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Home My WebLink About20210730Bayer 81-102 to PAC.pdfRatrdall C, Budge, ISB No, 1949 Thotnas J, Budge, ISB No, 7465 RACINE OLSON, PLLP P,0, Box 1391;201 E, Cbntct Poeatello, Idaho 83204=1 391 Telephone: (2oB) 232=610l Fax: 1208) 232.6109 randy(Oracineol son. cotrr Li@racineolson.com Attorneytfor Intenenor P4 Produetion, L,L,C,, an affliiate of Bayer Cotporatton BEFORE THE IDAHO PUBLIC UTITITIES COMMISSION IN THE MATTER OF THE APPTICATION Of'ROCKY MOUNTAIN POWER FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES IN IDAHO AND APPROVAT OF PROPOSED ETECTRIC SERVICE SCHEDUTES AND REGULATIONS cAsE NO. PAC-E-21=07 BAYER CORPORATION'S sIxTH DATA REQUESTS TO ROCKY MOUNTAIN POWE,R P4 Produetion, L,L,C,, an afliliate of Bayer Corporation (hereinaftu "Bayef"), by and through its attorneys, hereby subrnits this First Data Requcst to Roeky Mountain Power, pur8uant to Rule 225 of the ldaho Public Utility Corrunission's Rulcs of Proeedure, IDAPA 31,01.01. This Data Request is to be considered eontinuing, and Roeky Mountain Power is requested to ptovide, by way of supplementary retponses, additional doeurnents that it or any person actitlg otr its behalf tnay later obtain that will augment the doeutneflts or infonnation produeed. Please provide answers to each question, supporting wotkpapets that provide detail or are the soutec of infornation used in caleulations, and the narne, job title and telephone number of the per$on preparing the doeuments. Please identift the narne, job title, loeation and telephone numbet of the reeord holdet, In addition to the written copies provided as r€sponse to the requests, please provide all ENcel and cleetronic ftles on CD with formulas activated. BAYER CORPORATION',S SIXTH DATA REQUESTS To ROCKY MOTNTAIN POWER - I Bayer Set 6 Request No. 8l: Employee Count. Please identiff each layoffor reduction in force performed by the Company across its system from 2014 to present. Please include the number of employees and the actual full time equivalent (FTE) of each layoff. Request No. 82: Employee Count. Please identiff number of retirements by year from 2013 to present. Please include the number of employees and the actual full time equivalent (FTE) by year. Request No. 83: Loss of Load Probability. Please provide the loss of load probability by month, year, and jurisdiction for the Company's most recently completed loss of load study Request No.84: Capital Additions. Please identiff each lawsuit PacifiCorp or a PacifCorp subsidiary has been party to from20l4 to present. Please indicate whether the case was criminal or civil, whether PacifiCorp was a defendant, whether the case is pending. If the case resulted in fines, damages, penalties, sanctions, or settlement amounts against PacifiCorp please identifr the nature and amounts. Request No.85: Capital Additions. Please provide documentation of PacifiCorp's capital project approval process. Request No. 86: Capital Additions. Please provide PacifiCorp's capitalization policy. Please include a description of how overhead and labor loadings are determined for individual projects. Request No. 87: Capital Additions. Please provide the following data for each capital addition made from 2014 to present for each project with more than $500,000 of gross capital allocated to Idaho: a. Original system capital addition, b. Applicable allocation factor, c. Net amount included in ratebase for this case, d. Date or dates that project was transferred to plant, e. Capital expenditure by month,f. Amount of AFUDC included in the project, g. All project management and capital approval documentation, and h. Basis for any cost ovemrns above the originally approved budget. Request No. 88: Capital Additions. Please provide the following data for each project not included in Request No. 87 but included in the test year ratebase for each project with more than $500,000 of gross capital allocated to Idaho: Amount of AFUDC included in the project, All project management and capital approval documentation, and Basis for any cost ovemrns above the originally approved budget. a. b. c. d. BAYER CORPORATION',S SrXTH DATA REQUESTS TO ROCKY MOT.INTAIN POWER - 2 Request No. 89: Capital Additions. Please refer to Exhibit No. 40 Page 162 of 350 which identifies two fire damage related capital projects. Please provide the following data for the referenced projects and all other fire damage related projects included in response to Request No. 87 and 88: a. If project is outside of ldaho, amount of situs capital additions associated with the fire. b. PacifiCorp's basis for assigning costs to system and sifus accounts. c. Whether the fire was associated with PacifiCorp equipment or employees. Request No. 90: Labor Expense. Please provide the following data by year and employee class (Officer, Exempt non-union, Non-exempt non-union, Union) for 2014 through 2020 and amounts included in the test year: a. Total Company FTE b. Total Company Capitalized Labor Expense, c. Total Company O&M Labor Expense, d. Total Company Base Wages and Salaries e. Total Company Overtimef. Total Company Incentives or Bonuses g. Idaho Allocated Capitalized Labor Expense, h. Idaho Allocated O&M Labor Expense,i. Idaho Allocated Base Wages and Salariesj. Idaho Allocated Overtime k. Idaho Allocated Incentives or Bonuses Request No. 91: Decommissioning Costs. Please refer to the Direct Testimony of Robert Van Engelenhoven, section VI. a. Please provide all workpapers supporting the 202}Decommissioning Studies. b. Please provide the basis for all cost estimates made by PacifiCorp and used to support the 2020 Decommissioning Studies.c. Please identiff each line item of the study that includes costs incurred or expected to be incurred by PacifiCorp. Describe what the costs are and why they are expected to be incurred by PacifiCorp. d. Please identiff each line item of the study that is not a legal obligation if PacifiCorp builds replacement generation at the plant site. e. Please identiff each line item of the study that is not alegal obligation if PacifiCorp does not build replacement generation at the plant site.f. Please provide the number of decommissioning studies performed by Kiewit Engineering Group Inc. of coal-fired generation plants prior to producing the 2020 Decommissioning Studies. g. Please provide the number of decommissioning studies performed by Kiewit Engineering Group Inc. of electric generation plants prior to producing the 2020 Decommissioning Studies. h. Please provide the number of decommissioning studies performed by Kiewit Engineering Group Inc. of rate-regulated assets prior to producing the 2020 Decommissioning Studies. BAYER CORPORATION'S SIXTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 3 plan Requert No, 92r Net Power Cortr, Pleasc rcfer to thc Dtreet Testitnony of Miehael G. Wtldlng, Please provide a€tual and foreeasted net powcr eosts by month ft0m 2014 to preseflt, Pleasc provide bystem and ldaho alloeated amounts, For foreeasted amounts please povide the mosucadily available foteeast for eaeh year and provide the datc of the foreeast, Requert No,93r Loed Foreerut. Plcasc refer to the Dtrcet Testlmony of Miehael G. Wilding. Plcase provide the load foree;ast uscd in the test ycar nct power eost fore€ast, Please provide sueh foreeast at the mo$t graflular level available, Please provide all wo*papers supporting the foteeast, ineluding all load foreeast tnodel inputs. assutrptions, and mathematieal speeifreations, Requert No. 94r Losd t'orccelt. Please provide PaeifiCorp's eunent 10=yeat business Requert No, 95r Loed f'orceert, Please provide the load foteeast used in PaeiliCorp's eurrent 10=year business plan. Please provide sueh foreeast at the most granular level availablc, Please provide all wotkpapers supportitrg the foreeast, ineluding all load foreeast model inputs, asbulnptions, and mathunatical speeifieations. Requert No. 96; Expenrer. Plcase provide the system atrd ldaho alloeated utility rcvenue and expense by month and FERC ao€ount afld subaesount from January 2014 to prcsent, Requut No. 97r Other Reyenue. Please refer to Exhibit No, 40 Page 55 of 350. Please provide the joint-us€ agre€mcnts and ptovide the basis for the foresasted revenue on thc refereneed page, Rcquut No. 9t: COVID-l9. Please to the Direst Testirnony of Oary W, Hoogeveen at page 7. a, Please identift all eosts ineuned in 2020 to aeeommodate ttansitioning employees to wort liorn horne. b. Please identift all eosts ineuned in 2020 to aceommodate soeial distaneing. e. Plcase identiff all sosts ineuned in 2020 to aceommodate eflhaneed sanitation measur€s, d, Did PaeifiCorp eilgagc any third party to assist in its response to COVID? If yes. please identiff eash engagement and the total amount billed in2020. e. Pleasc identift all eosts ineuned in 2020 ineuned in response to COVID and not addresscd in pats a through d above.f. Please identi$ all adjustments PacifiCorp noade to the test year sxpeflses to remove items identifred in parts a through e above. g, Please identift all adjustments PaciftCorp made to accouflt for the impaet of COVID on late fees. Requert No. 99: Affillated Interertr. Please refer to page 21 of PacifiCorp's 2020 Affiliated Interest Report (https://edocs.puc.state.or.us/efdocs/HAQ/re69haq I 0845.pdf) "Sutlrnary of transaetions included in Section II for the Year Ended December 31, 2020." For affiliates whete both ownership interest exceeds 50 percent and "Non-ISIA Goods and Servises BAYER CORPORATION',S SIXTH DATA REQUESTS To ROCKY MOUNTAIN POWER - 4 Total Rceeived and Provided" lb grcater than $l mllllon please provide the basis for tt.ansfer priees used in 2020, 79 of PaeifiCorp's 2020to..BI{E B, Plcase povide all eontraets and agteemcfltr bctween PaeiflCorp and BHE Wind, LLC. b. Pleasc povide all eosts ineuned by BHE Wind, LLC to proeurc and deliver the $147,029,375 of wind tutbine equipmat in the refercneed page, Please inelude suppofttrlg irloiees and transaetion daails, Requert No. 10lr Nodel Pdclng Do test ycar cxpcnres or ratebase ineludc any eosts assoeiated with ransitioning to nodal piee ot loeational marginal priee dispatehing? If yes, please: d, Identiff the amounts and indieate whcre they appear in the eompany's filing, b, Explain why thc Cotnpany is ineuning sueh eosts, and €, Explain how thc eompany has aeeounted for the benefits assoeiatcd with thesc eost6, Requert No. 102: Net Power Cortr. Please refer to the Publie Utility Commission of Oregon Doeket No. UE 390 PAC 400 Staples Page 5 lines 14 to 17, a. Does PaeifrCorp believe that Orcgon eornrnission Staffs proposal to impove Energy lrnbalanee Markct (EIM) Benefits Modeling would improve NPC estimates for ldaho? If no, why not? b, Does Paeifieorp believe that Oregon Commission Staffs ptoposal to irnprove the modeling of greenhous€ gas (GHC) benefits would improve NPC estimatcs fbr Idaho? If no, why not? e. Does PaeifrCorp believc that AWEC's proposal to update the produetion tax sredit (PTC) rate would inprove NPC estimates for ldaho? If no, why not? DATED this 29th day of July,202l, RACINE OLSON, PLLP A I 0845 By L/, RANDALL C. BUDGE BAYER CORPORATION',S STXTH DATA REQUESTS TO ROCKY MOUNTAIN POWER = 5 CERTIHTCATN OF MAIffi I HEREBY CERTIFY that on this 29fr day of July,202l,l served a truei eoneet and eomplete eopy of the foregoing doeument, to eaeh of the following, vta the method so lndieatcd: Jan Noriyukt eonuntssion Seeretary Idaho Publie Utilities Commission P,0, Box 83120, Boisc ID 83720=0074 11331 W, Chtnden Blvd, Bldg, 8, Suite 201=A Boise,lD 83714 Jan.noriyuki@puc. idaho. gov Tcd Weston ldaho Regulatory Affairs Manager Roeky Mountain Power 1407 West North Temple, Suite 330 Salt Lakc City, UT 84115 ted. weston@pac i fi corp.colll Data Request Response Center Paeifieory datareq uest@paci ficorp. com Anthony Yar*el 12100 take Avenue, Unit 2505 Lakewood, Ohio 44107 tony@yankel.net Dayn llardic John flammond, Jr, Deputy Attomeys General ldaho Publie Utilities eonmission 11331 W, Chinden Blvd., Bldg No, t, Suite 201.A (83714) PO Box t3120 Boise, lD t3120=0074 dayn.hardie@puc. idaho. eov i ohn.hammond@puc.idaho. gov Emily L. Wegenu Mauhew D, MeVce Assistant Gcnual eounsel Roeky Mountain Powu 1407 West North Temple, Suite 320 Salt Lake City, UT 84116, Erni l)r. we gener@pac i fi c o rp. co,r Matthew. mcvee @pacifi corp. com Erie L. Olsen Attorney for ldaho lrulgation Pumpers Awoeiation, Ine, (IIPA) ECHO HAWK & OLSEN, PLLC 505 Pershing Avs., Ste, 100 P,O. Box 6119 Posatello,ldaho 83205 elo@echohawk.com Ronald L. Williarns Attorney for PaelfiCorp ldaho Induttlal Cu$omert (PIrc) WILLIAMS BRADBURY, P.C, P.O, Box 388 Boise,ID 83701 ron@williamsbradbury. com BAYER CORPORATION',S SIXTH DATA REQUESTS TO ROCKY MOLNTAIN POWER - 6 Brudley Mullins MW Analytles, Energy & Utilities brmull ins@rnwanalytics. com James R, Smith Bayer Corporatiott P4 Produetion, L,L,e, 371 S, 3rd West Soda Springs, Idaho 81216 i im.r. smith@icloud.com Brian e, eoilins Mauriee Brubaker Brubaker & Assosiates 16690 Swtngley Ridgc Rd., #140 ehesterfleld, MO 61011 bcollins@consultbai.com mbrubaker@consultbai.conr PIIC Elceuonte Serviee Only: Val Stetng; Val.Steiner@itafos.com Kyle Williams; williamsk@byui.edu Adatn Gardner: AGardner@idahoan.com Mike Veile Bayer Corporation P4 Ptoduetion, t,t,e, P,O, Box 816 Soda Sprlngs, ldaho 83276 rnike.veile@bayer. corn Lanee Kaulhran Aegis Insight 2623 NW Bluebell Plase eorvallis, Oregon 97330 lance@aegisinsisht.com Be4jamin J, Otto Idaho Conservatlon League 710 N. 6th Street Boise,lD 83702 botto@ idahoconservation.org Kevin C. Hlggins Courtney Higgins Neal Tovauend Milli Piehardo Energy Strategies 111 East Broadway, Suitc 1200 Salt Lake City, Utah 84111 khi e sins@energystrat.corn chissinsA.enersvstrat.com strat.com rnnichardo @enersvstrat. collr Brad M, Purdy Anorney for C ommunlty Aetlon P artneruhlp Asroelatlon of ldaho 2019N. 17tt St. Boise,lD. t3702 bmpurdy@hotmail.com BAYER CoRpoRATION',S SIXTH DATA REQUESTS TO ROCKY MOUNTAIN POWER - 7