20210817PIIC 55-93 to PAC.pdf

Ronald L. Williams,ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone : [phone]
[e-mail]
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
:.i'.t11rl
CaseNo. PAC-E-21-07
THIRD PRODUCTION REQUEST OF
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS TO ROCKY
MOUNTAIN POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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, if possible, on or before
September 3 ,2021.. I
Please provide answers to each question and supporting work papers that provide
detail or are the source of information used in calculations. In 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. 55. Reference RMP witness McDougal workpaper "4.'7 - lnsurance
Expense", Tab*4.7.1": Pleasereconcilethe"$139,075,877" amountincell "E25",of
the referenced workpaper to the *$149,446,000" amount of injuries and damages
I PIIC recognizes this response date is 17 days from the date of this request, and not the 2l days allowed by
rule, but these few extra days (for PIIC) would give PIIC a full week with the data before the first
settlement conference scheduled on September 13,2021.
PIIC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page I
expense accrued in Account 925.0 identified in response to PIIC Production Request
5, workpaper "82 - Operations & Maintenance Expense Dec," Cell "F71 1."
REQUEST NO. 56. Reference RMP witness McDougal workpaper o'4.7 -
Insurance Expense", Tab*4.7.1": Please provide a description forthe $1,671,915
amounts in cell "Bl5" identified as "Third party insurance claim proceed amounts not
requested:"
REQUEST NO. 57. Reference RMP witness McDougal workpaper o'4.7 -
Insurance Expense", Tab "4.7 .3," Cell "B1 1.":
a. Please provide workpapers supporting the estimated liability insurance premium
$32,700,000 in the referenced cell.
b. Please provide an update of the referenced value, including supporting
workpapers, for any new policies or renewals since RMP filed testimony.
c. Please identifo each of RMP's liability insurance policies, the associated
premiums, deductibles, coverages, and any other relevant information about the policies.
d. Please provide policy statements for each of RMP's liability insurance policies.
e. Please identiff all new policies or renewals, and the associated premiums, entered
into since the 2020 test period.
REQUEST NO. 58. Please detail all insurance proceeds that RMP has received
over the period 2018,2019, and2020 by insurance policy.
REQUEST NO. 59. Reference RMP's Response to PIIC Production Request 5,
workpaper "Bl6 - Regulatory Assets.xlsm:" For each regulatory asset identified under
Account " 1823910 ENVIR CST UNDR AMORT" with amounts allocated to Idaho,
please:
a. Provide a brief description of the environmental costs, including the date that the
costs were incurred;
b. Identifu the order in which the regulatory asset was approved;
c. Identifu the amortization period; and,
d. Detail the amount of amortization expense associated with the regulatory asset
included in revenue requirement, including detail of both the system and Idaho-allocated
amortization amounts.
PIIC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page2
REQUEST NO. 60. Reference RMP's Response to PIIC Production Request 5,
workpaper "Bl6 - Regulatory Assets.xlsm:" For the regulatory asset titled "Reg Asset
Current - Energy West Mining" booked to account "1823990", please:
a. Provide abrief description of the regulatory asset;
b. Identifr the order in which the regulatory asset was approved;
c. Identifu the arnortization period; and,
d. Detail the amount of amortization expense associated with the regulatory asset
included in revenue requirement, including detail of both the systern and Idaho-allocated
amortization amounts.
REQUEST NO. 61. Reference RMP's Response to PIIC Production Request 5,
workpaper "Bl6 - Regulatory Assets.xlsm:" For the regulatory asset titled "REG ASSET
- CARBON PLT DECOIU/INVENTORY" booked to account *1823990," please:
a. Provide a brief description of the regulatory asset;
b. Identiff the order in which the regulatory asset was approved;
c. Identifu the amortization period.
d. Detail the amount of amortization expense associated with the regulatory asset
included in revenue requirement, including detail of both the systern and Idaho-allocated
amortization amounts.
REQUEST NO. 62. Reference RMP's Response to PIIC Production Request 5,
workpaper "Bl6 - Regulatory Assets.xlsm:" Please provide an explanation for the
amounts booked to 1823930DSR COSTS NOT AMORT, and explain why those amounts
from 2006 are still included in rate base. Please also identift the order where the
regulatory assets were approved.
REQUEST NO. 63. Please describe the status of the UMWA 1974 Pension
Trust withdrawal settlement negotiations, and explain how the costs associated with the
UMWA 1974 Pension Trust withdrawal settle,rnent negotiations are being included in
revenue requirement.
REQUEST NO. 64. Please detail the number of FTE employees employed at
the deer creek mine business unit by job title over the period 2012 through2020.
PIIC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 3
REQUEST NO. 65. Please detail the number of FTE employees employed by
Energy West by job title over the period 2012 throurdtt202O.
REQUEST NO. 66. Please detail the O&M expenses incurred, by FERC
account, by Energy West for the deer creek mine over the period 2012 through 2020.
REQUEST NO. 67. Please provide operating results for Energy West over the
period 2012 through 2020.'
REQUEST NO. 68. Please provide an operating cost summary, including
operating results by month, for the Deer Creek Mine business unit and/or cost centers
over the period 2012 through2020.
REQUEST NO. 69. Have all closure activities at the Deer Creek Mine been
completed? If no, please identiff all future closure activities expected at the Deer Creek
Mine through2025 and provide cost projections supporting the closure activities.
REQUEST NO. 70. Please provide an unredacted copy of the Direct Testimony
and exhibits of Douglas K Stuver in Case No. PAC-E-I4-10, including electronic copies
of workpapers provided in response to Monsanto Production Request 2 in that case.
REQUEST NO. 71. Please provide Pacific Power's confidential response to
Sierra Club Data Request 1, Attach Sierra Club 1.1 CONF from Oregon Docket UM
1712. Note that this response was provided in Case No. PAC-E-14-10 in response to
Monsanto Production Request 1. (see also AWEC Data Request 0094 in Oregon Docket
No UE 374)
REQUEST NO. 72. Please provide confidential, unredacted versions of
testimony and legal briefs submitted by RMP or any other party in Oregon Docket No.
uE 374.
REQUEST NO. 73. Reference RMP's response to PIIC Production Request 16,
Attach PIIC 16: Please explain why the $8,323,073 retiree medical settlernent loss is
greater than the amount identified in Case No. PAC-E-14-10 (See e.g. Stuver, Di - l3).
Please also itemize each difference in the calculation between Attach PIIC l6 and the
amount from Case No. PAC-E-14-10 that led to such a material change in the settlement
amount.
PIIC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 4
REQUEST NO. 74. Referenced the RMP witress McDougal workpaper "8.l4 -
Deer Creek Mine", Tab "8.14.6", Cell "C12": Please provide workpapers supporting the
92,291,034 amount identified in the referenced cell.
REQUEST NO. 75. Reference RMP's response to PIIC Production Request 17:
In Case No. PAC-E-14-10, RMP represented that the settlement of the o'existing
unrecognized actuarial losses currently reflected in the Company's regulatory assets that
would otherwise have been amortized to FAS 106 expense in the future and thus
represents a significant benefit to customers." See Stuver, Di -13. Please identifu the
reduction in the FAS 106 expense attributable to the reduction in unamortized losses
resulting from the settlement of the UMWA Retiree Medical Obligation for each year
over the period 2015 throudhzDzl and provide workpapers supporting the calculations.
REQUEST NO. 76. Reference RMP's response to AWEC Data Request 0100,
Attach AWEC 0100 in Oregon Docket No. UE 374: Please provide an updated version of
the referenced workpapers including a reconciliation of the $75,550,723 of total closure
costs identified in adjustnent 8.14.3 in this matter to the closure costs identified in Case
No. PAC-E-14-10.
REQUEST NO. 77. Reference RMP's response to AWEC Data Request 0100,
Attach AWEC 0100 in Oregon Docket No. UE 374 lnthe referenced response, RMP
identified the225Yo budget variance in "Reg Asset-Deer Creek-Misc Closure Costs" as
follows: "Increase primarily due to extending the closure period from 2016 to 2018 and
plan changes required by oversight agencies. The inability to gain approval of the in-
mine bulkhead engineering designs and additional time required to permit and construct
the alternate de-watering pipeline resulted in delays spanning approximately two years.":
a. Please provide all intemal documentation supporting the decision to extend the
closure period from 2016 to 2018.
b. Please provide the original mine closure plans, including the in-mine bulkhead
engineering designs, and identiff when the original plans were prepared.
c. Did the mine produce coal over the period 2016 to 2018, prior to when the mine
was actually closed?
d. Please provide all internal memoranda or documentation over the period 2015 to
2020 discussing the inability to gain approval of the in-mine bulkhead engineering
designs.
PtrC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 5
e. Please provide all communications from oversight agencies over the period 2015
to 2020 discussing the approval of the in-mine bulkhead engineering designs.
f. Please provide all internal memoranda or documentation over the period 2015 to
2020 discussing the need to construct the alternate de-watering pipeline.
g. Please provide all communications from oversight agencies over the period 2015
to 2020 discussing the need to construct an alternate de-watering pipeline.
REQUEST NO. 78. Referenced the RMP witness McDougal workpaper "S.l4 -
Deer Creek Mine", Tab"8.14.7", Cell "B8": Please itemize RMP's estimated
abandonment royalties and recovery royalties of $15,557,244by agency or counterparty,
and provide workpapers supporting the estimate.
REQUEST NO. 79. For each agency or counterparty in which RMP has an
abandonment or recovery royalty obligations, please provide the following:
a. The statute, regulation, or contract under which the royalties may be assessed.
b. All communications between RMP and the agency regarding abandonment or
recovery royalty obligations over the period 2015 throudn202l (o date).
REQUEST NO. 80. Reference RMP's response to AWEC Data Request 0100,
Attach AWEC 0100 in Oregon Docket No. UE 374: With regard to abandonment
royalties, the referenced workpapers states "No coal lease abandonment royalty
obligation was assessed by the BLM as the agency found maximum economic recovery
had been achieved.":
a. Please provide the communications from the BLM stating that no abandonment
royalties would be assessed.
b. Please explain how the referenced statement is consistent with RMP's proposal to
recover estimated abandonment royalties in this proceeding.
REQUEST NO. 81. Please describe PacifiCorp's current policy regarding
remote working following the pandonic.
REQUEST NO. 82. Reference RMP's Response to PIIC Production Request 5,
workpaper'oB2 - Operations & Maintenance Expense Dec," Account "9239990 - AFFL
SERV EMPLOYED": Please provide all cost allocation manuals and workpapers
supporting the amounts accrued to the referenced account.
PIIC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 6
REQUEST NO. 83. Please identiff all new debt issuances that PacifiCorp has
made since the preparation of Kobliha Exhibit 3 and provide the terms of all such debt
issuances in the same format as provided in Kobliha Exhibit 3.
REQUEST NO. 84. Please identiff all expected debt issuances that PacifiCorp
plans to make through Decernber 31,2022 and provide the expected terms of all such
debt issuances in the same format as provided in Kobliha Exhibit 3.
REQUEST NO. 85. Reference RMP's Response to PIIC Production Request 5,
workpaper "B2 - Operations & Maintenance Expense Dec," Account "9020000": Does
RMP expect meter reading expense savings associated with its Idaho Advanced Metering
Infrastructure Program? If yes, please identifr the amount of meter reading savings that
RMP expects in calendil year 2021.
REQUEST NO. 86. Please provide all cost benefit analyses that RMP has
prepared in connection with the implementation of Advanced Metering lnfrastructure in
Idaho.
REQUEST NO. 87. Please provide the most recent 10-year plan for Bridger
Coal Company, including all of the "OPEX-CAPEX" supporting workpapers ( e.g. "01
OpsCostSchedules", "03 Labor- SURF," etc.) that are typically provided along with
RMP's net power cost filings.
REQUEST NO. 88. Please provide workpapers supporting the cost of coal from
each of RMP's coal fired power plants in the same manner as provided in the confidential
workpapers supporting the Direct Testimony of Pacific Power witness Ralston in Oregon
Docket UE 390.
REQUEST NO. 89. Please provide RMP's calculation of the Idaho ECAM
balance for calendar year 2021 including 2021 cost data through the most recent month
available.
REQUEST NO. 90. Please provide transaction level (i.e. invoice level) detail
for FERC Account 9210000, OFFICE SUPPL & EXP. Please include all fields stored in
RMP's accounting system, including description, date, vendor, allocation factor and all
other information stored with respect to aparticular accounting entry.
REQUEST NO. 91. Please provide transaction level (i.e. invoice level) detail
for all Outside Services expenses incurred in2020: Please include all fields stored in
PtrC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 PageT
RMP's accounting system, including description, date, vendor, allocation factor and all
other information stored with respect to a particular accounting entry.
REQLJEST NO. 92. Please provide transaction level (i.e. invoice level) detail
for legal expenses incurred in2020 Please include all fields stored in RMP's accounting
system, including description, date, vendor, allocation factor and all other information
stored with respect to a particular accounting enty. For each entry, please also include a
description of the legal matter for which the legal services were acquired.
REQUEST NO. 93. Please provide annual detail of each depreciation study
deferred account that RMP has had in place over the period 2012 through 2021 (to date).
Specifically, please detail the amount deferred, the amount arnortize.d, the docket where
the amount was amortized,the beginning and ending balances, and any other adjustrnents
to the deferred account (e.g. carrying-charges).
Dated this 17th day of August,2l2l.
Respectfu lly submitted,
/stWllL.W%n
Ronald L. Williams
Williams Bradbury, P.C
Attorneys for PIIC
PtrC 3ed Set of Production Requests to RMP, Case No. IPUC-E-21-07 Page 8
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 17th day ofAu&S! 2021,1caused to be served a true and
correct electronic copy of the third set of discoverv 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
J an. nori wki @puc. idaho. sov
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, ID 83720-0074
davn.hardi idaho.sov
i [e-mail]. gov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
ted. weston@paci fi com. com
Emily L. Wegener
Matthew D. McVee
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
emily. weeener@naci fi corp. com
matthew.mcvee@paci fi com. com
Data Request Response Center
PacificCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
datarequest@f'aci fi corp. com
Randall C. Budge
Thomas J. Budge
Racine, Olson, Nye & Budge, Chtd.
201E. Center
PO Box 1391
Pocatello, ID 83204-1391
[e-mail]
[e-mail]
Bradley G. Mullins
MW Analytics, Energy & Utilities
brmul I ins@mwanalytics. com
PIIC Electronic Service Only:
Val Steiner: Val. Steiner(g)itafos.com
Kyle Williams: williamsk@byui. edu
Adam Gardner: AGardner@ idahoan. com
Additional Bayer Representatives:
(Electronic Service Only)
James Smith: [e-mail]
Mike Velie: [e-mail]
Brubaker @ Associates
Brian Collins: bcollins(@consultbai.com
Maurice Brubaker: [e-mail]
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box 61 19
Pocatello,ID 83205
[e-mail]
Energy Shategies
Kevin C. Higgins: [e-mail]
Courtney Higgins chi [e-mail]
Milli Picharo: mpichardo@,energystrat.com
Neal Townsend: [e-mail]
PIIC CERTIFICATE OF MAILING Page I
Anthony Yankel
1277 LakeAven7e, Unit 2505
Lakewood, OH 44107
[e-mail]
Aegis Sfrategies
Lance Kaufrnan: lance@aeeisinsi ght.com
Benjamin J. Otto
Idaho Conservation League
7l0N.6tnSteet
Boise,Idaho 83702
botto@ idahoconservation.ore
Brad M. Purdy
Community Action Partnership
Association of Idaho
Attorney at Law
2019 N. l7th Sneet Boise,ID 83702 E-mail:
[e-mail]
tstkatll L Wilher4
Ronald L. Williams
Williams Bradbury, P.C
Attomey for PIIC
PtrC CERTIFICATE OF MAILING Page2