20210810PIIC 22-54 to PAC.pdf

Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone : [phone]
ron@willi amsbradbury. corn
Attorneys for PIIC
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
rl; .r. I t:-.; iu i'li J' lJ
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. PAC-E-21-07
SECOND PRODUCTION REQUEST
OF PACIFICORP IDAHO
INDUSTRIAL CUSTOMERS TO
ROCI(Y 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 31,
2021.
Please provide answers to each question and supporting work papers that provide
detail or are the source of information used in calculations. ln 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. 22: Please identifu the historical test period, or base period, that is
being proposed in this proceeding, along with the accounting conventions being used
(e.g. year-end, 13-month averages, etc.).
Request No 23: Reference McDougal workpaper "8.5 - Major Plant Additions",
Tab*8.5.2": Please explain why an adjustment is necessary for major plant placed into
service in calendar year in 2020 ("e.g. Vantage Pomona Heights 230kV Line") when the
PIIC 2ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page I
unadjusted results used in this proceeding in the RAM are already based on Year End
balances as of December 31, 2020.
Request No. 24: Reference McDougal workpaper "6.1 and 6.2 Depr and Amort
Exp_Reserve", Tab "6.1.1": Please explain why an adjustment is necessary for
depreciation expenses associated with major plant placed into service in calendar year
2020 when the unadjusted results used in this proceeding in the RAM are already based
on Year End plant balances as of Decernber 31, 2020.
Request No. 25. Reference McDougal workpaper "8.5 - Major Plant Additions",
Tab*8.5.2": Please provide similar project detail for the major plant additions proposed
for calendar year 2020, including the actual cost and in service dates for each project.
Request No. 26: Reference McDougal workpaper "8.5 - Major Plant Additions",
Tab "8.5.2": Please provide monthly construction work in progress balances and actual
transfers to plant associated with each project identified in the referenced workpaper
through Jnly 2021.
Request No. 27: Reference McDougal, Di at 38:3-5: Rocky Mountain Power
states that "The Company identified capital projects with expenditures over $5 million
that will be used and useful by Decernber 31, 2021:' Please explain why the
expenditures identified in McDougal workpaper "8.5 - Major Plant Additions", Tab
"8.5.2" include several projects with capital budgets of less than $5 million.
Request No. 28: Reference McDougal workpaper'08.5 - Major Plant Additions",
Tab "8.5.2": For each project where the in service date is listed as various, please
provide a monthly schedule of transfers to plant assumed for each such project.
Request No. 29: Reference McDougal workpaper "8.5 - Major Plant Additions,
Tab "8.5.2", Cell "G46", Project *AM[ - Idaho 2019 meters":
a. Please provide a workpaper detailing the calculation of the hardcoded value in
the referenced cell.
b. Please explain why Rocky Mountain Power is proposing an adjustment for
meters placed into service in20l9, prior to the start of the test period.
c. Please provide a general explanation of Rocky Mountain Power's AMI
program in Idaho and the nafure of the referenced pro forma adjustment.
d. Please identifr the transfers to plant by month associated with Rocky
Mountain Power's Idaho AMI program over the period January 1,2016
through July 31, 2021.
e. Please identifu the plant in service associated with Idaho meter retirements by
month over the period January 1,2016 through July 31, 2021.
PtrC 2ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page2
f. Please state the oZ of customers by rate schedule with an AMI meter deployed
as of December 31, 2019, December 31,2020 and July 31,2021.
Request No. 30: Reference McDougal workpaper "8.5 - Major Plant Additions,
Tab *8.5.2", Cell uG25", "Lloyd Center Tower Open Offtce":
a. Please provide a description of the referenced capital project, including
supporting project justification forms and project approvals from
management.
b. Did the referenced project result in the retirement of previous leasehold
improvements at the Lloyd Center? If yes, please identifu the plant in service
that was, or will be retired, in connection with the referenced project.
c. Please state the date that Rocky Mountain Power expects the project to be
completed.
Request No. 31: Reference McDougal workpaper "8.5 - Major Plant Additions,
Tab "8.5.2", Cell "G25", "Lloyd Center Tower Open Office":
a. Please provide a description of the referenced capital project, including
supporting project justification forms and project approvals from
management.
b. Did the referenced project result in the retirement of previous leasehold
improvements at the Lloyd Center? If yes, please identifu the plant in service
that was, or will be retired, in connection with the referenced project.
c. Please state the date that Rocky Mountain Power expects the project to be
completed.
Request No. 32: Reference McDougal workpaper "8.5 - Major Plant Additions,
Tab "8.5.2": For each project with an expected or actual in service date prior to the date
of this request, including projects listed as "various", please identiff the date that the
project was placed into service and the actual capital costs transferred to plant.
Request No. 33: Reference McDougal workpaper "8.5 - Major Plant Additions,
Tab "8.5.2", Project Transmission Wildfire Mitigation:
a. Please explain why there are two projects identified as wildfire mitigation
under the Transmission category.
b. Please provide detailed project justification documentation and planning
documents supporting Rocky Mountain Power's proposed wildfire mitigation
activities on its transmission system.
Request No. 34: Reference McDougal workpaper "8.5 - Major Plant Additions,
Tab "8.5.2", Project'oC7 Data Centers, Load Increase":
a. Please provide a detailed description, supporting project justification analyses,
and managernent approval documentation for the referenced project.
PIIC 2ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 3
b. Please identifu the amount of the load increase associated with the referenced
project both in terms of MWhs and 12-CP demand.
c. Please identifu the jurisdiction where the load is or will be located.
Request No. 35: Reference McDougal workpaper "Exhibit No. 43 - TCJA
Regulatory Liability Balance (Clean)": Please provide workpapers, will all links and
formulae intact, supporting the calculation of the following hardcoded values in the
referenced workpaper:
a. Cell "H10" Classification Correction
b. Cells "Fl2:F15" Deferred Amortization
c. Cell "F17" Gross-up Factor
d. Cells "H19","J19", and "Ll9" Amounts Used
e. Cell "H28" Current Tax Benefitf. Cell"H29" Wheeling Revenue Offset
g. Cells "H39:H40", "J39.J40" ECAM Offset
h. Cell "L4l" Plant Buy-Down (Cholla")i. Cell'N43" Powerdale Decommissioningj. Cell'N44" Electric Plant Acquisition Adjustment - Craig and Haydenk. Cell "N45" 2017 Protocoll. Cell'N46" Intervenor Funding
m. Cell "N47" Cholla Balances.
Request No. 36: Reference McDougal workpaper "Exhibit No. 43 - TCJA
Regulatory Liability Balance (Clean)": Did the retirement of wind facilities in
connection with the Wind repowering program result in incremental amortization of
Protected EDFIT balances and/or deferred amortization? If yes, please identiff the
amounts of the incremental amortization and explain how the amounts were considered in
the referenced workpapers.
Request No. 37: Reference McDougal workpaper "'7.6 - TCJA Tax Deferred"
Tab "Page 7.6.1":
a. Please explain the difference between the protected EDFIT balances
accrued to SAP Account 288932 and SAP Account 288942.
b. Please explain why SAP Account 288942 is expected to amortize to
zero by December 3 l, 2021.
c. Please explain why the cumulative change in Protected EDFIT account
balances in202l for SAP Account 288932 and SAP Account 288942
of $10,392,381 (sum of cells "E9" and "E13") is different than the
$2,912,455 of protected EDFIT amortizationfor 2027 identified cell
"E45."
PIIC 2ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 4
Request No. 38. Reference McDougal workpaper "S.l l - Cholla 4," Tab
"8.1 1.3", Cell"CI7": Please detail the monthly deprecation expenses associated with the
referenced value, including detail of the monthly plant balances, and the assumed
depreciation rates.
Request No. 39: Please identiff the remaining fuel stock balances at Cholla on
Decernber 31,2020. Please also include a description of how the fuel was disposed and
identification ofany sales proceeds and dates received or expected to be received.
Request No. 40: Please identifo all salvage proceeds recognized, or expected, in
connection with the retirement of Cholla 4.
Request No. 4l: Please identiff the amount of Fly Ash in storage at Cholla 4 as
of December 31, 2020 and describe plans for selling the remaining fly ash at the facility.
Please also identifu all such sales of Cholla 4 Fly Ash in2020 and to date.
Request No. 42: Reference McDougal workpaper "8.l l - Cholla 4," Tab
"8.11.2", Cell "F9": Please provide detail of each type of materials and supplies
expenses that are expected to be recognized in connection with the Cholla 4 retirements.
Request No. 43: Reference McDougal workpaper "8.l l - Cholla 4," Tab
"8.11.2", Cell "Fll":
a. Have the referenced liquidated damages amounts been paid? If yes, please
provide invoices supporting the liquidated damages amount. If no, please
state when the amounts are expected to be paid.
b. Please provide a copy of the contract(s) where the obligation to pay liquidated
damages are included and identifu the specific contract language requiring the
payment of liquidated damages.
Request No. 44: Reference McDougal workpaper "8.1I - Cholla 4," Tab "8.11":
Please identifu the protected EDFIT balances associated with Cholla 4 as of December
31,2020, and provide a description of how those freed-up EDFIT amounts are being
treated in revenue requirement.
Request No. 45: Reference McDougal workpaper "6.5 - New Depreciation
Study", Tab"6.5.4": Please provide detail supporting the2020 depreciation and
amortization expenses by FERC account and FERC sub account. Please include monthly
detail of the plant balances (gross plant), the associated depreciation rate applied and the
applicable Idaho jurisdictional allocation factor. Please reconcile the response to the
PIIC 2ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 5
$40,448,993 of depreciation expense and $2,682,363 amortization expenses included in
the unadjusted result of operations for the Idaho jurisdiction for calendar year 2020.
Request No. 46: Reference McDougal workpaper "6.5 - New Depreciation
Study", Tab "6.5.4": Please provide detail supporting the old and new depreciation rates.
Specifically, please provide electronic copies (in Excel format) of Attachment 1,
Attachment 2, and Attachment 3 supporting the Phase I Stipulation in Case No. PAC-E-
18-08, or provide workpaper(s) with a comparable set of data.
Request No. 47: Reference Attachment 3 of the Phase I Stipulation in Case No.
PAC-E-18-08: Please provide actual plant in service as of December 31, 2020 for each
FERC Account, FERC sub account, including separate detail for each generation unit
using the same account classifications and level of detail identified in the referenced
Stipulation Attachment.
Request No. 48. Reference McDougal workpaper 006.5 - New Depreciation
Study", Tab *6.5.4": Please explain why there is no adjustment removing the property
plant and equipment associated with wind property plant and equipment that was retired
in2020 in connection with the repowering progr{Lm.
Request No. 49: Please identifr the amount of plant retirements by month
associated with each of the repowering projects, including the cumulative amount of
plant retirements for each project.
Request No. 50. Please identiff the actual in-service date and the actual amount
of capital placed into service for each EY 2020 (including Pryor Mountain) project, the
associated EV 2020 Transmission investment, and the repowering investments. Please
detail the transfers to plant for each project by month on a system basis.
Request No. 51: Did the Capital costs associated with EY 2020, including the
Transmission investment exceed the caps identified on Page l3 of Order No. 34104 in
Case No. PAC-E-I7-07. If yes, please identifu the amount by which the cap was
exceeded, including project by project capital cost details. If no, please demonstrate that
the cap was not exceeded including project by project capital cost details.
Request No. 52. Please provide an unredacted copy of the May 8, 2018, Multi-
party Settlement Stipulation between the Company and Staffin Case No PAC-E-17-07.
Please also state whether the redactions continue to be confidential, given that the
underlying facilities have since been constructed and placed into service.
PIIC 2ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 6
Request No. 53: Please provide Rocky Mountain Power's Idatro results of
operations over the period 2012 through 2020, including actual and normalized results
and supporting adjustments. Please provide supporting RAM and JAM files.
Request No. 54: Please state Rocky Mountain Power's actual and normalized
return on equity earned in Idaho over the period 2012 through 2020.
Dated this 10th day of August,2|2l.
Respectfully submitted,
tstPo,,vrll L. Will;*n
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
PtrC 2ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 PageT
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this lOth day of Auzust 2021,I caused to be served a true and
correct electronic copy of the second 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
Jan. noriyuki @puc. idaho. eov
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, lD 83720-0074
davn.hardie@puc. idaho. eov
i ohn.hamrnond@pucl. idaho. gov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 841l6
ted. weston@pacifi corp. com
Emily L. Wegener
Matthew D. McVee
Rocky Mountain Power
1407 West North Ternple, Suite 320
Salt Lake City, UT 84116
emily. we gener@pacifi corp. com
matthew. m cv ee@p acifi com. com
Data Request Response Center
PacificCorp
825 NE Multnomah, Suite 2000
Portland, OP.97232
datareq uest@paci fi corp. com
Randall C. Budge
Thomas J. Budge
Racine, Olson, Nye & Budge, Chtd
201E. Center
PO Box 1391
Pocatello, tD 83204-1391
r andy Gr)r aci n e I a w. n et
ti@,racineolson.com
Bradley G. Mullins
MW Analytics, Energy & Utilities
brm u I I in s@m wanalyt i cs. com
PIIC Electronic Service Only:
Val Steiner: Val. Steiner(ditafos.com
Kyle Williams: williamsk@.byui.edu
Adam Gardner: [e-mail]
Additional Bayer Representatives :
(Electronic Service Only)
James Smith: [e-mail]
Mike Velie: [e-mail]
Brubaker @ Associates
Brian Collins: bcollins(D.consultbai.com
Maurice Brubaker: mbrub aker(@consu ltba i . corn
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box 6119
Pocatello, ID 83205
elo(@echohawk.com
Energy Strategies
Kevin C. Higgins: [e-mail]
Courtney Higgins chi s gins@ energystrat. com
Milli Picharo: [e-mail]
Neal Townsend: [e-mail]
PTIC CERTIFICATE OF MAILING Page I
Anthony Yankel
1277 Lake AvenTe, Unit 2505
Lakewood, OH 44107
[e-mail]
Aegis Strategies
Lance Kaufrnan: [e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6ttr Street
Boisen Idaho 83702
botto@idahoconservation. ore
Brad M. Furdy
Community Action Partrership
Association of Idaho
Attorney atLaw
2019 N. 17th Street Boise,lD 83702 E-mail:
[e-mail]
rsrPrlrrllLWbn
RonaldL. Williams
Williams Bradbury, P.C.
Attorney for PIIC
PIIC CERTIFICATE OF MAILING Page2