20210819Staff 161-174 to PAC.pdf

DAYN HARDIE (ISB No. 9917)
JOHN R. HAMMOND, JR. (ISB No. 5470)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 83720-0074
[phone]
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC.E.2I.O1
SIXTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and John R. Hammond, Jr., Deputy Attomeys General, request that Rocky
Mountain Power ("Company") provide the following documents and information as soon as
possible, but no later than THURSDAY, SEPTEMBER 2n 2021.r
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
SIXTH PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER
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AUGUST I9,2O2I
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
EXCEL spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 161: Please provide a list of all business function codes used by the
Company and include the abbreviations and descriptions of each business function code.
REQUEST NO. 162: In reference to Company Witness McDougal's Exhibit No. 40,
page 56 of 350, Joint Use Revenue (adjustment3.T), what is the total joint use revenue from the
agreements with ExteNet and Cingular Wireless to date?
REQUEST NO. 163: How many attachments from ExteNet and Cingular Wireless does
the Company currently have and what is the basis for the expected additional joint use revenue in
this adjustment?
REQUEST NO. 164: With reference to Company Witness McDougal's Exhibit 40,
page 57 of 350, Ash Sales Revenue (adjustment 3.8), please provide a copy of the recently
executed contract for ash from the Jim Bridger plant.
REQUEST NO. 165: With reference to Company Witness McDougal's Exhibit 40,
page 57 of 350, Ash Sales Revenue, (adjustment 3.8), please provide the source documents and
workpapers supporting the revised level of ash sales with the terms of the new Jim Bridger
Contract.
REQUEST NO. 166: With reference to Company Witness McDougal's Exhibit 40,
page 57 of 350, Ash Sales Revenue, (adjustment 3.8), please provide the source documents and
workpapers supporting the normalized ash sale revenues on the Craig, Naughton, and Cholla
plant in the test period.
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST I9,2O2I
REQUEST NO. 167: With reference to Company Witness McDougal's Exhibit 40,
page 57 of 350, Ash Sales Revenue, (adjustment 3.8), please provide the annual revenues for the
years 2016 through 2020by contract and by plant.
REQUEST NO. 168: With reference to Company Witness McDougal's Exhibit 40,
page 6l of 350, Miscellaneous General Expense & Revenue (adjustment4.l), please provide the
source documents, including invoices, and the workpapers for the Gain on Property Sales
allocated to Idaho. In addition, please provide the source documents, including invoices, and the
workpapers for the adjustments to expense.
REQUEST NO. 169: With reference to Company Witness McDougal's Exhibit 40,
page 75 of 350, Remove Non-recurring Entries (adjustment 4.3), please provide the source
documents, including invoices and any workpapers for the Klamath Settlement Obligation,
including the settlement Accumulated Deferred lncome Tax (ADIT), and the Peak Reliability
Fund entries.
REQUEST NO. 170: With reference to Company Witness McDougal's Exhibit 40,
page 86 of 350, Insurance Expense (adjustment4.T), please provide the actual liability insurance
contracts and premiums, and the actual property insurance contracts and premiums for the years
2016 through202l, to date. Please provide the source documents, including invoices and
workpapers.
REQUEST NO. 171: With reference to Company Witness McDougal's Exhibit 40,
page 87 of 350, Insurance Expense (adjustment 4.7 .l), please provide the source documents,
including any invoices and workpapers to support the Injuries & Damages Reserve balance of
($ 141,041,285).
REQUEST NO. 172: With reference to Company Witness McDougal's Exhibit 40,
page 87 of 350, Insurance Expense (adjustment 4.7 .l), please provide the net cash paid on claims
and net reimbursement from commercial insurance for the years 2016 md2017.
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST I9,2O2I
REQUEST NO. 173: With reference to Company Witness McDougal's Exhibit 40,
page 87 of 350, Insurance Expense (adjustment 4.7.1), please provide the journal entries
supporting the Net Accrued Expense of $139,075,877. Please provide the source documents,
including any invoices and workpapers.
REQUEST NO. 174: With reference to Company Witness McDougal's Exhibit 40,
page 86 of 350, Insurance Expense (adjustment 4.7), please provide the workpapers supporting
the calculation of the Adjustments to Tax, including the Schedule M Adjustments allocated and
directly assigned to Idaho, Defened Income Tax Expense allocated and directly assigned to
Idaho, Accumulated Deferred Income Tax Balance.
DATED at Boise,Idaho, this lqtt.day of August 2021.
Dayn Hardie
Deputy Attorney General
i:umisc:prodreq/pace2 l.Tdhmhjt prod req 6
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST I9,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lgth DAY OF AUGUST 202I,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-21-07, BY E-MAILING A COPY THEREOF, TO THE FOLLOMNG:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : [e-mail]
idahodockets@pac ifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi corp.com
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
[e-mail]
LANCE KAUFMAN
AEGIS INSIGHT
E-MAIL: [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CTTY UT 84116
E-MAIL: emily.wesenerfD.pacificorp.com
matthe'*,. mcvee@pac i flcor?.corn
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 61 19
POCATELLO ID 83205
E-MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX 1391
POCATELLO ID 83204
E-MAIL : rar-rd)r@,racineolson.com
[e-mail]
JAMES R SMTTH
MIKE VEILE
BAYER CORPORATION
E-MAIL: i i m.r. smith[DicIoud.com
mike.vei le@.ba),er.com
KEVIN HIGGINS
COURTNEY HIGGINS
MILLI PICHARO
NEAL TOWNSEND
ENERGY STRATEGIES
E-MAIL: [e-mail]
chi [e-mail]
[e-mail]
ntownsend (C)energy strat. com
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
MLLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL : [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: [e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL : brmullins@.mwanalytics.com
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
SECRE Y
CERTIFICATE OF SERVICE