20210810PAC to Bayer 57-62.pdf

ROCKY MOUNTAIN
POWER
1407 W North Temple, Suite 330
Salt Lake City, Utah 841 '16
; li, '.
August 10,2021
Randall C. Budge/Bayer randy (@.racineolson. com (C)
Thomas J. Budge/Bayer ti @racineolson. com (WXC)
Brian C. Collins/Bayer [e-mail] (W)(C)
Maurice B rubaker/B ayer mbrubaker@ c onsultba i. c om (C )
Kevin Higgins/B ayer khiseins@energystrat. com (C)
L ance Kaufman/B ayer lance @,ae e isinsi ght. co m (C)
James R. SmithlBayer i im. r. smith@ic loud. com (C)
Mike Veile lBay er m ike. vei le@ba),er.com
Courfirey Higgins/Bayer [e-mail]
Milli Picharo/Bayer m pichardo @enersy strat. c om
Neal Townsend/Bayer ntownsend @energystrat.com
RE:ID PAC.E-21-07
Bayer Set 4ft (57-62)
Please find enclosed Rocky Mountain Power's Responses to Bayer 4ft Set Data Request 57-62.
Also provided are Attachments Bayer 57 and 58. Provided via encryption are Confidential
Attachments Bayer 6l and 62. 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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-1sl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC brmull ins@,mwanalytics. com
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC williamsk@bvui. edu (W)
Val Steiner/PIIC val. steiner@ itafos.com (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
Ronald L. Willianos/PllC [e-mail]
Btadley G. MullinslPIIC [e-mail]
Adam Crardner/PIIC [e-mail] (W)
Kyle WtlliamslPllC williamsk@bv,ui.edu (W)
Val StEinerlP. [C val. steiner@itafos. com (W)
Eric t. OlsEu/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Brad furdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 10,2021
Bayer Data Request 57
Bayer Data Request 57
Customer Service Deposits. Please refer to Mr. McDougal's Exhibit No. 40
(Results of Operations), page 2.28.
(a) Please explain why the entries corresponding to Customer Service Deposits
(lines 2145-2148) are zero.
(b) Please compare these entries to the comparable entries in Exhibit
RMP_(SRM-3), page 2.29,hnes 2164-2167, in Utah Docket No. 20-034-04
In the Utah docket, $16.3 million of Customer Service Deposits are adjusted
into the 2021testperiod as a credit against rate base. Please explain in detail
why there is no analogous adjustment for Idaho and provide any
documentation and work papers supporting such explanation.
(c) Please provide the actual (if available) or projected monthly balance of Idaho
Customer Service Deposits for each month from December 2019 to December
2021. Please indicate whether each amount provided represents an actual or
projected balance.
(d) Please provide the actual (if available) or projected monthly Idaho interest
expense on Customer Service Deposits for each month from January 2020to
December 202L. Please indicate whether each amount provided represents an
actual or projected amount.
Response to Bayer Data Request 57
(a) In accordance with the Idaho Public Utilities Commission approved
methodology the Company does not include customer service deposits as a
rate base deduction because customer service deposits are short-term in
nature, paid interest at the commission approved customer deposit rate, and
held for guarantee of payment on services rendered.
(b) The Company assumes that the reference to "Utah Docket No. 20-034-04" is
intended to be a reference to PacifiCorp's Utah general rate case (GRC)
proceeding, Docket 20-035-04. Based on the foregoing correction and
assumption, the Company responds as follows:
The Company treats customer service deposits in Utah consistent with the
Utah commission approved methodology as approved in Utah Docket No. 97-
035-01.
(c) Please refer to Attachment Bayer 57. No projected amounts were available
(d) Please refer to Attachment Bayer 57. No projected amounts were available.
PAC-E-21-07 / Rocky Mountain Power
August 10,2021
Bayer Data Request 57
Recordholder:Mike Martin
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 10,2021
Bayer Data Request 58
Bayer Data Request 58
Employee count. Please provide the actual full time equivalent (FTE) employee
count by month, beginning in January 2017 md continuing through the most
recent date available. In this response, please indicate the day of the month to
which the FTE counts correspond (e.g., lst of the month,last day of the month,
etc.). Please supplement this response as new information becomes available
during the pendency of this case.
Response to Bayer Data Request 58
Please refer to Attachment Bayer 58 for the actual monthly full-time equivalent
(FTE) count as of the last day ofthe month from January 2017 through the most
recent month of July 2021.
Recordholder:Brittrrey Davis-Smiley
Steve McDougalSponsor
PAC-E-21-07 / Rocky Mountain Power
August 10,2021
Bayer Data Request 59
Bayer Data Request 59
Employee count. Please confirm that the Company's test period labor expenses
are efFectively based on the average full time equivalent employee count for the
base period ended December 31,2020.If not please indicate the time period
corresponding to the employee count upon which test period labor expenses are
based.
Response to Bayer Data Request 59
The Wage and Employee Benefit Adjustnent (WEBA) included in this general
rate case (GRC) does not use employee count in the calculation.
Recordholder:Laura Miller
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 10,2021
Bayer Data Request 60
Bayer Data Request 60
Employee count Please indicate whether the Company has made any
adjusfrnents to the base period to reflect known and measurable changes that
include changes to the number of employees. If so, please explain and cite to the
adjustnent(s) in the Company's filing.
Response to Bayer Data Request 60
The Wage and Employee Benefit Adjustnent (WEBA) included in this general
rate case (GRC) does not use employee count in the calculation.
Recordholder:Laura Miller
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 10,2021
Bayer Data Request 6l
Bayer Data Request 61
Annual Incentive Plan. Please provide a copy of the Annual Incentive Plan
documents for each year 2018 through 2020, and if available,202l.
Response to Bayer Data Request 61
Please refer to Confidential Attachment Bayer 61 which provides copies of
PacifiCorp's Annual Incentive Plan (AIP) documents for calendar years 2018
through 2021.
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 10,2021
Bayer Data Request 62
Bayer Data Request 62
Annual Incentive Plan. Please provide the PacifiCorp Scorecards applicable to
the Annual lncentive Plan for each year 2018 through2020, and if available,
2021.
Response to Bayer Data Request 62
Please refer to Confidential AttachmentBayer 62
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:Dana Connors
Sponsor:Steve McDougal