20210812PAC to Bayer 63-80.pdf

ROCKY MOUNTAIN
FIOWER
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 12,2021
Randall C. Budge/Bayer randy (@racineolson. com (C)
Thomas J. Budge/Bayer ti @racineolson. com (W)(C)
Brian C. Collins/Bayer bcollins@consultbai. com fi\D(C)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer [e-mail] (C)
Lance Kaufman/Bayer lance@aegisinsi eht. com (C)
James R. Smith/Bayer j im. r. smi th@ic loud. com (C)
Mike Veile/Bayer m ike. vei [e-mail]
Courtney Higgins/Bayer ch i s s i ns @energy strat. com
Milli Picharo [Bay u m pi ch ardo @enersy strat.c om
Neal Townsend/Bayer [e-mail]
RE ID PAC.E.2I-07
Bayer Set 5ft (63-80)
Please find enclosed Rocky Mountain Power's Responses to Bayer 5ft Set Data Request 63-70,
72, and 75-80. The remaining responses will be provided under separate cover. Also provided
are Attachments Bayer 76,77, and 80. Provided via encryption are Confidential Attachments
Bayer 68,69,70,72,78, and 79. 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,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC ron@williamsbradburv. com
Bradley G. Mullins/PIIC brmull ins@mwanalvtic s. com
Adam GardnerlPIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Ben Ouo/ICL [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/PlC [e-mail] (W)
Kyle Williaurs/PtrC williamsk@bvui. edu (W)
Val SteinerlPIIC val. steiner@ itafos. com (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 63
Bayer Data Request 63
Test Period. Please confirm that the test period approved in RMP's most recent
general rate cases in Utah and Wyoming utilized a2021test period with a l3-
month average rate base. If RMP disagrees, please explain in detail the basis for
the disagreement.
Response to Bayer Data Request 63
Confirmed. The test period in the Company's Utah general rate case (GRC) and
Wyoming GRC reflected a2021test period using a 13-month average rate base
and a requested rate effective date of January 1,2021.
Recordholder:Nick Highsmith
Sponsor:Steve McDougal
PAC-E-2I-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 64
Bayer Data Request 64
Test period. Please prepare and provide a complete set of Idaho revenue
requirement models, adjustnents, and work papers, comparable in all respects to
RMP's as-filed models/work papers used to produce RMP witress Steven R.
McDougal's Exhibit No. 40, but that reflects a 13-month average rate base
amount for 2021. In preparing these revenue requirement models, please do not
reflect any annualizations for any adjustrnents with changes occurring during the
2021 calendar year, including any post-2020 capital additions. Please provide the
models/work papers in Excel format with formulas intact.
Response to Bayer Data Request 64
PacifiCorp objects to this request as overly burdensome and requiring the creation
of a new analysis that is beyond the scope of discovery in this proceeding.
Notwithstanding the foregoing objection, the Company responds as follows:
The Company has not performed the requested calculation and to do so would
require gathering new forecasts and projections. The test period in this general
rate case (GRC) has been prepared in a manner that is consistent with the
Company's prior Idaho general rate case proceedings, which the Idaho
Commission has approved. Notably, the use of an end-of-period calendar year
2021 testperiod ensures that costs associated with capital investrnent is used in
useful and properly aligned with customer rates beginning with the January l,
2022 rate effective date proposed in this proceeding.
Recordholder: Nick Highsmith
Sponsor Steve McDougal
PAC-E-2I-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 65
Bayer Data Request 65
Accum ulated Depreciation/Am o rtlzation Reserve. I s RMP adj usting the
accumulated depreciation/amortization reserve for existing plant in the base
period to reflect year-end 202L balances? If not, please explain why RMP didn't
reflect year-end 2021balances and identiff the time period RMP is proposing for
this reserve balance in its filing. If so, please provide a workpaper in Excel format
that rolls forward the year-end2020 reserve balances to year-end 2021 balances
and the location within RMP's adjustments where each of the roll forward
adjustments are located.
Response to Bayer Data Request 65
The Company is not walking all the depreciationlamortization reserve balances
forward to year-end 202l.The Company did not walk all the reserve balances to
2021 as the Company has not included all202l capital additions in this general
rate case (GRC). The Company did not include capital additions less than $5
million in the GRC consistent with prior GRC filings. If the Company included all
of the capital additions and associated depreciation expense, it would be
appropriate to adjust the reserve amounts. The base period reserve balances are
year-end 2020 andthe Company is adjusting the reserve balance for the major
plant additions being included in the filing in Adjustrnent 6.2. The Company also
adjusted the reserve balance in the following adjustments: Nodal Pricing (No.
5.2), Hydro Decommissioning (No. 6.3), New Depreciation Study (No. 6.5),
Klamath Hydroelectric Settlement Agreement (No. 8.10), and the New Wind and
Repowering Capital Additions Adjustrnent (No. 8.15).
Recordholder Laura Miller
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 66
Bayer Data Request 66
Adjustment 8.15 - New Wind and Repowering Capital Addition. In the
Confidential 8.15 exhibit file, the values on p. 8.15.1 appear to show the calendar
year 2020 gross plant in service capital additions for each resource. Please
confirm that RMP's proposed depreciation expense adjustrnent is intended to
derive an annualized depreciation expense at the 2013 depreciation rates for each
resource. In addition, please explain why RMP did not also reflect the incremental
depreciation expense in accumulated depreciation.
Response to Bayer Data Request 66
Confirmed for the projects listed on page 8.15.1. Adjusftnent 8.15 did annualize
the depreciation expense for the projects that went into service n2020 shown on
page 8. 1 5. I . The capital projects that will go into service n 2021 shown on page
8.15.2 reflect the stipulated depreciation rate. Adjusfrnent 6.5 New Depreciation
Study incorporates the stipulated depreciation rate for the 2020 projects listed on
page 8.15.1. (See page 6.5.4) The Idaho general rate case (GRC) is based on a
year-end rate base methodology with capital projects greater than $5 million. The
Company did not reflect the additional reserve amounts in this adjustment
because the Company did not include all capital additions consistent with prior
Idaho GRC filings.
Recordholder:Craig Larsen
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 67
Bayer Data Request 67
Adjustment 8.15 - New Wind and Repowering Capital Addition. In the
Confidential 8.15 exhibit file, the values on p. 8.15.2 appear to show the calendar
year 2021gross plant-in-service capital additions. Please confirm that RMP is
reflecting a2021end-of-period plant in service balance for each project (in
addition to the 2020 end of period balances). For each new or repowered wind
project and related tansmission, please provide a work paper deriving the 13-
month average balance for 2021for gross plant, accumulated depreciation, and
accumulated defened income taxes. Please reconcile any differences with the rate
base amounts included in RMP's filing.
Response to Bayer Data Request 67
Adjustnent 8.15 includes the December 2021year end plant in service capital
additions. The December 2020 year end plant in service capital additions are
included in the base period and not this adjustnent.
Please refer to the Companyos response to Bayer Data Request 64 regarding the
calculation of a l3-month average for 2Al.
Recordholder Craig Larsen
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 68
Bayer Data Request 68
Adjustment 8.15 - New Wind and Repowering Capital Addition. For any new
wind or repowered wind plant in which some portion of the plant has an in-
service date during calendar year 2021(e.g. Pryor Mountain, TB F1ats, etc.),
please provide a monthly breakdown of the capital additions for each phase of the
plant addition. As part of this response, please include the pro forma monthly
depreciation expense, accumulated depreciation, and accumulated deferred
income taxes for each phase of each plant. If there is any difference from the
amounts included in RMP's filing, please reconcile the difference with the
requested amount in the filing.
Response to Bayer Data Request 68
There are no separate phases for wind plants included in the Idaho general rate
case (GRC). Please refer to Confidential Attachment Bayer 68.
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: Craig Larsen
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 69
Bayer Data Request 69
Adjustment 8.15 - New Wind and Repowering Capital Addition. For any new
wind or repowered wind plant in which some portion of the plant has an in-
service date during calendar year 2021 (e.g. Pryor Mountain, TB Flats, etc.),
please explain whether or not the O&M expense amounts shown on p. 8.15.3 are
annualized amounts or amounts based upon the various in-service dates for the
plant. As part of this response, please include the pro-forma202l monthly O&M
expense for each phase of each plant. In addition, please describe the impact, if
any, that the various 2021 in-service dates have on the requested O&M expense.
Response to Bayer Data Request 69
The new wind or repowered plants that have an in-service date during calendar
year 2021 are;
Pryor Mountain operational date of March3l,202l for Vestas turbines, and
February 5,2021for General Electric (GE) turbines; and
TB Flats with operational dates of February 13,2021and July 26,2021.
Foote Creek operational date of March24,202l.
The amounts provided Confidential Exhibit No. 41, on page 8.15.3 are the
annualized operations and maintenance (O&M) expenses. Please refer to
Confidential Attachment Bayer 69 which provides the monthly details shown in
Confidential Exhibit No. 41, on page 8.15.3, and the impact the in-service dates
have on the requested O&M. The202l in-service dates resulted in delayed
operational costs such as the long-term fixed service agreements, production lease
payments, utility costs, avian monitoring, and other operations expenses. O&M
costs are lower at Pryor Mountain by $247,546, TB Flats by $779,314, and Foote
Creek by $54,054. The delayed in-service dates affect 2021 O&M only.
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: Gary Tawwater
Sponsor Steve McDougal
PAC-E'21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 70
Bayer Data Request 70
Pryor Mountain. Please separately identiff each revenue requirement component
(e.g., rate base, expense, PTCs, REC revenue) associated with Pryor Mountain
plant (broken out for each phase of the plant) in the revenue requirement models
on both a Total Company and Idaho jurisdictional basis. [n addition, please
identifu the location within RMP's work papers where the amounts for each of
these revenue requirement items are located. Using each of the identified Idaho
amounts, please provide the revenue requirement for the Pryor Mountain plant
separately for each phase included in the test period in Excel format with
formulas intact.
Response to Bayer Data Request 70
The Company assumes "associated with Pryor Mountain plant" is intended to
mean the components related to the other production plant function. Based on the
foregoing assumption, the Company responds as follows:
There are no separate phases included in the Idaho general rate case (GRC) for the
Pryor Mountain wind project. Please refer to Confidential Attachment Bayer 70.
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 - lnformation Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Craig Larsen
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data RequestT2
Bayer Data RequestT2
TB Flats. Please separately identifu each revenue requirement component (e.g.,
rate base, expense, PTCs, REC revenue) associated with TB Flats plant (broken
out for each phase of the plan0 in the revenue requirement models on both a Total
Company and Idaho jurisdictional basis. In addition, please identiff the location
within PacifiCorp's work papers where the amounts for each of these revenue
requirement items are located. Using each of the identified Idaho amounts, please
provide the revenue requirement for the Pryor Mountain plant separately for each
phase included in the test period in Excel format with formulas intact.
Response to Bayer Data Request72
The Company assumes "associated with TB Flats plant" is intended to mean the
components related to the other production plant function. The Company further
assumes that the reference to "Pryor Mountain" is in error, and that the reference
was intended to be to the TB Flats wind projects. Based on the foregoing
assumptions, the Company responds as follows:
There are no separate phases included in the Idaho general rate case (GRC) for the
TB Flats wind project. Please refer to Confidential AttachmentBayer 72.
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 and31.01.01.233, 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:Craig Larsen
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12"2021
Bayer Data Request 75
Bayer Data Request 75
Repowered Wind Plants (excluding Foote Creek). For each ofthe 12
repowered wind facilities please provide, in Excel format, the Total Company and
Idaho-allocated annual depreciation expense that was included in Idaho's elecfric
rates in 2019. (That is, please provide the amount included in rates in 2019 as
distinct from the amount the RMP may have booked n2019.) Please include the
applicable depreciation rate(s) in deriving these amounts.
Response to Bayer Data Request 75
The Company is unable to identifu the exact amount included lri,2019 rates as the
last general rate case (GRC), Case No. PAC-E-I l-12, was a black box settlement
with a two-year rate plan. Since that GRC, a $2 million base rate increase was
also agreed to in Case No. PAC-E-I3-04.
Recordholder:Laura Miller
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 76
Bayer Data Request 76
Pryor Mountain. Please provide a copy of RMP's response to WIEC-VK-TR
Data Request 3.13 and Attach WIEC-VK-TR 3.13-1 in Wyoming PSC Docket
No. 20000-545-ET-18.
Response to Bayer Data Request 76
Rocky Mountain Power objects to this request to the extent it seeks information
that is stale information that was not used by the Company to analyze whether to
move forward with the project" and thus, is unlikely to lead to the discovery of
admissible evidence. Noturittrstanding the foregoing objection, the Company
responds as follows:
Please refer to Attachment Bayer 76.
Recordholder:Dan Martinez I CraigEller
Not applicableSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data RequestTT
Bayer Data RequestTT
Pryor Mountain. Please provide a copy of RMP's response to WIEC Data
Request 29.4 n Wyoming PSC DocketNo. 20000-578-ER-20.
Response to Bayer Data RequestTT
Rocky Mountain Power objects to this request to the extent it seeks information
that is stale information that was not used by the Company to analyze whether to
move forward with the project and, thus, is unlikely to lead to the discovery of
admissible evidence. Notwithstanding the foregoing objection, the Company
responds as follows:
Please refer to Attachment Bayer 77.
Recordholder:Dan Martinez I CraigEller
Not applicableSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 78
Bayer Data Request 78
Pryor Mountain. Please refer to lnes 295-297 inthe Direct Testimony of
Michael Johnson in Wyoming PSC Docket No. 20000-505-EC-16, in which Mr.
Johnson references avoided cost pricing that RMP sent EverPower on May 13,
2016.
(a) Please provide a full copy of the communication in which the referenced
avoided cost pricing was made.
(b) Was avoided cost pricing provided after May 13,2016 to any party with an
ownership interest in the wind resource that has become the Pryor Mountain
Project? [f so, please provide a copy.
Response to Bayer Data Request 78
Rocky Mountain Power objects to this request to the extent it seeks information
that is stale information that was not used by the Company to analyze whether to
move forward with the project, and, thus, is unlikely to lead to the discovery of
admissible evidence. Notwithstanding the foregoing objection, the Company
responds as follows:
(a) Please refer to Confidential Attachment Bayer 78
(b) Please refer to Confidential Attachment Bayer 78
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 Paul Johnson
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer Data Request 79
Bayer Data Request 79
Craig Unit 2 SCR. Please provide a copy of the Company's independent
assessment of the Craig Unrt2 SCR project performed in July 2013, as referenced
in tvlr. Owen's Direct Testimony on page 5, lines 8-16. Did the Company perform
any subsequent analysis? If yes, please provide such analyses. If not, please
explain why the Company did not perform any subsequent analysis.
Response to Bayer Data Request 79
Please refer to Confidential AttachmentBayer 79
No subsequent analysis was completed specific to a Craig Unit 2 analysis that
involved the selective catalytic reduction (SCR) as the project started construction
in 2013 with no further analysis warranted.
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:Mike Johanson
Sponsor:James Owen
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
Bayer DataRequest 80
Bayer Date Request 80
Crarg Unit 2 SCR. Please provide a copy of the Craig Participation Agrcement
referenced in h[r. Owen's Direct Testimony on page 4, lines 6-12.
Response to BayerDeta RequestS0
Please refer to Attochment Bayer 80.
Recordholder:Mike Johanson
Sponsor:James Owen