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Home My WebLink About20210716Bayer 35-56 to PAC.pdf.,..=.- .:a;.1.. i-!,r r ti@racineolson conl Attorneysfor Intervenor P4 Production, L.L.C., an ffiliate of Bayer Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Randall C. Budge,ISB No. 1949 Thomas J. Budge,ISB No. 7465 RACINE OLSON, PLLP P.O. Box l39l;2018. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 randy@rac ineolson. com IN THE MATTER OF THE APPLICATION OF'ROCKY MOIINTAIN POWER F'OR AUTHORITY TO INCREASE ITS RATES AND CHARGES IN IDAHO AI\D APPROVAL OF PROPOSED ELECTRIC SERVICE SCITEDULES AND REGULATIONS :,', -i.l- i* FH 1: CS , i-,' CASE NO. PAC-E-2I.07 BAYER CORPORATION'S THIRD DATA REQUESTS TO ROCKY MOI'NTAIN POWER P4 Production, L.L.C., an affiliate of Bayer Corporation (hereinafter "Bayer"), by and through its attomeys, 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 THIRD DATA REQI"JESTS TO ROCKY MOUNTAIN POWER - I Bayer Set 3 Request No.35: Please provide the amount of overtime dollars and overtime hours incurred by RMP for each of the last five years (2016-2020). Request No.36: Please list the employees who are eligible to receive overtime payments and provide the average number of employees eligible for overtime each year from 20t6-2020. Request No.37: Please breakdown the amount of overtime dollars for each of the last five years (2016-2020) by type of overtime paid. For example, time and a half, double time, etc. Request No.38: Please provide RMP's vacation policy including an explanation of the ability to accrue unused leave. Request No. 39: Please describe the types of employees who are legible to accrue leave (unused leave). For each employee group identified, please state whether these employees are salaried or paid by the hour. Request No. 40: Please provide the balance of unused leave accrual atyear end for each of the last five calendar yeils. Request No. 41: Please provide all documentation that explains the different components of RMP's Annual lncentive Plan (AIP). The response should describe the different metrics used to award AIP payments. Request No. 42: Please provide the RMP Bonus and Awards payment balances for the last five years. Request No. 43: For 2020, please provide a detailed description of all actions performed that would qualiff for a bonus or award payment. Request No. 44: In annualizing payroll for wage increases during 2020, did RMP restate payroll, overtime and premium pay to reflect those months in 2020 when the payroll increase was not in effect? Please explain your response. Request No. 45: Is RMP seeking to include payroll increases in cost of service beyond the test year in this case. If so, please provide a detailed explanation of all increases. Request No. 46: Please provide detailed explanation of the negative expense associated with Joint Owners Cutbacks. In the last five years except for 2020, was there a negative expense for this item. If so please provide all negative expenses for the period 2016-2019. Request No. 47: Please provide the percentage of total labor dollars assigned to Non- Utility and Capitalized Labor for the last five years (2016-2020). BAYER CORPORATION',S THIRD DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2 Request No. 48: With respect to the testimony of Craig Eller at page 13, please provide the amount of elapsed time between start-up and full rated capacity output for the following: a. The proposed Naughton SCCT b. A SCCT Frame F c. A SCCT Aero d. An Intercooled SCCT Aero e. The proposed Bayer operating reserve product f. The proposed Bayer economic curtailment product Request No. 49: With respect to the testimony of Craig Eller page 13, please provide the ramp rate in MW per minute for the following: a. The proposed Naughton SCCT b. A SCCT Frame F c. A SCCT Aero d. An Intercooled SCCT Aero e. The proposed Bayer operating reserve product f. The proposed Bayer economic curtailment product Request No. 50: With respect to the testimony of Craig Eller at page 13, please confirm that expected benefits of a SCCT were not netted from the valuation of Bayer's operating reserve product in Commission Order No. 32196 in Case No. PAC-E-10-07. Request No. 51: With respect to the testimony of Craig Eller at page 13, please provide a narrative explanation of the formula used to derive the expected benefits of a SCCT that are netted from the valuation of Bayer's operating reserve product. Request No. 52: With respect to the testimony of Craig Eller at page 13 regarding Bayer's operating reserve product, please provide a narrative explanation of how, on a system operational basis, energy benefits are lost as a result of not installing a SCCT. Request No. 53: With respect to the testimony of Craig Eller at page l3 regarding Bayer's operating reserve product, please describe and quantify the reduced revenue requirement mentioned at line 10. BAYER CORPORATION'S THIRD DATA REQUESTS TO ROCKY MOUNTATN POWER - 3 Request No. 54: With respect to the testimony of Craig Eller at page 15, please confirm that expected benefits of a SCCT were not netted from the valuation of Bayer's economic curtailment product in Commission OrderNo. 32196 in Case No. PAC-E-10-07. Request No. 55: With respect to the testimony of Craig Eller at page 15, please provide a narrative explanation of the formula used to derive the expected benefits of a SCCT that are netted from the valuation of Bayer's economic curtailment product. Request No. 56: With respect to the testimony of Craig Eller at page 15 regarding Bayer's economic curtaihnent product, please provide a narrative explanation of how, on a system operational basis, energy benefits are lost as a result of not installing a SCCT. DATED this l6m day of July,2O2l. RACINE OLSON, PLLP c"By C. BAYER CORPORATION'S THIRD DATA REQIJESTS TO ROCKY MOUNTAIN POWER - 4 CERTIFICATE OF MAILING I FIEREBY CERTIFY that on this 16tr day of July,202l, I caused to be served a true and correct copy of the foregoing document upon the following individuals in the manner indicated below: RACINE OLSON, PLLP By c. RANDALL C. BUDGE Jan Noriyuki 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. eov Ted Weston Idaho Regulatory Affairs Manager Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake city, uT 841l6 ted.weston@oacifi corp.com Data Request Response Center PacifiCorp 825 NE Multnomah St., Suite 2000 Portland, OR97232 datarequest@pacifi corp. corn Dayn Hardie Matt Hunter Attorneys for Commission Staff Deputy Attorneys General Idaho Public Utilities Commission P.O. Box 83720 Boise, Idaho 83720-007 4 Dayn.hardie(@puc. idaho. qov Matt.hunter@puc. idaho. eov Karl Klein Deputy Attorney General Idaho Public Utilities Commission 47 2 W . Washington (83702) PO Box 83720 Boise, lD 83720 karl.klein@puc.idaho. sov Emily L. Wegener Matthew D. McVee Assistant General Counsel Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake city, uT 84116 Enri I y. we g ener @p acifi corp. com Matthew.mcvee@pacifi corp.com BAYER CORPORATION'S THIRD DATA REQUESTS TO ROCKY MOTJNTAIN POWER - 5 Anthony Yankel 12700 Lake Avenue, Unit 2505 Lakewood, Ohio 44107 tony@.yankel.net Bradley Mullins MW Analytics, Energy & Utilities brmulIins@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 Lance Kaufinan Aegis Insight 2623 NW Bluebell Place Corvallis, Oregon 97330 lance@aegi sinsi ght.com Eric L. Olsen Attorney for ldaho Inigation Pumpers Association, Inc. ECHO FIAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6ll9 Pocatello,Idaho 83205 elo@.echohawk.com Ronald L. Williams Attorney for P aci/iCorp ldaho Industrial Customers WILLIAMS BRADBURY, P.C. P.O. Box 388 Boise,ID 83701 ron@williamsbradbury. com PIIC Electronic Service Only: Val Steiner: Val.Steiner@itafos.com Kyle Williams: williamsk@byui.edu Adam Gardner: AGardner@idahoan.com Mike Veile Bayer Corporation P4 Production, L.L.C. P.O. Box 816 Soda Springs, Idaho 83276 mike.veile@bayer.com Kevin C. Higgins Energy Strategies I I I East Broadway, Suite 1200 Salt Lake City, Utah 841I I khi s eins@enersy strat. com Brad M. Purdy Attorney for Community Action P artnership Association of Idaho 2019N. 17th St. Boise,lD. 83702 brnpurdy@hohnail.com BAYER CORPORATION'S THIRD DATA REQUESTS TO ROCKY MOLINTAIN POWER - 6