20210722PIIC 1-21 to PAC.pdf

PIIC 1st Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 1
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone: [phone]
[e-mail]

Attorneys for PIIC

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

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Case No. PAC-E-21-07

FIRST PRODUCTION REQUEST OF
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS TO ROCKY
MOUNTAIN POWER

PacifiCorp Idaho Industrial Customers (“PIIC”), by and through its
attorney of record Ronald L. Williams and pursuant to the Rules of Procedure of the
Idaho Public Utilities Commission (“Commission”), hereby requests that Rocky
Mountain Power (“RMP”) provide the following documents on or before August 12,
2021.
Please provide answers to each question and supporting work papers that provide
detail or are the source of information used in calculations. In addition to the written
copies provided as response to the questions, please provide all Excel and electronic files
on CD with formulas activated. Please provide a copy of all responses electronically to
PIIC consultant, Brad Mullins, via his email as shown on the attached service list, or
through an electronic portal.
Request No. 1 Please provide PIIC Consultant, Brad Mullins, with access to the
GRID model and all associated GRID modeling workpapers, used to calculate Net Power
Costs in this Proceeding.
Request No 2: Please provide working copies of the Net Power Cost model
template, including the supporting Day-ahead Real-time adjustment workpapers, with all
links, formulas, and functionality intact.
RECEIVED
2021 July 22, AM 7:42
IDAHO PUBLIC
UTILITIES COMMISSION
PIIC 1st Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 2
.
Request No. 3: Please provide working copies of the workpapers used to
perform jurisdictional allocation of Net Power Cost with all links and formulas intact to
the Net Power Cost template.
Request No. 4. Please provide the most recent version of the GRID model
conversion wizard.
Request No. 5: Please provide all of the B-tab workpapers supporting the JAM
and RAM models filed in this case, as provided with Rocky Mountain Power’s or
PacifiCorp’s rate case filings in other jurisdictions.
Request No. 6: Please provide the RAM and JAM files used to establish final
rates in Rocky Mountain Power’s recent General Rate Case in Wyoming, Docket No.
WY 20000-578-ER-20.
Request No. 7: Reference McDougal workpaper “JAM Dec 2021 ID GRC”:
Please provide a version of the tab “Factors”, based on actual data from calendar year
2019.
Request No. 8: Reference McDougal workpaper “JAM Dec 2021 ID GRC”:
Please provide a version of the tab “Factors”, based on forecast data for 2022, using data
from Rocky Mountain Power’s 2021 Load Forecast.
Request No. 9: Please identify the property taxes incurred with respect to the
Cholla 4 power plant in calendar year 2020
Request No. 10: Please identify and itemize all taxes, including property taxes,
paid to the state of Arizona, or a political subdivision of the state of Arizona, in calendar
year 2020.
Request No. 11: Please provide Rocky Mountain Power’s pro forma federal tax
return for calendar years 2018 and 2019.
Request No. 12: Does Rocky Mountain Power file a stand-alone tax return in
Idaho? If yes, please provide a copy of Rocky Mountain Power’s Idaho state tax returns
of calendar years 2018 and 2019. If not, please provide the consolidated Idaho state
income tax return, where PacifiCorp’s tax liability is reported to the state of Idaho, for
calendar years 2018 and 2019.

PIIC 1st Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 3
Request No. 13: Please identify the amount of Idaho state income taxes
PacifiCorp paid directly in 2018, 2019 and 2020, including the specific the dates and the
amounts paid.
Request No. 14: Reference McDougal Workpaper “8.14 - Deer Creek Mine, tab
“8.14.3:” Please provide itemized detail supporting the amounts identified as “Total
Closure Costs” and “Recovery Royalties” in cells “C7” and “C8” of the referenced
workpaper, respectively.
Request No. 15: Reference McDougal Workpaper “8.14 - Deer Creek Mine, tab
“8.14.3:” Please provide detail of the “Recovery Royalties” that have actually been paid,
identifying the specific dates and the amounts paid.
Request No. 16: Reference McDougal Workpaper “8.14 - Deer Creek Mine, tab
“8.14.4:” Please provide itemized detail supporting the amounts identified as “Retiree
Medical Obligation Settlement Losses” in cell “D8” of the referenced workpaper.
Request No. 17: Reference McDougal Workpaper “8.14 - Deer Creek Mine, tab
“8.14.4:” Please identify the annual Financial Accounting Standards (FAS) 106 expenses
benefits for each calendar year 2015 through 2021 associated with the Retiree Medical
Obligation Settlement Loss accrued at the time of the Deer Creek Mine closure. Please
identify both the total-Company and Idaho-allocated benefit amounts.
Request No. 18: Please provide the following information by month and by rate
schedule (including special contract customers) based on actual data for calendar year
2020:
a. Base Rate Revenues ($)
b. Sales (kWhs)
c. Coincident Peak Demand (KW Loads Coincident To System Peak)
d. Non-Coincident Peaks @ Input
e. Distribution Peaks @ Input
f. Non-Coincident Peaks @ Sales
g. Average Number of customers.

Request No. 19: Please provide hourly load data at sales for schedule 401 over
the period January 2019 through December 2020.

PIIC 1st Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 4
Request No. 20: Please provide PacifiCorp’s 2021 load forecast with load data by
jurisdiction, and rate schedule, including load data in the most granular time scale
available.
Request No. 21: Please provide all Idaho pole attachment revenues by licensee in
calendar years 2018, 2019, and 2020, and please discuss how these revenues are factored
into Idaho rates.

Dated this 22th day of July, 2021.
Respectfully submitted,
/s/ Ron Williams

Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
PIIC CERTIFICATE OF MAILING Page 1
CERTIFICATE OF MAILING

I HEREBY CERTIFY that on this 22ed day of July 2021, I caused to be served a true and
correct electronic copy of the first set of discovery of the PacifiCorp Idaho Industrial Customers
upon the following individuals:

Jan Norkyuki
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]

Karl Klein
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720
[e-mail]

Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
[e-mail]

Emily L. Wegener
Matthew D. McVee
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
[e-mail]
[e-mail]

Data Request Response Center
PacificCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]

Randall C. Budge
Thomas J. Budge
Racine, Olson, Nye & Budge, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
[e-mail]
[e-mail]

Bradley G. Mullins
MW Analytics, Energy & Utilities
[e-mail]

Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box 6119
Pocatello, ID 83205
[e-mail]

PIIC Electronic Service Only:
Val Steiner: [e-mail]
Kyle Williams: [e-mail]
Adam Gardner: [e-mail]

Additional Bayer Representatives:
James Smith: [e-mail]
Mike Velie: [e-mail]

PIIC CERTIFICATE OF MAILING Page 2
Brubaker @ Associates
Brian Collins: [e-mail]
Maurice Brubaker:
[e-mail]
Anthony Yankel
1277 Lake Aven7e, Unit 2505
Lakewood, OH 44107
[e-mail]

Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
[e-mail]

Dayn Hardie
John Hammond, Jr.
Deputy Attorneys General Idaho Public
Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714) PO Box 83720
Boise, ID 83720-0074
[e-mail]
[e-mail]

Brad M. Purdy
Community Action Partnership
Association of Idaho
Attorney at Law
2019 N. 17th Street Boise, ID 83702 E-mail:
[e-mail]

/s/ Ronald L. Williams
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for PIIC