20210820Bayer 111-130 to PAC.pdf

:i!i:;:.jRandall C. Budge,ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box 1391; 201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
IN THE MATTER OF THE APPLICATION
OF ROCKY MOTINTAIN POWER FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AI\D
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDTILES AND
REGULATIONS
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Attorneys for Intervenor P4 Production, L.L.C., an ffiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E-2I.07
BAYER CORPORATION'S
TENTH SET OF DATA
REQUESTS TO ROCKY
MOUNTAIN POWER
P4 Production, L.L.C., an affiliate of Bayer Corporation (hereinafter "Bayer"), by and
through its attorneys, hereby submits this tenth set of Data Requests to Rocky Mountain Power,
pursuant to Rule 225 of the ldaho Public Utility Commission's Rules of Procedure, IDAPA
31.01.01.
This Data Request is to be considered continuing, and Rocky Mountain Power 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 the
person preparing the documents. Please identiff the name, job title, location and telephone number
ofthe record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
BAYER CORPORATION'S TENTH SET OF DATA REQUESTS TO ROCKY MOI.INTAIN POWER -
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Bayer Set 10
Request No. 111: Coal Costs. Please provide the Bridger Coal Mine 1O-year
plan.
Request No. 112: Coal Costs. Please provide all planning documents related to
the closure of the Bridger Coal Mine underground mine.
Request No. 113: Coal Costs. Please explain how PacifiCorp intends to dispose
of underground mine assets.
Request No. 114: Coal Costs. Please refer to Exhibit No. 40 Page 8.3, Jim
Bridger Rate Base. Please provide the Bridger Coal Mine plant records documenting the
rate base identified in this page. Please indicate which assets serve underground mining
operations.
Request No. 115: CoaI Costs. Please provide the Bridger Coal Company coal
prices assumed in the net power cost forecast. Please include all supporting
documentation used to calculate such prices, including depreciation expense. Please
identi$ the portion of depreciation expense associated with assets used in the
underground mining operation.
Request No. 116: Coal Costs. Please provide the Net Power Cost forecast with
the depreciation and amortization expense associated with the underground mine
excluded from the BCC coal prices, under the assumption that Idaho's share of the
remaining balance of underground mine assets are offset against a portion of the Tax Cuts
and Jobs Act deferral balance. Such prices should continue to include other operating
expense associated with the underground mine.
Request No. 117: Pryor Mountain. Please refer to the Direct Testimony of Rick
T. Link, Section V.a. Please identiff all transmission used to move energy from Pryor Mountain
to and through PacifiCorp's system.b. Did the addition of Pryor Mountain increase transmission congestion on
PacifiCorp's system in any of the years modeled?c. How did PacifiCorp account for the cost of transmission or transmission
constraints due to Pryor Mountain?d. Please provide all transmission studies performed by or on behalf of
PacifiCorp related to Pryor Mountain, including any studies performed prior to
PacifiCorp's acquisition of the project.e. Please provide the GRID model results for 2021with and without Pryor
Mountain. Please include energy curtailments by transmission bubble and the value of
curtailed energy. Please also include a graphic representation of the GRID transmission
topology. If the company declines to provide such data please provide access to the 2021
GRID model.f. Please provide a graphic representation of the transmission topology
modeled in PaR analysis of the referenced testimony. Please explain how the PaR
analysis accounts for transmission constraints.
Request No. 118: Pryor Mountain. Please refer to the Direct Testimony of Rick
T. Link, Section V.a. Please provide the annual capital expenditure assumed by year in the
BAYER CORPORATION'S TENTH SET OF DATA REQUESTS TO ROCKY MOLINTAIN POWER -)
analysis presented in the referenced testimony.b. Did PacifiCorp perform any sensitivity analysis evaluating economic
performance of Pryor Mountain under a shorter economic life, such as 20 or 25 yearc? lf
no why not?c. Do the values in Table 3 and Figure 4 reflect the cost increases noted in
the Direct Testimony of Robert Van Engelenhoven? If no, please provide these tables
updated to reflect actual costs or provide the data necessary to perform such updates.d. Does the PVRR analysis performed by Mr. Link reflect additional
AFUDC associated by the early procurement of turbines to qualifu for production tax
credits? If no, why not?
Request No. 119: Pryor Mountain. Please refer to the Direct Testimony of Rick
T. Link, Section V Figure 4.a. Please explain why the change in revenue requirement decreases
substantially in2028.b. Please explain why the change in revenue requirement increases
substantially in 2031.c. Please explain why the change in revenue requirement decreases
substantially in 2050.d. Do the values in Figure 4 reflect declining plant balances?
Request No. 120: Pryor Mountain. Please refer to the Direct Testimony of
Robert Van Engelenhoven Section II[. Please provide the following data related to the
Pryor Mountain project:
a. Please provide the dates for all notices to proceed.
b. Please provide expense by month.c. Please provide transfers to plant by month
Request No. 121: Load. Please provide PacifiCorp's hourly load by jurisdiction
from2014 to present.
Request No. 122: Generation. Please provide PacifiCorp's hourly generation,
including PPAs and QFs, from January 1,2019 to present, separately for dispatchable and
non-dispatchable resources.
Request No. 123: Wind Generation. Please refer to
hups://wwwjustice.gov/opa/prlutility-company-sentenced-wyoming-killing-protected-
birds-wind-proj ects-0a. Please provide copies of the court orders and rulings for the cases
referenced. Please also provide copies of any wriffen briefs, expert reports, and expert
testimony that were submitted in the case record.
b. Does PacifiCorp agree with the referenced article's assertion that
compliance costs were estimated at $600,000? If no, why not?c. Please provide the 2020 compliance costs associated with this plea
agreement by FERC account.d. Does the amounts in part c. reflect wind curtailment to avoid avian deaths?
If no, please provide the change in202l Net Power Costs if avian related curtailments are
eliminated from the wind generation profile for Dunlap.
Request No. 124: Plant Additions. Please refer to Exhibit No. 40 Page 8.5.2.a. Please provide all workpapers used to allocate or assign expenses and
revenues for the Lloyd center between utility and non-utility.
BAYER CORPORATION'S TENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER -
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b. Please provide budgeted and actual expenses andrevenues forthe Lloyd
center by month and account from January 2018 to December 2021.c. Please explain why the C7 Data Center Load Increase project is not
directly assigned to the associated customer or jurisdiction.
d. Has PacifiCorp adjusted test year expenses to account for AMI
infrastructure labor reductions? If no, why not?
Request No. 125: Property Tax. Please provide PacifiCorp's Cholla property
tax payment by year in2019,2020, and202l.
Request No. 126: Property Tax. Please refer to Confidential Exhibit 42.a. Please provide workpapers supporting the2020 and202l assessed values
for each state.b. Does the 2021 assessed value for Arizona reflect the impact of closing
Cholla on Cholla property tax assessment? If no, why not?
Request No. 127: Depreciation. Please refer to the Direct Testimony of Steven
R. McDougalatpage22.a. Please provide the impact of the change in probable retirement dates for
steam plants in the referenced depreciation study on Idaho allocated depreciation expense
in this case. Please provide such data by plant.b. Does the early closure of Colstrip, Jim Bridger, and Craig units reduce
PacifiCorp's revenue requirement in post closure years? If no, why did PacifiCorp
accelerate the planned retirement date for these units?c. Does the early closure of Colship, Jim Bridger, and Craig units increase
PacifiCorp's revenue requirement in pre closure years?
d. Please provide the current agreement among Colstrip 3 and 4 owners
regarding the end of operation date for these units. Please indicate if PacifiCorp
supported this date in discussions with other owners.e. Does PacifiCorp currently expect Colstrip 3 and 4 to operate beyond
2027? If no, why not?
Request No. 128: Expenses. Please provide transaction details for non-labor
costs recorded FERC accounts n2020. Please include:a. Total amount chargedb. Assignments and allocations to Utility/non-utility.c. Assignments and allocations to Idaho.d. Description of cost.e. Business unit charged.f. All other transaction detail generally maintained.g. Please include atable describing each code, account, or subaccount used.
Request No. 129: Load. Please provide the documents produced in response to
Bayer Data Request 2l and24 for 2021to date.
Request No. 130: Transmission. Does the Company attach sub-transmission and
transmission conductors to the same poles or towers for any portion of the transmission
system? If yes, please explain how the cost of such poles and towers are allocated
between plant accounts. If no, why not?
BAYER CORPORATION',S TENTH SET OF DATA REQLJESTS TO ROCKY MOLINTAIN POWER -
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DATED this 206 day of August,2O2l.
RACINE OLSON, PLLP
By:0.
C.
BAYER CORPORATION',S TENTI{ SET OF DATA REQUESTS TO ROCKY MOIJNTAIN POWER -
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CERTTFICATE OF MAILING
I HEREBY CERTIFY that on this 20tr day of August,202l,I caused to be served a true and
correct copy of the foregoing document upon the following individuals in the manner indicated below:
RACINE OLSON, PLLP
By:At/"
RANDALL C. BUDGE
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720, Boise ID 83720-0074
11331 W. Chinden Blvd, Bldg. 8, Suite 201-A
Boise,lD 83714
Jan.noriyuki@puc. idaho. gov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake ciry, uT 84116
ted.weston@pacifi corp. com
Data Request Response Center
PacifiCorp
datarequest@pac i fi c orp. c om
Dayn Hardie
John Hammond, Jr.
Deputy Attorneys General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
[e-mail]. gov
i ohn.hamrnond@puc. idaho. gov
Emily L. Wegener
Matthew D. McVee
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
Emily. weeener@pacifi corp. conr
Matthew. mc vee (E pac i fi c orp. com
Eric L. Olsen
Attorney for ldaho lruigation P umpers
Association, Inc. (IIPA)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6l l9
Pocatello,Idaho 83205
[e-mail]
BAYER CORPORATION'S TENTH SET OF DATA REQUESTS TO ROCKY MOT.INTAIN POWER -
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Bradley Mullins
MW Analytics, Energy & Utilities
bnnullins@mwanalytics. com
James R. Smith
Bayer Corporation
P4 Production, L.L.C.
371 S. 3rd West
Soda Springs, Idaho 83276
i im.r. [e-mail]
Brian C. Collins
Maurice Brubaker
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]
mbrubaker@ consultbai. com
Kevin C. Higgins
Courtney Higgins
Neal Townsend
Milli Pichardo
Energy Strategieslll EastBroadway, Suite 1200
Salt Lake City, Utah 84111
khi q gins@ energystrat. com
chi g gins@enerqystrat. com
ntownsend @.enersv strat. com
mpichardo@energystrat. com
Ronald L. Williams
Attorney for P acifiC orp Idaho Industrial
Customers (PIrc)
WILLIAMS BRADBURY, P.C.
P.O. Box 388
Boise,ID 83701
[e-mail]
PIIC Electronic Service Only:
Val Steiner: Val. [e-mail]
Kyle Williams: [e-mail]
Adam Gardner: AGardner@idahoan. com
Mike Veile
Bayer Corporation
P4 Production, L.L.C.
P.O. Box 816
Soda Springs, Idaho 83276
[e-mail]
Lance Kaufinan
Aegis Insight
2623 NW Bluebell Place
Corvallis, Oregon 97330
lance@aegisinsi sht.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, lD 83702
botto@idahoconservation. org
BAYER CORPORATION'S TENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER -
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Brad M. Purdy
Attorney for C ommmity Action P mtner ship
Association of Idalw
2019N. 17rh St.
Boise,ID. 83702
[e-mail]
BAYER CORPORATION',S TENTIT SET OF DATA REQLTESTS TO ROCI(Y MOLJNTAIN POWER -
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