed as two transactions.
PacifiCorp sells the customer electricity at the retail service rate and then buys the electricity back during the interruption period at the Customer Ancillary Service Contract’s rate.

Loads of Special Contract customers will be included in all Load-Based Dynamic Allocation Factors. When interruptions of a Special Contract customer’s service occur, the host jurisdiction’s Load-Based Dynamic Allocation Factors
and the retail service revenue are calculated as though the
interruption did not occur.” In Case No. PAC-E-10-07, Monsanto contended a proper valuation of their
curtailment should reflect the avoidance of capacity and energy. Without a
valuation of Monsanto’s interruptibility, the cost of service (COS) study results provided by the Company and treatment of Monsanto's load as "all firm", it stated, are incomplete. The IPUC did not accept Monsanto’s argument. In its order, the Commission
acknowledged the Company's COS study as reasonable and recognized its use in
the Revised Protocol and the use of the study in prior Company rate cases. The IPUC denied Monsanto’s position stating: “We find no reason to abandon its use despite the recommendations of other parties”. Recordholder: Steve McDougal Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 27
Bayer Data Request 27 Please provide a copy of the most recent contract Rocky Mountain Power has with Nucor, including the interruptibility provisions, as well as Nucor’s
interruption history for the years 2010 through 2020, inclusive.
Response to Bayer Data Request 27
The Company objects to this data request on the grounds that it seeks confidential,
customer specific information of PacifiCorp customer, Nucor Steel-Utah, a division of Nucor Corporation (Nucor). The Company will provide the requested customer specific information only if P4 Production, L.L.C., an affiliate of Bayer Corporation (Bayer) / Bayer can provide explicit written permission from Nucor to release the information.

Recordholder: Counsel
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 28
Bayer Data Request 28 Please explain how Nucor’s interruptible 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.
Response to Bayer Data Request 28
The Company objects to this data request on the grounds that it seeks confidential,
customer specific information of PacifiCorp customer, Nucor Steel-Utah, a division of Nucor Corporation (Nucor). The Company will provide the requested customer specific information only if P4 Production, L.L.C., an affiliate of Bayer Corporation (Bayer) / Bayer can provide explicit written permission from Nucor to release the information. Subject to and without waiving any objection, the
Company provides the following non-confidential information:
Nucor load has been treated as a Special Contract with Customer Ancillary Service Attributes as defined in Appendix G (Special Contracts) of the 2020
Protocol.
Please refer to Attachment Bayer 28 which provides a copy of the 2020 Protocol (pursuant to Case PAC-E-19-20). Specifically refer to the sections related to “special contracts”, and Appendix G (Special Contracts) for the treatment of special contracts pursuant to the 2020 Protocol and the calculation of
jurisdictional allocation factors. The 2020 Protocol was approved by the Idaho
Public Utilities Commission (IPUC) in its Final Order 34640 issued April 22, 2020.

Recordholder: Steve McDougal Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 29
Bayer Data Request 29 Please provide a copy of the most recent interruptible contract Rocky Mountain Power has with Magcorp, including the interruptibility provisions, as well as
Magcorp’s interruption history for the years 2010 through 2020, inclusive. Response to Bayer Data Request 29
The Company objects to this data request on the grounds that it seeks confidential,
customer specific information of PacifiCorp customer, US Magnesium LLC (US Magnesium). The Company will provide the requested customer specific information only if P4 Production, L.L.C., an affiliate of Bayer Corporation (Bayer) / Bayer can provide explicit written permission from US Magnesium to release the information.

Recordholder: Counsel
Sponsor: To Be Determined

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 30
Bayer Data Request 30 Please explain how Magcorp’s interruptible 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.
Response to Bayer Data Request 30
The Company objects to this data request on the grounds that it seeks confidential,
customer specific information of PacifiCorp customer, US Magnesium LLC (US Magnesium). The Company will provide the requested customer specific information only if P4 Production, L.L.C., an affiliate of Bayer Corporation (Bayer) / Bayer can provide explicit written permission from US Magnesium to release the information. Subject to and without waiving any objection, the
Company provides the following non-confidential information:
US Magnesium’s load has been treated as a Special Contract with Customer Ancillary Service Attributes as defined in Appendix G (Special Contracts) of the
2020 Protocol.
Please refer to the Company’s response to Bayer Data Request 28, specifically Attachment Bayer 28 which provides a copy of the 2020 Protocol (pursuant to Case PAC-E-19-20). Specifically refer to the sections related to “special contracts”, and Appendix G (Special Contracts) for the treatment of special
contracts pursuant to the 2020 Protocol and the calculation of jurisdictional
allocation factors. The 2020 Protocol was approved by the Idaho Public Utilities Commission (IPUC) in its Final Order 34640 issued April 22, 2020.

Recordholder: Steve McDougal Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 31
Bayer Data Request 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.

Coincident
Provide the hour in 0100-2400 Mountain Prevailing Time basis and indicate what hour is represented by clock time 8AM-9AM for reference. Response to Bayer Data Request 31 The Company assumes that the reference to the “past 5 years” is intended to be a
reference to calendar years 2016 through 2020. Based on the foregoing
assumption, the Company responds as follows: Please refer to Attachment Bayer 31 which provides PacifiCorp’s system monthly peak and energy data, and the state jurisdictional contributions, for calendar years 2016 through 2020, including day, month and hour. The information provided is
in megawatts (MW) and megawatt-hours (MWh). Recordholder: David Novom

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 32
Bayer Data Request 32 Please provide the Bayer load during the same period in response to Request No. 30 by hour for the 5-year period and in the same format.
Response to Bayer Data Request 32 The requested information is customer specific confidential information. The
Company requests special handling.
The Company assumes that the reference to “Request No. 30” is intended to be a reference to Bayer Data Request 31. The Company further assumes that the reference to “the 5-year period” is intended to be a reference to calendar years 2016 through 2020. Based on the foregoing assumptions, the Company responds
as follows:
Please refer to Customer-Specific Confidential Attachment Bayer 32 which provides Bayer’s load during the system monthly coincident peaks (CP) in
calendar years 2016 through 2020. The requested information is being provided
only to the Idaho Public Utilities Commission (IPUC) and the requester / customer, Bayer. Customer-Specific Confidential Attachment Bayer 32 contains customer-specific information and is considered business confidential. The Company requests
special handling which includes destroying or returning customer-specific
information within 30 days after the docket is completed. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the IPUC’s Rules of Procedure No. 67 – Information Exempt from
Public Review, and further subject to the Non-Disclosure Agreement (NDA)
executed in this proceeding. Recordholder: Travis Walker / Lee Elder
Sponsor: Steve McDougal

PAC-E-21-07 / Rocky Mountain Power July 6, 2021 Bayer Data Request 33
Bayer Data Request 33 Please provide the jurisdictional allocation model with Bayer load at zero 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
Idaho.
Response to Bayer Data Request 33 The Company objects to this request on the grounds that it is unduly burdensome, speculative, and would require the Company to make unsupported assumptions.
The Company has not performed the requested analysis. To perform the requested
calculation, the Company would need to make broad and unsupported assumptions related to the impact this would have on items such as, but not limited to, net power costs (NPC).

Recordholder: Nicholas Highsmith Sponsor: Steve McDougal