20210726Staff 111-138 to PAC.pdf

DAYN HARDIE (lSB No. 99lt)
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC.E.2I.O1
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power ("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY, AUGUST 16, 2021.
This Production Request is to be considered as continuing, and the Company 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 also identifu 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 spreadsheets and electronic files on CD with formulas intact and enabled.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 JULY 26,2021
REQUEST NO. 111: On pages 18 and 19 of Company Witness Meredith's direct
testimony, the Company is recommending a 50 percent shift toward elimination of tiered rates
Please provide analysis and work papers demonstrating the effects of elimination of the tiered
rates and the Company decision to change them by 50 percent.
REQUEST NO. 112: Page 2O,line 2 of Company Witness Meredith's direct testimony
references an email survey conducted by the Company regarding tiered rates. Please provide a
copy of the survey question and the customer responses and include the Company's analysis of
the results.
REQUEST NO. 113: Please provide a current list of mobile home parks that are master
metered and include the number of submeters in each park for which the Company pays a
monthly fee to the park to provide readings. Please provide the number of the Company-owned
meters and park-owned meters in each of the mobile home parks.
REQUEST NO. 114: For those mobile home parks in the question above, does the
Company have a plan to replace any park owned meter with Company-owned AMI meters so the
park can be removed from the master meter list? Please provide a timeline and projection of the
costs to replace park owned meters for each of the master metered mobile home parks.
REQUEST NO. 115: Please provide supporting documentation for the State Effective
Tax Rate of 4.54 percent found on Page 2.1 of Exhibit No. 40.
REQUEST NO. 116: Please provide supporting documentation for the adjustment to
"Special Contract l0 Curtailment" shown on Pages 3.1.4 and 3.3 of Exhibit No. 40.
REQUEST NO. 117: Has the Company entered any long-term contracts since
January 1,2021, to sell RECs, like the Kennecot Contract that was removed on Page 3.4.1 of
Exhibit No. 40?
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 26,2021
REQUEST NO. 118: Please provide supporting documentation for the refunds and out-
of-period adjustments for wheeling revenue shown on Page 3.5.1 of Exhibit No. 40.
REQUEST NO. 119: Has the Company entered any ancillary services contracts since
January l,202l,like the contracts listed on Page 3.6.1 of Exhibit No. 40?
REQUEST NO. 120: Please provide a copy of the Company's policy on employee
incentive pay that includes how target levels are established and how the final incentive amounts
are calculated. Please provide these metrics and other supporting documentation for the Annual
Incentive Plan payments in 2018 through2020, as shown on Page 4.2.5 of Exhibit No. 40.
REQUEST NO. 121: Please provide supporting documentation for the pro forma
increases to retirement plans, benefits, disability insurance, and workers compensation shown on
Page 4.2.6 of Exhibit No. 40.
REQUEST NO. 122: Please provide a detailed list of all outside services charged to the
entire Company system for 2018 through 2020, as shown on Page 4.5.1 of Exhibit No. 40.
Please include within your response sufficient identiffing transaction details, such as the
transaction description, vendor narne? date, dollar amount, and FERC account number.
REQUEST NO. 123: Please provide a detailed list of all items included in Account
550775 - Bad Debt Expense - Transmission PD in 2019 and 2020, as shown on Page 4.8.1 of
Exhibit No. 40. Please include within your response sufficient identifuing transaction details,
such as the transaction description, vendor name, date, dollar amount, and reason for assigning a
transaction to bad debt expense.
REQUEST NO. 124: Please provide the amounts charged to Account 550775 - Bad
Debt Expense - Transmission PD, as shown on Page 4.8.1 of Exhibit No. 40, for the years 201I
through 2017.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER aJ JULY 26,2021
REQUEST NO. 125: Please provide a copy of the Company's Master Property Tax
Estimation Worksheet, as shown in Confidential Exhibit No. 42, in Excel format.
REQUEST NO. 126: Please update the following estimates in the Company's Master
Property Tax Estimation Worksheet, as shown in Confidential Exhibit No. 42 for any new and
known information:
a. Column B: Assessed Values Estimates;
b. Column D: Estimated Net Property Taxes;
c. Column I: Estimated Gross Property Taxes;
d. Column J: Estimated Gross Property Taxes;
e. Column L: Pryor Mtn Savings; and
f. Column M: Estimated Net Property Taxes.
REQUEST NO. 127: Please provide a detailed list of all plant additions shown in the
Adjustment to Rate Base on Page 8.5 of Exhibit No. 40. Please include within your response
sufficient identifuing transaction details, such as the asset description, counterparty, location,
date, and dollar amount.
REQUEST NO. 128: Please provide a detailed list of all assets in FERC Account 105,
including those items that were removed from rate base on Page 8.8 of Exhibit No. 40.
REQUEST NO. 129: Company Witness Nottingham's direct testimony, beginning on
page 5, proposes to increase the Temporary Service Charge from $85 to $200. Please provide
the supporting documentation for the Activity Rate of Employee of $134.60 and the various
components such as wages, benefits, vehicle, etc. that make up the activity rate as shown in
Exhibit 38. Please provide the supporting documentation for the 1.5 hours for the average time
for employee performing the work and the average travel time for employee performing the work
as shown in the supporting calculation for Exhibit 38.
FOURTH PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER 4 JULY 26,2021
REQUEST NO. 130: Company Witness Nottingham's direct testimony, beginning on
page 5, covers the labor for the Temporary Service Charge. Are there any material charges
associated with the Temporary Service Charge in addition to the labor charges?
REQUEST NO. 131: In reference to Company Witness McDougal's Exhibit No. 40,
page 178 of 350, Klamath Hydroelectric Settlement Agreement (page 8.10):
a) Please provide the calculation and supporting documentation for the Klamath
Relicensing & Settlement Process Costs of amortization expense of $113,414 on
an Idaho Allocated basis.
b) Please provide the calculation and supporting documentation for the Klamath
Relicensing & Settlement Process Costs depreciation expense of $390,306 on an
Idaho Allocated basis.
c) Please provide the source documents for the 2021 plant additions with the project
description, "Klamath ongoing capital additions," as shown on page 8.10.3.
REQUEST NO. 132: Please explain the efforts put forth by the Company to promote
the Lend-A-Hand program.
REQUEST NO. 133: For years 2018 through2020, please provide the total dollar
amount contributed to Lend-A-Hand for Idaho by: a) RMP shareholders; b) Idaho customers;
and c) other sources. Additionally, please provide the total number of grants provided to Idaho
customers: a) average amount of each grant; b) administrative costs; c) total dollar amount
distributed to Idaho customers; and d) the eligibility requirements.
REQUEST NO. 134: For years 2018 through2020, identified in your response to
Production Request No. 2, please provide the total dollar amount of Lend-A-Hand funds that
went unused and carried over to the following calendar year and provide the reasons why the
funds were unused.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 26,2021
REQUEST NO. 135: What types of advertising (radio, tv, bill insert, welcome kit, etc.)
is conducted in Idaho to inform and educate customers about: a) energy assistance and bill
payment options; b) energy conservation; and c) Winter Moratorium and the Winter Payment
Plan. In addition, please provide copies of any written brochures or documents sent or otherwise
provided to customers for each defined category listed in this question.
REQUEST NO. 136: Please describe in detail the type of standard payment
plans/arrangements the Company offers its Idaho customers.
REQUEST NO. 137: Please describe in detail the temporary alternative/modified
payment plan/arrangements the Company offered its Idaho customers in2020 due to COVID-I9
REQUEST NO. 138: Has the Company considered making any of the temporary
altemative/modified payment plan/arrangement a permeant offering? Please explain.
DATED at Boise, Idaho, tni" 2-0$aay of July 2021
Dayn
Deputy Attomey General
i:umisc:prodreq/pace2l .Tdhmhjt prod req 4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 ruLY 26,2021
CBRTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF ruLY 2021, SERVED
THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC.E-21-07, BY E.MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOLINTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pac i fi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@.pacifi c orp.coni
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #I4O
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
[e-mail]
LANCE KAUFMAN
AEGIS INSIGHT
E-MAIL: [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
matthew ficorp.con'r
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l 19
POCATELLO ID 83205
E-MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX 1391
POCATELLO ID 83204
E-MAIL : [e-mail]
[e-mail]
JAMES R SMITH
MIKE VEILE
BAYER CORPORATION
E-MAIL: [e-mail]
[e-mail]
KEVIN HIGGINS
COURTNEY HIGGINS
MILLI PICHARO
NEAL TOWNSEND
ENERGY STRATEGIES
E-MAIL: [e-mail]
[e-mail]
[e-mail]
[e-mail]
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-MAIL : [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N ITTH ST
BOISE TD 83702
E-MAIL: [e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL: brmul .com
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE