20210722Bayer 57-62 to PAC Corrected.pdf

BAYER CORPORATION’S FOURTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 1
Randall C. Budge, ISB No. 1949 Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: [phone] Fax: [phone]
[e-mail]
[e-mail] Attorneys for Intervenor P4 Production, L.L.C., an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES IN IDAHO AND APPROVAL OF PROPOSED ELECTRIC SERVICE SCHEDULES AND REGULATIONS
CASE NO. PAC-E-21-07 BAYER CORPORATION’S FOURTH DATA REQUESTS TO ROCKY MOUNTAIN POWER (Corrected)
P4 Production, L.L.C., an affiliate of Bayer Corporation (hereinafter “Bayer”), by and
through its attorneys, hereby submits this Fifth 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 identify 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.

RECEIVED
2021 July 22, PM 6:29
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER CORPORATION’S FOURTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2
Bayer Set 5
Request No. 57: Customer Service Deposits. Please refer to Mr. McDougal’s
Exhibit No. 40 (Results of Operations), page 2.28. a. Please explain why the entries corresponding to Customer Service Deposits (lines 2145-2148)
are zero. b. Please compare these entries to the comparable entries in Exhibit RMP__(SRM-3), page 2.29, lines 2164-2167, in Utah Docket No. 20-034-04. In the Utah docket, $16.3 million of Customer Service Deposits are adjusted into the 2021 test period as a credit against rate base. Please explain in detail why there is no analogous adjustment for Idaho and provide any documentation and workpapers supporting such explanation. c. Please provide the actual (if available) or projected monthly balance of Idaho Customer Service Deposits for each month from December 2019 to December 2021. Please indicate whether each amount provided represents an actual or projected balance.
d. Please provide the actual (if available) or projected monthly Idaho interest expense on Customer Service Deposits for each month from January 2020 to December 2021. Please
indicate whether each amount provided represents an actual or projected amount. Request No. 58: Employee count. Please provide the actual full time equivalent (FTE)
employee count by month, beginning in January 2017 and continuing through the most recent date available. In this response, please indicate the day of the month to which the FTE counts correspond (e.g., 1st of the month, last day of the month, etc.). Please supplement this response as new information becomes available during the pendency of this case. Request No. 59: Employee count. Please confirm that the Company’s test period labor expenses are effectively based on the average full time equivalent employee count for the base period ended December 31, 2020. If not, please indicate the time period corresponding to the employee count upon which test period labor expenses are based. Request No. 60: Employee count. Please indicate whether the Company has made any
adjustments to the base period to reflect known and measurable changes that include changes to the number of employees. If so, please explain and cite to the adjustment(s) in the Company’s filing.
Request No. 61: Annual Incentive Plan. Please provide a copy of the Annual Incentive Plan documents for each year 2018 through 2020, and if available, 2021.
Request No. 62: Annual Incentive Plan. Please provide the PacifiCorp Scorecards applicable to the Annual Incentive Plan for each year 2018 through 2020, and if available, 2021.
DATED this 22st day of July, 2021.

BAYER CORPORATION’S FOURTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 3
RACINE OLSON, PLLP

By: ___________________________ RANDALL C. BUDGE
BAYER CORPORATION’S FOURTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 22st day of July, 2021, 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: ___________________________ RANDALL C. BUDGE

Commission Secretary Idaho Public Utilities Commission P.O. Box 83720, Boise ID 83720-0074
11331 W. Chinden Blvd, Bldg. 8, Suite 201-A
Boise, ID 83714 [e-mail]
Matt Hunter Attorneys for Commission Staff Deputy Attorneys General
Idaho Public Utilities Commission
P.O. Box 83720 Boise, Idaho 83720-0074 [e-mail] [e-mail]
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330 Salt Lake City, UT 84116 [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702) PO Box 83720 Boise, ID 83720 [e-mail]
PacifiCorp 825 NE Multnomah St., Suite 2000 Portland, OR 97232
[e-mail]
Matthew D. McVee Assistant General Counsel Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116 [e-mail] [e-mail]
BAYER CORPORATION’S FOURTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 5
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Attorney for Idaho Irrigation Pumpers
Association, Inc.
ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205
[e-mail]
MW Analytics, Energy & Utilities [e-mail] Attorney for PacifiCorp Idaho Industrial Customers
WILLIAMS BRADBURY, P.C.
P.O. Box 388 Boise, ID 83701 [e-mail]
Bayer Corporation P4 Production, L.L.C. 371 S. 3rd West Soda Springs, Idaho 83276
[e-mail]
Val Steiner: [e-mail] Kyle Williams: [e-mail] Adam Gardner: [e-mail]

Maurice Brubaker Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017 [e-mail] [e-mail]
Bayer Corporation P4 Production, L.L.C.
P.O. Box 816
Soda Springs, Idaho 83276 [e-mail]
Aegis Insight 2623 NW Bluebell Place Corvallis, Oregon 97330 [e-mail]
Energy Strategies 111 East Broadway, Suite 1200 Salt Lake City, Utah 84111 [e-mail]
Attorney for Community Action Partnership Association of Idaho 2019N. 17ᵗʰ St.
Boise, ID. 83702