20210805PAC to Bayer 35-56-Redacted.pdf

ROCKY MOUNTAIN
POWER
''' ''!''l'il: .- -.)
. '., ';, ' ".i Pi'i 5: l'+1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 5,2021
Randall C. Budge/B ayer randv (a)rac ineo lson. com (C)
Thomas J. Budge/Bayer ti @racineolson. com (WXC)
Brian C. Collins/Bayer bcollins@consultbai. com OID(C)
Maurice B rubaker/B ayer mbmbaker(Ec on su ltb a i. c orn (C)
Kevin Higgins/Bayer khig gins@,enereystrat. com (C)
Lance Kaufrnan/Bayer lance@aeei sinsi sht. com (C)
James R. Smith/Bayer j im. r. smith@ic loud. com (C)
Mike Veile/Bayer m ike. vei [e-mail]
Courfirey Higgins/Bayer ch i sein s@enersv strat. conr
Milli Picharo/B ayer m p ich ard o @en er s.v strat. c om
Neal Townsend/Bayer ntownsen [e-mail]
RE ID PAC.E.2I-07
Bayer Set 3'd (35-56)
Please find enclosed Rocky Mountain Power's Responses to Bayer 3'd Set Data Request 35-56.
Also provided is Attachment Bayer 38. Provided via encryption is Confidential Attachment
Bayer 35 and Confidential Response Bayer 41. Confidential information is provided subject to
protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities
Commission's Rules of Procedure No. 67 - Information Exempt from Public Review, and
further subject to the Non-Disclosure Agreement (NDA) executed in this proceeding. Provided
via encryption to Bayer and IPUC only are Customer-Specific Confidential Responses Bayer 48
and 49. Customer-Specific Confidential Attachments contain customer-specific information and
are considered business confidential. The Company requests special handling which includes
destroying or retuming customer-specific information within 30 days after the docket is
completed.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC jan.norivuki(@puc.idaho.eov (C)
Ronald L. Williams/PIIC ron@,williamsbradburv.corn
Bradley G. Mullins/PIIC brmullins@mwanalytics. com
Adam Gardner/PIIC AGardner@idahoan. com (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Ben Otto/ICL botto@i dahoconservation. ore (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC [e-mail]
Adarn Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val.steiner@ itafos.com (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA tonv@vankel. net (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 35
Bayer Data Request 35
Please provide the amount of overtime dollars and overtime hours incurred by
RMP for each of the last five years (2016-2020).
Response to Bayer Data Request 35
Please refer to Confidential Attachment Bayer 35 which provides a breakout of
PacifiCorp's general ledger (G/L) account balances of overtime dollars and hours
for calendar years 2016 through 2020. Note: overtime dollars include accruals,
adjustnents, capitalued labor and cutback (credits) for costs associated with
j oint-owned facilitie s.
Confidential information is provided subject to protection under IDAPA
31.01 .01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Dave Cumow
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 36
Bayer Data Request 36
Please list the employees who are eligible to receive overtime payments and
provide the average number of employees eligible for overtime each year from
20t6-2020.
Response to Bayer Data Request 36
Non-union/non-exempt employees who work more than 40 hours in a week,
union employees and a very limited number of non-union supervisory employees
are eligible for overtime. Note: the counts below do not include the supervisory
employees:
Year-end Count
2016 3,273
2017 3-228
2018 3.204
2019 3,066
2020 3,013
Recordholder:Dave Curnow / Shelley Zoller
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 37
Bayer Data Request 37
Please breakdown the amount of overtime dollars for each of the last five years
Q0l6-2020) by type of overtime paid. For example, time and a hall double time,
etc.
Response to Bayer Data Request 37
The Company does not tack the breakout of overtime pay into the categories of
time and a half, double time, etc., as each union contract contains different
provisions for overtime. PacifiCorp only tacks the cos! hours and number of
people associated with overtime pay by union or non-union category.
Recordholder:Dave Curnow
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 38
Bayer Data Request 38
Please provide RMP's vacation policy including an explanation of the ability to
accrue unused leave.
Response to Bayer Data Request 38
Please refer to Attachment Bayer 38 for a copy of the PacifiCorp 2020 Personal
Time Program which contains RMP's personal time policy.
The Company's personal time program for non-union employees provides pay
when employees are away from work. Note: all time taken off is considered
personal time, with the exception of holidays, civic duty, certain leaves of absence
and disability.
Employees are eligible for personal time benefits if they are a regular full-time or
part-time non-represented employee (salaried and hourly) regularly scheduled to
work 20 or more hours per week.
For part-time exempt, non-represented employees, time offallocations (including
personal time and floating holidays) are based on scheduled work hours. For part-
time, hourly, non-represented employees, time offallocations will be pro-rated,
based on actual hours worked the previous year.
Participation is automatic, and benefits begin accruing the first pay period in
which your regular full-time or part-time employment begins.
*Only available to employees with a current hire date before Janua-y l, 2010.
Vacation, sick and other leave accommodations for union employees are
dependent on the contract for each union.
Recordholder:Leslie Chase
Length of Seruice Per Pay Period Annual Accrual Maximum Accrual
Personal Time Cap
G49 months 6.00 hours 144 hours 216 hours
50-145 months 7.67 hours 1 84 hours 276 hours
146-277 months 9.33 hours 224hours 336 hours
278 or more months*I 1.00 hours 264 hours 396 hours
Sponsor Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 39
Boyer Data Request 39
Please describe the types of employees who are legible to accrue leave (unused
leave). For each employee group identified, please state whether these employees
are salaried or paid by the hour.
Response to Bayer Data Requost 39
Please refer to the Company's response to Bayer Data Request 38.
Recordholder: Leslie Chase
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 40
Bayer Data Request 40
Please provide the balance of unused leave accrual at year end for each ofthe last
five calendar years.
Response to Bayer Data Request 40
Please refer to the table below for the Company's unused leave expense balance,
in dollars, as of December 3l for calendar years 2016 through 2020.
Recordholder: Dave Cumow
Sponsor: Steve McDougal
General Ledger (G/L) Account Description 2020 2019 2018 2017 2016
500515 Unused Leave Accrual - IBEW 57 73,047.19 (171,393.32)(l r,134.40)184,556.00 (144,409.59)
500516 Unused Leave Accrual - Non Union l,9 r 8,859.31 389,342.36 143,895.71 3s,759.31 Q36,864.97)
500517 Unused Leave Accrual - Local 125 198,007.55 (11,472.59)87,096.35 (30,001.07)61,756.01
500518 Unused Leave Accrual - l-ocal 127 163,7 4r.37 (58,613.82)160,541.20 76,291.81 (43,817.74)
5005 I 9 Unused Leave Accrual - Local 197 2,000.00 (1,500.00)(500.00)(1,000.00)(500.00)
500520 Unused Leave Accrual - Local 659 232,473.77 96,645.75 34,3 81.s0 Q2,307.36)10,176.07
Subtotal Unused Leave Expense 2,588,129.19 243,008.38 414,280.36 243,298.69 (353,660.22)
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 41
Bayer Data Request 41
Please provide all documentation that explains the different components of
RMP's Annual Incentive Plan (AIP). The response should describe the different
metrics used to award AIP payments.
Response to Bayer Data Request 41
PacifiCorp's Annual Incentive Plan (AIP), part of PacifiCorp's compensation
package, provides incentive awards to reward employees for achieving objective
targets (as measured by scorecards) and the contributions for advancing the
business. Awards will be made based upon measurable achievement of results.
This approach supports the philosophy of incentive compensation as pay at risk
that is earned based on the Company, departrnent and individual performance.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Leslie Chase
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2421
Bayer Data Request 42
Bayer Data Request 42
Please provide the RMP Bonus and Awards payment balances for the last five
years.
Response to Bayer Data Request 42
Please refer to the table below for bonuses and Annual Incentive Plan (AIP)
payments made for the last five years:
Calendar Yealt)AIP Bonuses (2)Total
2020 $ 22,432,780 $ 10,313,401 $ 32,746,181
20t9 $ 29,221,443 $ 5,840,957 $ 35,062,400
2018 $ 25,017,322 $ 4,966,509 $ 29,983,830
2017 $ 28,011,574 $ 4,418,418 $ 32,429,992
2016 $ 28,312,137 $ 4,753,778 $ 33,065,915
( l) Bonus payments may include estimates for retention and hiring, safetyferformmce awrds not related o AIP md
Long-tem Incentive Plan (LTIP) payments.
(2) Amounts are as of December 3l
Recordholder:Dave Curnow
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 43
Bayer Date Request 43
For 2020, please provide a detailed description of all actions performed that
would quali& for a bonus or award payment.
Response to Bayer Data Request 43
Performanee awards are given at the discretion ef managers and are based on the
individuals' performanee and achiwements dudng the year.
Recordholder: Leslie Chase
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 44
Bayer Data Request 44
In annualizing payroll for wage increases during 2020, did RMP restate payroll,
overtime and premium pay to reflect those months in2020 when the payroll
increase was not in effect? Please explain your response.
Response to Bayer Data Request 44
Yes. To properly reflect the level of regular, premium, and overtime pay that will
be incurred with the rate effective date of January 1,,2022, the Company
annualized all increases during calendar year 2020 and projected in calendu year
2021. Further details on this calculation is provided in Confidential Exhibit No.
4l,Page 4.2.4.
Recordholder:Nick Highsmith
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 45
Bayer Data Request 45
Is RMP seeking to include payroll increases in cost of service beyond the test year
in this case. If so, please provide a detailed explanation of all increases.
Response to Bayer Data Request 45
No. As shown on Confidential Exhibit No. 41, Page 4.2.4, the Company is
annualizing regular, overtime, and premium labor for increases that have or are
forecasted to occur in calendar year 2021. These annualizations ensure the
appropriate level of labor expense is included in the revenue requirement
beginning with the requested rate effective date in this docket, January 1,2022.
Recordholder:Nick Highsmith
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 46
Bayer Data Request 46
Please provide detailed explanation of the negative expense associated with Joint
Owners Cutbacks. In the last five years except for 2020, was there a negative
expense for this item. If so please provide all negative expenses for the period
2016-2019.
Response to Bayer Data Request 46
Joint-owner cutbacks to coal plants represent billed amounts to minority owners
within operation and maintenance (O&M) expense (excluding fuel), which credit
expense and debit accounts receivable. Please refer to the table below for
cutbacks within O&M expense accounts for joint-owned plants, as reported in the
Company's Federal Energy Regulatory Commission (FERC) Form I for calendar
years 2016 through 2020:
Joint-Owner Cutback (Smillions)
Calendar Year Ilunter Unit I Hunter Unit 2 Jim Bridser Wvodak
2020 $ 1.2 $ 6.8 924.2 $ 4.0
2019 $ 1.2 $ ll.8 $ 30.9 $ 3.9
2018 $ 2.0 $ 7.6 s 33.7 $ 4.0
2017 $ 1.4 $ 7.3 $ 28.3 $ 3.9
2016 $ 1.3 $ 7.6 $27.6 $ s.l
Recordholder:Catherine Docekal
Sponsor:Steve McDouga1
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 47
Bayer Data Request 47
Please provide the percentage of total labor dollars assigned to Non-Utility and
Capitalized Labor for the last five years (2016-2020).
Response to Bayer Data Request 47
Please refer to the table below for PacifiCorp's estimated bare labor (salary and
annual incentive plan) costs, for the following years, as reported in the
Company's Federal Energy Regulatory Commission (FERC) Form I for non-
utility and capitalized labor:
Recordholder:Catherine Docekal
Sponsor:Steve McDougal
CY
Estimated Misc. Non-
Operating and Non-
Utility
7o ofNon-
Utility
Estimated
Capitalized
Labor
o/o of
Capitalized
Labor
Total
Estimated
Salaries and
Wages
2020 478,060 %177.240.117 3t%56s.827.631
2019 912,471 %163.070.510 30%543.112.097
201 8 546,524 %162-409-945 3t%531.461.M8
2017 1.294.351 %t44.084.590 28%517.404.188
2016 671,391 %146.930.576 29 o/o 514,882.176
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 48
Bayer Data Request 48
With respect to the testimony of Craig Eller at page 13, please provide the amount
of elapsed time between start-up and full rated capacity output for the following:
(a) The proposed Naughton SCCT.
O) A SCCT Frame F.
(c) A SCCT Aero.
(d) An lntercooled SCCT Aero.
(e) The proposed Bayer operating reserve product.
(f) The proposed Bayer economic curtailment product.
Customer-Specific Confidential Response to Bayer Data Request 48
The start times of supply side resources identified in PacifiCorp's 2019 Integrated
Resource Plan (IRP) are provided in answers to subparts (a) through (d) below.
Start time for simple cycle combustion turbines (SCCT) was defured as the time
required to achieve full load output from start initiation under normal operating
conditions. It is possible to reduce start times to approximately half the values
shown below under abnormal operating conditions but such operation could result
in increased maintenance costs and shortened maintenance intervals.
(a) The proposed Naughton SCCT Frame F : 225 minutes.
(b) A SCCT Frame F:22.5 minutes.
(c) A SCCT Aero: 10 minutes.
(d) An Intercooled SCCT Aero: l0 minutes.
(e)
Public Utilities
(0
Commission (IPUC) and the requester / customer, Bayer
customer-
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 48
specific information is being provided only to the Idaho Public Utilities
Commission (IPUC) and the requester / customer, Bayer.
The customer-specific confidential information provided in this data request
response is customer-specific information and is considered business confidential.
The Company requests special handling which includes destroying or retuming
customer-specific information within 30 days after the docket is completed.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the IPUC's Rules of Procedure No. 67 -
Information Exempt from Public Review, and further subject to the Non-
Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Irene Heng / Grant Laughter / Tom Burns
Craig EllerSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 49
Bayer Data Request 49
With respect to the testimony of Craig Eller page 13, please provide the ramp rate
in MW per minute for the following:
(a) The proposed Naughton SCCT.
(b) A SCCT Frame F.
(c) A SCCTAero.
(d) An Intercooled SCCT Aero.
(e) The proposed Bayer operating reserve product.
(f) The proposed Bayer economic curtailment product.
Customer-Specific Confidential Response to Bayer Data Request 49
The ramp rates of supply side resources identified in PacifiCorp's 2019 Integrated
Resource Plan (IRP) are provided in response to subparts (a) through (d) below.
Ramp rate is the maximum rate of change in unit load, either an increase or
decrease, expressed as megawatts per hour (MWh), while maintaining stable load
and stack emissions targets when operating at a load between minimum load and
tull load.
(a) The proposed Naughton SCCT: 2,400 MW/h (40 MWmin)
(b) A SCCT Frame F:2,400 MW/h (40 MWmin)
(c) A SCCT Aero: 3,000 MW/h (50 MWmin)
(d) An Intercooled SCCT Aero: 3,000 MWh (50 MWmin)
(e)
Idaho Public Utilities Commission
(PUC) and the requester / customer, Bayer.
(f)
ote customer-
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 49
specific information is being provided only to the IPUC and the requester /
customer, Bayer.
The customer-specific confidential information provided in this data request
response is customer-specific information and is considered business confidential.
The Company requests special handling which includes destroying or returning
customer-specific information within 30 days after the docket is completed.
Confidential information is provided subject to protection under IDAPA
3l.01.01.067 and 31.01.01.233, the IPUC's Rules of Procedure No. 67 -
Information Exempt from Public Review, and furttrer subject to the Non-
Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Irene Heng I Grant Laughter / Tom Burns
Craig EllerSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 5,2421
Bayer DataRequest 50
Bayer Data Roquest 50
rWith respect to the testimony of Craig Eller at page 13, please confirm that
expected benefits of a SCCT were notnetted from the valuatioa of Bayer's
operating reserve product in Commission Order No. 32196 in Case No. PAC-E-
l0-07.
Responso to Bayer Data Requet 50
Confirmed.
Recordholder: Dan MacNeil
Sponsor:Craig Eller
PAC-E-2147 / Rocky Mountain Power
August 5,2421
Bayer DataReguest 5l
Bayer Dete Requect 51
With respect to the testimony of Craig Eller at page 13, please provide a narrative
explanation of the fonnula used to derive the expected benefits of a SCCT that are
netted from the valuation of Bayer's operating resetrve product.
Recponse to BayerData Request 51
Please refer to the Company's response to Bayer Data Request 34.
Recordholder: Dan MacNeil
Sponsor: Craig Eller
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 52
Bayer Data Request 52
With respect to the testimony of Craig Eller at page l3 regarding Bayer's
operating reserve product, please provide a narrative explanation of how, on a
system operational basis, energy benefits are lost as a result of not installing a
SCCT.
Response to Bayer Data Request 52
If the Company acquires a simple cycle combustion turbine (SCCT), retail rates
would reflect the costs of the SCCT, but would also reflect the energy benefits
that resource provides, in the form of reduced net power costs (IIPC) whenever
the SCCT generates instead of a more expensive altemative or holds operating
reserves freeing up economic resources to serve load or support wholesale sales
As a result, a SCCT provides both energy benefits, from resource dispatch and the
provision of operating reserves, and capacity benefits, representing the additional
cost of ensuring sufficient resources are available to reliably serve load. This is
analogous to the values calculated for the Bayer operating reserve product which
also include both energy and capacity.
The energy benefits of the SCCT would be "lost" to retail customers (and their
rates would be higher) if the Company contracts to provide compensation for
capacity based on the full cost of a SCCT and does not account for the energy
benefits a SCCT would have provided.
Recordholder:Dan MacNeil
Sponsor:Craig Eller
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 53
Bayer Data Request 53
With respect to the testimony of Craig Eller at page 13 regarding Bayer's
operating reserve product, please describe and quantifr the reduced revenue
requirement mentioned at line 10.
Response to Bayer Data Request 53
For a description of the reduced revenue requirement, please refer the Company's
response to Bayer Data Request 34. For a quantification of the reduced revenue
requirement, please refer to the direct testimony of Company witness, Craig M.
Eller, specifically Confidential Exhibit 36, and to the Company's response to
Bayer Data Request 34, specifically Confidential Attachment Bayer 34,file
"Bayer-SCCT EIM Value 2017 - 2020 CONF.xlsb".
Recordholder:Dan MacNeil
Sponsor:Craig Eller
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 54
Bayer Data Request 54
With respect to the testimony of Craig Eller at page 15, please confirm that
expected benefits of a SCCT were not netted from the valuation of Bayer's
economic curtailment product in Commission Order No. 32196 in Case No. PAC-
E-10-07.
Response to Bayer Data Request 54
Confirmed. The Company would note that the valuation of the economic
curtailment product in Idaho Public Utilities Commission (IPUC) Order No.
32196 in Case No. PAC-E-I0-07 also did not include costs associated with a
simple cycle combustion turbine (SCCT).
Recordholder: Dan MacNeil
Sponsor: Craig Eller
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 55
Bayer Data Request 55
With respect to the testimony of Craig Eller at page 15, please provide a narrative
explanation of the formula used to derive the expected benefits of a SCCT that are
netted from the valuation of Bayer's economic curtailment product.
Response to Bayer Data Request 55
Please refer to the Company's response to Bayer Data Request 34.
Recordholder: Dan MacNeil
Sponsor: Craig Eller
PAC-E-21-07 / Rocky Mountain Power
August 5,2021
Bayer Data Request 56
Bayer Data Request 56
With respect to the testimony of Craig Eller at page 15 regarding Bayer's
economic curtailment product, please provide a narrative explanation of how, on a
system operational basis, energy benefits are lost as a result of not installing a
SCCT.
Response to Bayer Data Request 56
If the Company acquires a simple cycle combustion turbine (SCCT), retail rates
would reflect the costs of the SCCT, but would also reflect the energy benefits
that resource provides, in the form of reduced net power costs (NPC) whenever
the SCCT generates instead of a more expensive alternative or holds operating
reserves freeing up economic resources to serve load or support wholesale sales.
As a result, a SCCT provides both energy benefits, from resource dispatch and the
provision of operating reserves, and capacity benefits, representing the additional
cost of ensuring sufficient resources are available to reliably serve load. This is
analogous to the values calculated for the Bayer operating reserye product which
also include both energy and capacity.
The energy benefits of the SCCT would be "lost" to retail customers (and their
rates would be higher) if the Company contracts to provide compensation for
capacity based on the full cost of a SCCT and does not account for the energy
benefits a SCCT would have provided.
Recordholder:Dan MacNeil
Sponsor:Craig Eller