20210820PAC to Bayer 81-102.pdf

ROCKY MOUNTAIN
FOWER
A DIVISION OF PACIFICOBP
' ': , ";l Fl' i:: 5;
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
'r.::'i,t- Jlrv
!ir'{
August 20,2021
Randall C. Budge/Bayer randv (Eracineolson. com (C)
Thomas J. Budge/Bayer ti @racineolson. com (W)(C)
Brian C. Collins/Bayer bcollins@consultbai. com (WXC)
Maurice Brubaker/Bayer mbmbaker@consultbai. com (C)
Kevin Higgins/Bayer khiesins@,enereystrat.com (C)
Lance Kaufrnan/Bayer lance @ae sisinsieht. com (C)
James R. Smith/Bayer i im. r. smith@ic loud. com (C)
Mike Veile/Bayer m ike. vei [e-mail]
C ourtrrey Higgins/B ayer ch i s s i n s @enersv strat. com
Milli Picharo/Bayer m pich ardo @en ersy strat.c om
Neal Townsend/Bayer ntownsen [e-mail]
RE ID PAC.E-21-07
Bayer Set 6ft (81-102)
Please find enclosed Rocky Mountain Power's Responses to Bayer 6ft Set Data Request 81-83,
85-89, and93-102. The remaining responses will be provided under separate cover. Also
provided via BOX are non-confidential Attachments and Confidential Attachments.
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 ian.norivuki(Epuc.idaho.eov (C)
Ronald L. Williams/PIIC ron (r?wi I I i amsbradbury. c om
Bradley G. Mullins/PIIC brmullins@mwanalytics. com
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC williamsk@bvui. edu (W)
Val Steiner/PIIC val. [e-mail] (W)
Eric L. OlsenflIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Ben Otto/ICL [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/P[C [e-mail] (W)
Kyle Williams/PtrC [e-mail] (W)
Val Steiner/PIIC 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 20,2021
Bayer Data Request 8l
Bayer Data Request 81
Employee Count. Please identifr each layoff or reduction in force performed by
the Company across its system from 2014 to present. Please include the number
of employees and the actual full time equivalent (FTE) of each layoff.
Response to Bayer Data Request 81
Headcount and full-time equivalent (FTE) counts are provided below. For
purposes of this report, full-time employees are one FTE and part-time, casual,
and temporary employees are 0.5 FTE. Data for 2021is through Ju,ly 2021:
Recordholder: Shelley Zoller
Sponsor:Steve McDougal
Reduction in Force 2014 2015 2016 2017 2018 2019 2020 2021 Total
Headcount 9 154 28 ",29 40 J 4 269
FTE 9.0 154.0 28.0 2.0 27.5 33.0 2.0 3.5 259.0
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 82
Bayer Data Request 82
Employee Count. Please identiff number of retirements by year from 2013 to
present. Please include the number of employees and the actual fulItime
equivalent (FTE) by year.
Response to Bayer Data Request 82
Headcount and full-time equivalent (FTE) counts are provided below. For
purposes of this report full-time employees are one FTE and part-time, casual,
and temporary employees are 0.5 FTE. Data for 2021is through Jru/ry 2A2l:
Recordholder: Shelley Zoller
Sponsor:Steve McDougal
Retirement 2013 2014 2015 2016 2017 201t 2019 2020 2021 Total
Headcount 260 181 230 197 192 187 142 182 142 1.713
FTE 260 180.0 229.0 197.0 192.0 186.5 l4l.s 181.5 141.0 1708.5
PAC-E-21-07 / Rocky Mountain Power
August 18,2021
Bayer Data Request 83
Bayer Data Request 83
Loss of Load Probability. Please provide the loss of load probability by month,
year, and jurisdiction for the Company's most recently completed loss of load
study.
Response to Bayer Data Request 83
The Company's most recently completed loss of load analysis was prepared as
part of its 2019 Integrated Resource Plan (IRP), as described in Appendix N
(Capacity Contribution Study). The final loss of load analysis in the 2019 IRP was
based on a portfolio that was very similar to the 2019 IRP preferred portfolio and
was conducted using a study period of 2030. The Company did not report data
necessary to identiff loss of load probability (LOLP) by jurisdiction or for other
years as part of this analysis.
For monthly detail on the loss of load events (LOLE), please refer to file
"Composite Reliability Event Summer-Wnter]0l9 l0 04 CONF.xlsx" which
was provided on the confidential data disk supporting PacifiCorp's 2019 IRP. For
ease of reference, this file is attached as Confidential Attachment Bayer 83. A
summary of LOLE by month and hour is provided on tab "Hourly LOLP", cells
J4:AGI5. The totals shown reflect events across 500 iterations of calendar year
2030 conditions.
The Company's 20l9IRP is publicly available and can be accessed by utilizing
the following website link:
Resource Plan ific com
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:Dan MacNeil
Sponsor:Steve McDougal
PAC.E-21-07 / Rocky Mountain Power
August 20,2021
Bayer DataRequest 85
Bayer Data Requost 85
Cepital Addifions. Please provide documentation of PacifiCorp's capital project
approval ptocess.
Response to Beyer Deta Request 85
Please referto the Companl.'s response to IPUC DataRequest 35.
Recordholder: Various
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 86
Bayer Data Request 86
Capital Additions. Please provide PacifiCorp's capitalization policy. Please
include a description of how overhead and labor loadings are determined for
individual projects.
Response to Bayer Data Request 86
Please refer to the Company's response to IPUC Data Request 35, specifically
Attachment IPUC 35-l which provides a copy of PacifiCorp's capitalization
policy. Capital overhead is described in PacifiCorp's capitalizationpolicy under
the Capital Surcharge section. Please refer to Confidential Attachment Bayer 86
which provides a copy of the memorandum describing labor loadings.
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: Dean Wirick
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 87
Bayer Data Request 87
Capital Additions. Please provide the following data for each capital addition
made from 2014 to present for each project with more than $500,000 of gross
capital allocated to Idaho:
(a) Original system capital addition,
(b) Applicable allocation factor,
(c) Net amount included in rate base for this case,
(d) Date or dates that project was transferred to plant,
(e) Capital expenditure by month,
(f) Amount of AFUDC included in the project,
(g) All project management and capital approval documentation, and
(h) Basis for any cost ovemrns above the originally approved budget.
Response to Bayer Data Request 87
PacifiCorp objects to this request as unduly broad, overly burdensome and not
reasonably calculated to lead to admissible evidence. Without waiving the
foregoing objection, PacifiCorp responds as follows:
(a) Please refer to the Company's response to IPUC Data Request 48 and IPUC
Data Request 49 for capital additions of $2 million or more, total company.
(b) Generation and transmission investments are allocated on a system generation
(SG) allocation factor, and distribution plant is situs assigned to Idaho.
(c) PacifiCorp objects to subparts (c) through (f), and subpart (h) as unduly
burdensome. Responding to these questions would require running extracts for
each capital project to identify gross plant, accumulated depreciation, and
allowance for funds used during construction (AFUDC), then the accumulated
deferred income tax (ADIT) balance would need to be calculated. The date a
project is transferred to plant in-service between 2014 through2D2l does not
provide meaning information relevant to the Company's requested revenue
requirement nor does capital expenditures by month or the amount of AFUDC
included in the project.
PAC-E-21-07 / Rocky Mountain Power
Auggst 24,2021
Bayer Data Request 87
(g) Ploare refer to the Company's response to IPUC DaA Roquest 48 and IPUC
Data Request 49 for capital approval documentation.
Recordholder: Various
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 88
Bayer Data Request 88
Capital Additions. Please provide the following data for each project not
included in Request No. 87 but included in the test year ratebase for each project
with more than $500,000 of gross capital allocated to Idaho:
(a) Amount of AFUDC included in the project,
(b) A11project management and capital approval documentation, and
(c) Basis for any cost ovemrns above the originally approved budget.
Response to Bayer Data Request 88
PacifiCorp objects to this request as unduly broad, overly burdensome and not
reasonably calculated to lead to admissible evidence. V/ithout waiving the
foregoing objection, PacifiCorp responds as follows:
Please refer to the Company's response to Bayer Data Request 87
Recordholder:Various
Sponsor:Steve McDougal
PAC-E-2l-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 89
Bayer Data Request 89
Capital Additions. Please refer to Exhibit No. 40 Page 162 of 350 which
identifies two fire damage related capital projects. Please provide the following
data for the referenced projects and all other fire damage related projects included
in response to Request No. 87 and 88:
(a) If project is outside of Idaho, amount of situs capital additions associated with
the fre.
(b) PacifiCorp's basis for assigning costs to system and situs accounts.
(c) Whether the fire was associated with PacifiCorp equipment or employees
Response to Bayer Data Request 89
The Company assumes that the reference to "Request No. 87 and 88" is intended
to be a reference to Bayer Data Request 87 and Bayer Data Request 88. Based on
the foregoing assumption, the Company responds as follows:
a. Archie Creek Fire Damage Repair was entirely a transmission line
repair/replacement in Oregon. Slater Fire Damage (Happy Ca*p) was also a
transmission line repair/replacement mainly in California with a very small
portion occurring in Oregon. Both fires damaged transmission facilities,
therefore no situs capital additions were associated with these fres.
b. FERC's Code of Federal Regulations for the Uniform System of Accounts
define where costs are assigned. Costs associated with transmission assets are
system allocated cost associated with distribution assets are situs assigned per
the 2020 Protocol.
The cause of the fires is under investigation.c
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 fuither subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Jeff Keyser
Steve McDougalSponsor
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 93
Bayer Data Request 93
Load Forecast. Please refer to the Direct Testimony of Michael G. Wilding.
Please provide the load forecast used in the test year net power cost forecast.
Please provide such forecast at the most granular level available. Please provide
all work papers supporting the forecast, including all load forecast model inputs,
assumptions, and mathematical specifications.
Response to Bayer Data Request 93
The Company interprets the reference to "load forecasf'to mean the load forecast
for calendar 2021 used in this general rate case (GRC) for forecasting net power
costs (NPC). The Company further clarifies that for the purposes of forecasting
NPC in PacifiCorp's Idaho GRC, the202l load forecast is based on actual load
for calendar year 2020 rotated to match the same day of the week for calendar
year 2021. Based on the foregoing interpretation and clarification, the Company
responds as follows:
Please refer to Confidential Attachment Bayer 93 which provides the load
forecast data used in this Idaho GRC. Specifically refer to tab *2020 Actuals
(MUf)" for the Generation and Regulation Initiative Decision Tool (GRID) input,
and tab "2021Forecast (MW)" for the mathematical specification.
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 20,2021
Bayer Data Request 94
Bayer Data Request 94
Load X'orecast. Please provide PacifiCorp's current 10-year business plan.
Response to Bayer Data Request 94
PacifiCorp assumes that the subject title of "Load Forecasf in this data request is
in error and that this request is seeking access to PacifiCorp's current l0-year
business plan. Based on the foregoing assumption, the Company responds as
follows:
PacifiCorp's l0-year business plan is highly confidential and commercially
sensitive. The Company requests special handling. Please contact Ted Weston at
[phone] to make arrangements to review.
Recordholder:Ted Weston
Sponsor:To Be Determined
PAC-E-2I-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 95
Bayer Data Request 95
Load Forecast. Please provide the load forecast used in PacifiCorp's current 10-
year business plan. Please provide such forecast at the most granular level
available. Please provide all workpapers supporting the forecast, including all
load forecast model inputs, assumptions, and mathematical specifications.
Response to Bayer Data Request 95
The Company objects to this request on the grounds that it is not reasonably
calculated to produce admissible evidence in this proceeding. PacifiCorp's Idaho
general rate case (GRC) is based on historical data and does not utilize the
requested 10-year business plan forecast. The Company further objects to this
request on the grounds that it is unduly burdensome. The Company interprets
"PacifiCorp's current 10-year business plan" to refer to the Company's 2021
budget forecast. Without waving the foregoing objections and given that
interpretation the Company responds as follows:
Please refer to the Company's response to PIIC Data Request 20, specifically
Confidential Attachment PIIC 20-1 which provides the hourly jurisdictional
forecast.
Please refer to Confidential Attachment Bayer 95, specifically the "data" tab for
the inputs, and the "coefficients" tab for the mathematical specifications of each
model. Note: the dependent variable, model coefficients and model predictions
have been redacted from the commercial use per day models in Oregon and Utah,
and the industrial use per day models in Califomia, Idaho, Utah and East
Wyoming to protect the confidentiality of individual customer information in
those jurisdictions.
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:Lee Elder
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 96
Bayer Data Request 96
Expenses. Please provide the system and Idaho allocated utility revenue and
expense by month and FERC account and subaccount from January 2014ta
present.
Response to Bayer Data Request 96
Due to the volume of data requested, completion of the request on a monthly basis
would require a significant amount of time and resources to complete. Please refer
to Attachment Bayer 96 which provides the Company's Idaho Results of
Operations (ROO) that have been filed with the Idaho Public Utilities
Commission (IPUC) for2014 through 2019. Details of total-Company and Idaho
allocation utility revenue and expenses by FERC Account and subaccount are
available in the below "B-Tabs" within each report:
Bl - Electric Operations Revenues
B2 - Operations and Maintenance Expense
83 - Depreciation Expense
84 - Amortization Expense
85 - Taxes Other Than Income
86 - Interest Expense and Schedule M
87 - Defened Income Tax Expense and ITC Amortization
The2020 ROO were provided as Exhibit No. 40 to Steven R. McDougal's
testimony. The202l Idaho ROO will become available for review on or around
April 30,2022.
Recordholder: Steven McDougal
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 97
Bayer Data Request 97
Other Revenue. Please refer to Exhibit No. 40 Page 56 of 350. Please provide the
joint-use agreements and provide the basis for the forecasted revenue on the
referenced page.
Response to Bayer Data Request 97
Please refer to Confidential Attach Bayer 97 for the joint-use agreements. The
basis for the forecasted revenues is the two agreements to attach devices on the
Company' s streetJight poles.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idalrc 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:Virginia Trask
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 98
Bayer Data Request 98
COVID-l9. Please to the Direct Testimony of Gary W. Hoogeveen at page7.
(a) Please identiff all costs incurred lr:.2020 to accommodate transitioning
employees to work from home.
(b) Please identiff all costs incurred n2020 to accommodate social distancing.
(c) Please identiff all costs incurred n2020 to accommodate enhanced sanitation
measures.
(d) Did PacifiCorp engage any thfud party to assist in its response to COVID? If
yes, please identiff each engagement and the total amount billed n2020.
(e) Please identiff all costs incurred l-rl2020 incurred in response to COVID and
not addressed in subparts (a) through (d) above.
(f) Please identiff all adjustments PacifiCorp made to the test year expenses to
remove items identified in subparts (a) through (e) above.
(g) Please identiff all adjusftnents PacifiCorp made to account for the impact of
COVID on late fees.
Response to Bayer Data Request 98
The following costs and savings are on a Total Company basis:
(a) The Company incurred $503,870 :.rl,2020 to accommodate transitioning
employees to work from home.
(b) The Company incurred $2,234,464 lr:,2020 to accommodate social distancing.
(c) The Company incurred $1,576,942:.r:,2020 to accommodate enhanced
sanitation measures.
(d) The Company followed state mandates in its response to the COVID-I9
pandemic. Costs incurred as a result of the Company's response to the
pandemic, including any third-party costs, are reflected in subparts (a) through
(c) above.
(e) In addition to the costs identified in subparts (a) through (c) the Company also
experienced approximately $7,000,000 of offsetting cost reductions to travel
and other areas in 2020 as a result of the COVID-I9 pandemic.
PAC-E21-07 / Rocky Mormtain Power
August 20,2fr21
Bayer DataRequest 98
(D No adjushents were made ftom the Base Period actual experrs€s to reflect the
Test Year used in this general rate case (GRC) proceeding.
(g) Please refer to the Company's response to subpart (f) above.
Recordholder: Heather Loechle / Steve McDougal
Sponsor: Steve McDorrgal
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 99
Bayer Data Request 99
Affiliated Interests. Please refer to page 2l of PacifiCorp' s 2020 Affiliated
Interest Report (https://edocs.puc.state.or. us/efdocs/t IAQ/re69haq I 0845.pdf)
o'Summary of transactions included in Section II for the Year Ended December
31,2020." For affiliates where both ownership interest exceeds 50 percent and
'Non-ISIA Goods and Services Total Received and Provided" is greater than $l
million please provide the basis for transfer prices used in 2020.
Response to Bayer Data Request 99
The basis of pricing for affrliates where both ownership and interest exceeds 50
percent and'Non-ISIA Goods and Services Total Received and Provided" is
greater than $1 million are as follows:
BNSF Railway Company - negotiated prices under long-term contacts for
rail services and right of way fees are based on factors of square footage.
o
a
a
Marmon Utility LLC - standard business pricing for materials.
BHE Wind,LLC - purchase and sale agreement for equipment transfer
Kern River Gas Transmission Company - tansportation services are based on
tariff rate on file wittr the Federal Energy Regulatory Commission (FERC);
power line crossing based on employee labor and third-party design costs.
MidAmerican Energy Company - services performed under Intercompany
Mutual Assistance Agreement with a true-up the following year.
Nevada Power Company - electricity fransmission services are provided
under Nevada Power open access transmission tariff (OATT) pricing;
wholesale energy purchases and sales are a negotiated rate capped by selling
entity's cost.
a Bridger Coal Company - coal purchases are priced at Bridger Coal's cost plus
a margin, with the margin being eliminated by inventory and fuel expense
based on generally accepted accounting principles (GAAP); Information
Technology (IT) and Administative Services are charged as a fully loaded
direct cost plus administrative and general (A&G) expense.
Recordholder: Rhiannon Wood
o
a
o
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 100
Bayer Data Request 100
Affiliated Interests. Please refer to page 79 of PacifiCorp's 2020 Affiliated
Interest Report (https ://edocs. puc. state. or. us/efdocs/FIAQ/re69haq I 0845. pdf)
"BHE Wind, LLC Affiliated Transactions".
(a) Please provide all contacts and agreements between PacifiCorp and BHE
Wind, LLC.
(b) Please provide all costs incuned by BIIE Wind, LLC to procure and deliver
the $147,029,375 of wind turbine equipment in the referenced page. Please
include supporting invoices and transaction details.
Response to Bayer Data Request 100
(a) Please refer to Confidential Attachment Bayer 100-1.
(b) Please refer to Confidential Attachment Bayer 100-2.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the ldaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Ajay Kumar / Timothy J. Hemstreet
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request l0l
Bayer Data Request 101
Nodal Pricing. Do test year expenses or ratebase include any costs associated
with ransitioning to nodal price or locational marginal price dispatching? If yes,
please:
(a) Identi$ the amounts and indicate where they appear in the company's filing,
(b) Explain why the Company is incurring such costs, and
(c) Explain how the Company has accounted for the benefits associated with
these costs.
Response to Bayer Data Request 101
(a) The amounts are included in Adjusfinent 5.2 Nodal Pricing provided in
Exhibit No. 40, pages 107-109. Please refer to Attachment Bayer 101 for an
electronic copy of Adjusftnent 5.2.
(b) This adjustrnent adds the software related rate base and on-going operations
and maintenance (O&M) costs for the Nodal Pricing Model (NPM) as agreed
upon in the Multi-State Process (MSP) filed in Case No. PAC-E-I9-20,
Appendix D.
(c) All benefits associated with the NPM will flow through net power costs. The
purpose of the NPM is to facilitate each state's energy policies and unique
resource portfolios while seeking to maintain the benefits of system dispatch
and optimization. The NPM is needed for on-going work during the interim
period of the 2020 Protocol.
Recordholder: Craig Larsen
Sponsor Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 20,2021
Bayer Data Request 102
Bayer Data Request 102
Net Power Costs. Please refer to the Public Utility Commission of Oregon
DocketNo. UE 390 PAC 400 Staples Page 5lines 14 to 17.
(a) Does PacifiCorp believe that Oregon Commission Staff s proposal to improve
Energy Imbalance Market (EIM) Benefits Modeling would improve NPC
estimates for Idaho? If no, why not?
(b) Does PacifiCorp believe that Oregon Commission Staff s proposal to improve
the modeling of greenhouse gas (GHG) benefits would improve NPC
estimates for ldaho? If no, why not?
(c) Does PacifiCorp believe that AWEC's proposal to update the production tax
credit (PTC) rate would improve NPC estimates for Idaho? If no, why not?
Response to Bayer Data Request 102
(a) Yes, PacifiCorp believes that the proposal regarding energy imbalance market
(EIIO benefits modeling presented by the Public Utility of Oregon
Commission (OPUC) staffin DocketUE-390 (2022 transition adjustnent
mechanism (TAM) would improve the accuracy of the net power costs
(NPC) estimate for Idaho. The adjustment was accepted in the July 2021 NPC
update of the 2022TAl[vd and is not specific to any particular time period.
(b) No, PacifiCorp does not believe that the proposal regarding greenhouse gas
(GHG) benefits modeling presented by OPUC in Docket UE-390 could
improve the accuracy of the NPC estimate for Idaho. The adjustnent was
accepted in the Jltly 2021NPC update of the 2022TAM, but it applied
specifically to the 2022benefrt forecast. As this Idaho general rate case
(GRC) proceeding uses a 2021 test period, the proposed update would not
apply.
(c) No, PacifiCorp does not believe that the proposals regarding the production
tax credits (PTC) rate presented by the Alliance of Western Energy
Consumers (AWEC) in Docket UE-390 would improve the accuracy of the
NPC estimate for Idaho. The adjustment was accepted in the July 2021 NPC
update of the 2022TAM, but it applied specifically to the 2022PTC benefit
forecast. As this Idaho GRC proceeding uses a 2021test period, the proposed
update would not apply.
Recordholder:Lori Oathes / Douglas R. Staples
Mike WildingSponsor: