20210812PAC to PIIC 1-21.pdf

ROCKY MOUNTAIN
POWER ,.,.,., i' ,: i: i'i, lil 5 i
'1407 W North Temple, Suite 330
Salt Lake Gity, Utah 84116:':. ,.iiui'i
August 12,2021
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC brmull [e-mail] (C)
Adam Gardner/PIIC AGardner@idahoan. com (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. [e-mail] (W)
RE ID PAC.E-21-07
PIIC Set I (l-21)
Please find enclosed Rocky Mountain Power's Responses to PIIC I't Set Data Requests l-21.
Provided via e-mail are the non-confidential Attachments and provided via encryption are the
Confidential Attachments. Confidential information is provided subject to protected 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 frrther subject to any
subsequent 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 NoriyukillPUC ian.norivukifg)puc.idaho.eov (C)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Randall C. Budge/Bayer [e-mail] (C)
Thomas J. Budge/Bayer ti @racineolson. com (WXC)
Brian C. Collins/Bayer [e-mail] (WXC)
Maurice Brubaker/B ayer mbrubaker@c onsu ltbai. c o m (C)
Kevin Higgins/Bayer khie gins@enersy strat. com (C)
Lance Kaufinan/B ayer lance @ae e isin s i eht. com (C)
James R. Smith/Bayer iim. r. smith@ic loud. com (C)
Brad Purdy [e-mail] (C)
Ben Otto/ICL botto@,idahoconservation. ore (C)
PAC-E-21-07 i Rocky Mountain Power
August 12,2021
PIIC Data Request I
PIIC Data Request I
Please provide PIIC Consultant, Brad Mullins, with access to the GRID model
and all associated GRID modeling work papers, used to calculate Net Power
Costs in this Proceeding.
Response to PIIC Data Request I
On July 23,2021, the Company provided Bradley Mullins of MW Analytics,
(consultant to the PacifiCorp Idaho Industrial Customers (PIIC) access to the
Generation and Regulation Initiative Decision Tool (GRID) via the intemet and
access to the GRID project relevant to the Company's direct testimony filing,
specifically supporting the Direct Testimony of Company witress, Michael G.
Wilding in this proceeding.
Please refer to the confidential work papers supporting Mr. Wilding's direct
testimony for copies of the supporting GzuD work papers. In addition to the
confidential GRID work papers, there are also highly confidential GRID work
papers which are deemed commercially sensitive. The Company requests special
handling. Please contact Ted Weston at [phone] to make arrangement for
review.
Access to GRID and its inputs are provided subject to the terms and conditions of
the protective order in this proceeding and may only be disclosed to qualified
persons as defined in that order.
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:Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 2
PIIC Data Request 2
Please provide working copies of the Net Power Cost model template, including
the supporting Day-ahead Real-time adjustnent work papers, with all links,
formulas, and functionality intact.
Response to PIIC Data Request 2
Please refer to Confidential Attachment PIIC 2
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: Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mounrain Power
August 12,2021
PIIC DataRequest 3
PIIC Data Request 3
Please provide wo*ing copies of the workpapers used to perform jwisdictional
allocation of Net Power Cost with all lin*s and formulas intact to the Ne.t Power
Cost templaG.
Responoe to PtrC Data Request3
Please refer to Attachment PIIC 3 whichprovides an electonic copy of Exhibit
No.44 showing the Idaho allocations.
Recordholder:Craig Larsen
Steve McDougalSpousor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 4
PIIC Data Request 4
Please provide the most recent version of the GRID model conversion wizard.
Response to PIIC Data Request 4
Please refer to Confidential Attachment PIIC 4. Note: this file contains macros
that are not compatible with Microsoft Excel 365.
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:Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 5
PIIC Data Request 5
Please provide all of the B-tab work papers supporting the JAM and RAM models
filed in this case, as provided with Rocky Mountain Power's or PacifiCorp's rate
case filings in other jurisdictions.
Response to PIIC Data Request 5
The Company objects to this request because the filed general rate cases (GRC) in
other jwisdictions used diflerent base periods than the Idaho GRC, and therefore
the B-tab work papers from those cases are not relevant. Subject to and without
waiving any objection, the Company responds as follows:
Please refer to Attachment PIIC 5 for the B-tab work papers for this Idaho general
rate case (GRC).
Recordholder Craig Larsen
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 6
PIIC Data Request 6
Please provide the RAM and JAM files used to establish final rates in Rocky
Mountain Power's recent General Rate Case in Wyoming, Docket No. WY
20000-s78-ER-20.
Response to PIIC Data Request 6
Please refer to Attachment PIIC 6. Note: the regulatory adjustnent model (RAM)
is not available because it was not used to establish final rates in PacifiCorp's
Wyoming general rate case (GRC), Docket 20000-578-ER-20. The jurisdictional
allocation model (JAIv| was the only file used to establish rates in PacifiCorp's
Wyoming GRC, Docket 20000-5 78-ER-20.
Recordholder Mike Martin
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 7
PIIC Data Request 7
Reference McDougal work paper "JAM Dec202l ID GRC": Please provide a
version of the tab "Factors", based on actual data from calendar year 2019.
Response to PIIC Data Request 7
The Company does not have a version of the "Factors" tab based on actual data
for calendar year 2019 consistent with the revenue requirement the Company
calculated in this general rate case (GRC) proceeding. Please refer to Attachment
PIIC 7 which provides a version of the "Factors" tab that was filed as paxt of the
Idaho December 2019 Results of Operations (ROO). Although accurate for 2019,
many of the factors would change if used with the test period in this GRC
proceeding.
Recordholder:Nick Highsmith
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 8
PIIC Data Request 8
Reference McDougal work paper *JAM Dec202l ID GRC": Please provide a
version of the tab "Factors", based on forecast data for 2022, using data from
Rocky Mountain Power's 2021Load Forecast.
Response to PIIC Data Request 8
The Company does not have a version of the "Factors" tab based on forecast data
for calendar year 2022 consistent with the revenue requirement the Company
calculated in this general rate case (GRC) proceeding. Many of the Company's
allocation factors such as "System Overhead" or'oSystem Net Plant" are based on
different components of rate base. The rate base calculated in this docket is done
consistent with the test period the Company has requested. To properly calculate a
version of calendar year 2022 allocation factors, the Company would need to
revise the entire revenue requirement to align all the various components such as
rate base. Additional revenue requirement items like revenues and net power cost
would also need to be revised to be consistent with any changes in load forecast
or underlying allocation factors.
Recordholder:Nick Highsmith
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 9
PIIC Data Request 9
Please identifr the property taxes incuned with respect to the Cholla 4 power
plant in calendar year 2020.
Response to PIIC Data Request 9
Because the State of Arizona property taxes are assessed on a one-year lag basis,
the assessed values used for 2020 property tax assessment purposes are based on
the $190 million value assigned to the Company's State ofArizona operating
property as of January 1,2019 by the Arizona Deparfinent of Revenue.
Based on the $190 million assessment, the Company incurred a total of
$2,656,103 in State of Arizona property tax for 2020. The portion of that amount
that per0ains to the Company's interest in Cholla Unit 4 is $2,614,153.
Recordholder:Norm Ross
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mormtain Power
August 12,2021
PIIC Data Request l0
PIIC Data Request 10
Please identifr and itemize all taxes, including property taxes, paid to the state of
Arizona, or apolitioal suMivision of the state of Arizoffi, h calendar yeu2020.
Response to PIIC Data Request 10
Please refer to Attachment PIIC l0 which provides a copy of PacifiCorp's202}
Federal Energy Regulatory Commission (FERC) Form-l, specffically page262
ard263,lines 9 through 12.
Recordholder:Brian Keyser
Ryan FullerSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 1l
PIIC Data Request 11
Please provide Rocky Moturtain Power's pro-forma federal tax return for calendar
years 2018 and 2019.
Response to PIIC Data Request 11
The Company's Federal pro-forma income tax returns are highly confidential and
commercially sensitive. The Company requests special handling. Please contact
Ted Weston at [phone] to make arrangements to review.
As an alternative, please refer to Attachment PIIC 1l which provides copies of
PacifiCorp's 2018 and20l9 Federal Energy Regulatory Commission (FERC)
Form l, page 261 which provides detailed information on the Company's Federal
income tax accrual, albeit based on an estimate made during the year-end
accounting which is tued-up to the filed tax return the following calendar year.
Additionally, please refer to the Company's 2018 and2019 FERC Form l, pages
262 and263 for Federal taxes paid.
Recordholder:Brian Keyser
Ryan FullerSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 12
PIIC Data Request 12
Does Rocky Mountain Power file a stand-alone tax retum in Idaho? If yes, please
provide a copy of Rocky Mountain Power's Idaho state tax returns of calendar
years 201 8 and 2019. If not, please provide the consolidated Idaho state income
tax return, where PacifiCorp's tax liability is reported to the state of Idaho, for
calendar years 2018 and20l9.
Response to PIIC Data Request 12
No, the Company does not file a stand-alone Idaho income tax return.
The Company's Idaho pro-forma tax retums are highly confidential and
commercially sensitive. The Company requests special handling. Please contact
Ted Weston at [phone] to make arrangements to review.
Information related to PacifiCorp-specific taxes accrued, prepaid and charged
during the year for Idaho is available in PacifiCorp's 2018 md20l9 Federal
Energy Regulatory Commission (FERC) Form l, pages 262 and 263. Please refer
to the Company's response to PIIC Data Request I l, specifically Attachment
PIIC I I for copies of PacifiCorp's 2018 and 2019 FERC Form l.
Recordholder: Brian Keyser
Sponsor:Ryan Fuller
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 13
PIIC Data Request 13
Please identify the amount of Idaho state income taxes PacifiCorp paid direcfly in
2018, 2019 and 2020, including the specific the dates and the amounts paid.
Response to PIIC Data Request 13
Please refer to Attachment PIIC 13 which summarizes the payments made by
PacifiCorp under its tax allocation agreement for each requested year. PacifiCorp
files in Idaho as a member of a consolidated group and does not remit payments
directly to the Idaho State Tax Commission.
Recordholder: Brian Keyser
Sponsor:Ryan Fuller
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 14
PIIC Data Request 14
Reference McDougal work paper "8.14 - Deer Creek Mine, tab "8.14.3:" Please
provide itemized detail supporting the amounts identified as "Total Closure
Costs" and'oRecovery Royalties" in cells "C7" and "C8" of the referenced work
paper, respectively.
Response to PIIC Data Request 14
Please refer to Attachment PIIC 14
Recordholder: Dan Moody
Sponsor:Steve McDougal
PAC-E-2147 / Rocky Momtain Power
August l2,2AZl
PIIC DataRoquest 15
PIIC Datr Request 15
Re&rence McDougal work papet "8.14 - Deer Creek Mine, tab "8.14.3:" Please
provide d€tail of the "Recovery Royalties" that have actually been paid,
identi$ing the specific dates and the amounts paid.
Response to PIIC Data Request 15
The Company has notpaid any recovery-based royalties.
Recordholder: Dan Moody
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 16
PIIC Data Request 16
Reference McDougal work paper "8.l4 - Deer Creek Mine, tab "8.14.4:" Please
provide itemized detail supporting the amounts identified as "Retiree Medical
Obligation Settlement Losses" in cell "D8" of the referenced work paper.
Response to PIIC Data Request 16
Please refer to Attachment PIIC 16 for the work papers supporting the United
Mine Workers of America (UMWA) Post-Retirement Benefits Other Than
Pensions (PBOP) settlement loss amount of $8,323,073.
Recordholder:Laura Miller
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 17
PIIC Data Request 17
Reference McDougal work paper "8.14 - Deer Creek Mine, tab "8.14.4:" Please
identifr the annual Financial Accounting Standards (fAS) 106 expenses benefits
for each calendar year 2015 through 2021 associated with the Retiree Medical
Obligation Settlement Loss accrued at the time of the Deer Creek Mine closure.
Please identifr both the total-Company and Idaho-allocated benefit amounts.
Response to PIIC Data Request 17
Please refer to Attachment PIIC 17 which provides a schedule of accounting for
the 2015 retiree medical obligation (RMO) settlement loss associated with the
Deer Creek mine closure. The settlement loss was a one-time event as a result of
Energy West Mining Company (EWMC) union employees at the Deer Creek
mine being carved out of the Company's retiree medical plan as described in the
Utah Mine Disposition frlings at the time. As presented in Attachment PIIC 17,
the Total Company amounts reflect the varying timing of recognition /
amortization across the state jurisdictions.
Recordholder:Jennifer Kahl
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request l8
PIIC Data Request 18
Please provide the following information by month and by rate schedule
(including special contact customers) based on actual data for calendar year
2020:
(a) Base Rate Revenues ($).
(b) Sales (kwhs).
(c) Coincident Peak Demand (KW Loads Coincident To System Peak).
(d) Non-Coincident Peaks @Input
(e) Distribution Peaks @ Input.
(0 Non-Coincident Peaks @ Sales.
(g) Average Number of customers.
Response to PIIC Data Request 18
Please refer to Attachment PIIC 18.
Recordholder:Mitchell Dean
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 19
PIIC Data Request 19
Please provide hourly load data at sales for schedule 401 over the period January
2019 through December 2020.
Response to PIIC Data Request 19
Please refer to Confidential Attachment PIIC 19.
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 Mitchell Dean
Sponsor Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
PIIC Data Request 20
PIIC Data Request 20
Please provide PacifiCorp's 2021 load forecast with load data by jurisdiction, and
rate schedule, including load data in the most granular time scale available.
Response to PIIC Data Request 20
The Company objects to this request on the grounds that it is not reasonably
calculated to produce admissible evidence in this proceeding. The Company's
Idaho general rate case (GRC) proceeding is based on historical data and does not
utilize the requested jurisdictional and rate schedule forecasts. Without waving
the foregoing objection the Company responds as follows:
Please refer to Confidential Attachment PIIC 20-l for the hourly jurisdictional
load forecastfor 2021, and Confidential Attachment PIIC 20-2 for the monthly
rate schedule forecast for202l.
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:Lee Elder
Sponsor:Michael G. Wilding