20210722Bayer 63-80 to PAC Corrected.pdf

BAYER CORPORATION’S FIFTH 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 FIFTH 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 FIFTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2
Bayer Set 4
Request No. 63: Test Period. Please confirm that the test period approved in RMP’s
most recent general rate cases in Utah and Wyoming utilized a 2021 test period with a 13-month average rate base. If RMP disagrees please explain in detail the basis for the disagreement. Request No. 64: Test period. Please prepare and provide a complete set of Idaho
revenue requirement models, adjustments, and workpapers, comparable in all respects to RMP’s
as-filed models/workpapers used to produce RMP witness Steven R. McDougal’s Exhibit No. 40, but that reflects a 13-month average rate base amount for 2021. In preparing these revenue requirement models, please do not reflect any annualizations for any adjustments with changes occurring during the 2021 calendar year, including any post-2020 capital additions. Please
provide the models/workpapers in Excel format with formulas intact.
Request No. 65: Accumulated Depreciation/Amortization Reserve. Is RMP adjusting the accumulated depreciation/amortization reserve for existing plant in the base period to reflect year-end 2021 balances? If not, please explain why RMP didn’t reflect year-end 2021
balances and identify the time period RMP is proposing for this reserve balance in its filing. If
so, please provide a workpaper in Excel format that rolls forward the year-end 2020 reserve balances to year-end 2021 balances and the location within RMP’s adjustments where each of the roll forward adjustments are located.
Request No. 66: Adjustment 8.15 – New Wind and Repowering Capital Addition.
In the CONFIDENTIAL 8.15 exhibit file, the values on p. 8.15.1 appear to show the calendar year 2020 gross plant in service capital additions for each resource. Please confirm that RMP’s proposed depreciation expense adjustment is intended to derive an annualized depreciation expense at the 2013 depreciation rates for each resource. In addition, please explain why RMP
did not also reflect the incremental depreciation expense in accumulated depreciation.
Request No. 67: Adjustment 8.15 – New Wind and Repowering Capital Addition. In the CONFIDENTIAL 8.15 exhibit file, the values on p. 8.15.2 appear to show the calendar year 2021 gross plant-in-service capital additions. Please confirm that RMP is reflecting a 2021
end-of-period plant in service balance for each project (in addition to the 2020 end of period
balances). For each new or repowered wind project and related transmission, please provide a workpaper deriving the 13-month average balance for 2021 for gross plant, accumulated depreciation, and accumulated deferred income taxes. Please reconcile any differences with the rate base amounts included in RMP’s filing.
Request No. 68: Adjustment 8.15 – New Wind and Repowering Capital Addition. For any new wind or repowered wind plant in which some portion of the plant has an in-service date during calendar year 2021 (e.g. Pryor Mountain, TB Flats, etc.), please provide a monthly breakdown of the capital additions for each phase of the plant addition. As part of this response,
please include the pro forma monthly depreciation expense, accumulated depreciation, and
accumulated deferred income taxes for each phase of each plant. If there is any difference from the amounts included in RMP’s filing, please reconcile the difference with the requested amount in the filing.
BAYER CORPORATION’S FIFTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 3
Request No. 69: Adjustment 8.15 – New Wind and Repowering Capital Addition.
For any new wind or repowered wind plant in which some portion of the plant has an in-service
date during calendar year 2021 (e.g. Pryor Mountain, TB Flats, etc.), please explain whether or not the O&M expense amounts shown on p. 8.15.3 are annualized amounts or amounts based upon the various in-service dates for the plant. As part of this response, please include the pro-forma 2021 monthly O&M expense for each phase of each plant. In addition, please describe the
impact, if any, that the various 2021 in-service dates have on the requested O&M expense.
Request No. 70: Pryor Mountain. Please separately identify each revenue requirement component (e.g., rate base, expense, PTCs, REC revenue) associated with Pryor Mountain plant (broken out for each phase of the plant) in the revenue requirement models on both a Total
Company and Idaho jurisdictional basis. In addition, please identify the location within RMP’s
workpapers where the amounts for each of these revenue requirement items are located. Using each of the identified Idaho amounts, please provide the revenue requirement for the Pryor Mountain plant separately for each phase included in the test period in Excel format with formulas intact.
Request No. 71: Pryor Mountain. RMP’s annualized costs of the Pryor Mountain project appear to be spread throughout RMP’s revenue requirement models and not separately identified in the models. a. Please provide the non-annualized test period revenue requirement for the Pryor
Mountain project (using RMP’s forecasted 2021 in-service dates for certain portions of the
project) in Excel format with formulas intact associated with each phase of the project. For rate base items, please use a 13-month average for a 2021 test period. In deriving the revenue requirement, please use a format comparable to RMP’s response to the previous data request. b. Please include a workpaper showing the monthly amount associated with non-
annualized revenue requirement component in Excel format with formulas intact.
c. Please provide the monthly incremental MWh energy production associated with each phase of the Pryor Mountain project for the test period using its forecasted in-service date. Request No. 72: TB Flats. Please separately identify each revenue requirement
component (e.g., rate base, expense, PTCs, REC revenue) associated with TB Flats plant (broken
out for each phase of the plant) in the revenue requirement models on both a Total Company and Idaho jurisdictional basis. In addition, please identify the location within PacifiCorp’s workpapers where the amounts for each of these revenue requirement items are located. Using each of the identified Idaho amounts, please provide the revenue requirement for the Pryor
Mountain plant separately for each phase included in the test period in Excel format with
formulas intact. Request No. 73: TB Flats. RMP’s annualized costs of the TB Flats project appear to be spread throughout RMP’s revenue requirement models and not separately identified in the
models.
a. Please provide the non-annualized test period revenue requirement for the TB Flats project (using RMP’s forecasted 2021 in-service dates for certain portions of the project) in Excel format with formulas intact associated with each phase of the project. For rate base items,
BAYER CORPORATION’S FIFTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4
please use a 13-month average for a 2021 test period. In deriving the revenue requirement, please use a format comparable to RMP’s response to the previous data request.
b. Please include a workpaper showing the monthly amount associated with non-
annualized revenue requirement component in Excel format with formulas intact. c. Please provide the monthly incremental MWh energy production associated with each phase of the Pryor Mountain project for the test period using its forecasted in-service date.
Request No. 74: Repowered Wind Plants (excluding Foote Creek). For each of the
12 repowered wind facilities please provide, in Excel format, the retirement date and the specific accounting entries that RMP made (or anticipates making) to the gross plant in service balance, accumulated depreciation reserve balance, accumulated deferred income tax balance, and any other applicable entries to reflect the retirement of the wind assets upon repowering.
Request No. 75: Repowered Wind Plants (excluding Foote Creek). For each of the 12 repowered wind facilities please provide, in Excel format, the Total Company and Idaho-allocated annual depreciation expense that was included in Idaho’s electric rates in 2019. (That is, please provide the amount included in rates in 2019 as distinct from the amount the RMP may
have booked in 2019.) Please include the applicable depreciation rate(s) in deriving these
amounts. Request No. 76: Pryor Mountain. Please provide a copy of RMP’s response to WIEC-VK-TR Data Request 3.13 and Attach WIEC-VK-TR 3.13-1 in Wyoming PSC Docket No.
20000-545-ET-18.
Request No. 77: Pryor Mountain. Please provide a copy of RMP’s response to WIEC Data Request 29.4 in Wyoming PSC Docket No. 20000-578-ER-20.
Request No. 78: Pryor Mountain. Please refer to lines 295-297 in the Direct Testimony
of Michael Johnson in Wyoming PSC Docket No. 20000-505-EC-16, in which Mr. Johnson references avoided cost pricing that RMP sent EverPower on May 13, 2016. a. Please provide a full copy of the communication in which the referenced avoided cost pricing was made.
b. Was avoided cost pricing provided after May 13, 2016 to any party with an
ownership interest in the wind resource that has become the Pryor Mountain Project? If so, please provide a copy. Request No. 79: Craig Unit 2 SCR. Please provide a copy of the Company’s
independent assessment of the Craig Unit 2 SCR project performed in July 2013, as referenced in
Mr. Owen’s Direct Testimony on page 5, lines 8-16. Did the Company perform any subsequent analysis? If yes, please provide such analyses. If not, please explain why the Company did not perform any subsequent analysis.
Request No. 80: Craig Unit 2 SCR. Please provide a copy of the Craig Participation
Agreement referenced in Mr. Owen’s Direct Testimony on page 4, lines 6-12.
BAYER CORPORATION’S FIFTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 5
DATED this 22ND day of July, 2021.

RACINE OLSON, PLLP By: ___________________________
RANDALL C. BUDGE
BAYER CORPORATION’S FIFTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 6
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 22ND 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 FIFTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 7
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