20210824PAC to Bayer 103-106.pdf

ROCKY MOUNTAIN
FOWER
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 24,2021
Randall C. Budge/Bayer randy@racineolson. com (C)
Thomas J. Budge/Bayer ti @racineolson. com (WXC)
Brian C. Collins/Bayer bcollins@consultbai. com (W)(C)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer khi s g ins@enerey strat. c om (C)
Lance KaufrnanlB ayer I ance @,ae gi sins i ght. com (C )
James R. Smith/Bayer i im.r. smith@ic loud.com (C)
Mike Veile/Bayer mike.vei [e-mail]
Courtney Higgins/Bayer [e-mail]
Milli Picharo/Bayer mpichardo @enersystrat.com
Neal Townsend/B ayer ntown sen d @enerqystrat. co m
RE: ID PAC-E-21-07
Bayer Set 7ft (103-106)
Please find enclosed Rocky Mountain Power's Responses to Bayer 7ft Set Data Request 103-
106. Also provided is Attachment Bayer 106.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-!sl-J. Ted Weston
Manager, Regulation
Enclosures
C.c. : Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC brmull ins@mwanalytics. com
Adam Gardner/PIIC AGardner@idahoan. com (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Eric L. Olsen/IIPA [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/PIIC [e-mail] (W)
Kyle Williams/PIIC williamsk@lbvui. edu (W)
Val Steiner/PIIC val. [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 24,2021
Bayer Data Request 103
Bayer Data Request 103
Rate Base. For each rate base item in RMP witress Steven R. McDougal's RMP
Exhibit 40, please prepare a comparison of RMP's proposed rate base amount
with a 13-month average rate base amount for the period ending December 31,
202I. Please provide this comparison on both a Total Company and Idaho
allocated basis by FERC account and allocation factor. For each rate base item
(e.g. electric plant in service, accumulated provision for depreciation, etc.), please
provide work papers with the monthly balance used for the l3-month average
balance by FERC account and allocation factor.
Response to Bayer Data Request 103
PacifiCorp objects to this request as overly burdensome and requiring the creation
of a new analysis that is beyond the scope of discovery in this proceeding.
Notwithstanding the foregoing objection, the Company responds as follows:
The Company has not performed the requested calculation and to do so would
require gathering new forecasts and projections. The test period in this general
rate case (GRC) has been prepared in a manner that is consistent with the
Company's prior Idaho general rate case proceedings, which the Idaho
Commission has approved. Notably, the use of an end-of-period calendar year
2021testperiod ensures that costs associated with capital invesfnent is used in
useful and properly aligned with customer rates beginning with the January l,
2022 rate effective date proposed in this proceeding.
Recordholder:Justin Waterman
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 24,2021
BayerDataRequest 104
BayerData Request 104
Net Pwer Cost. Please provide the RMP work paper file that converts the output
shown in the Mr. Wilding's Exhibit 37 GRID report to the NPC adjustuents in
the JAIvI/RAM revenue requirement models by FERC accornt and allocation
factor.
Response to Bayer Data Request 104
Please refer to the direct testimony of Company witress, Steven R McDougal,
qpecifically ExhibitNo. 40, page 5.1.1.
Reoordholder: Aaron Rose
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
August 24,2021
Bayer Data Request 105
Bayer Data Request 105
Net Power Cost. Please provide the complete copy of the GRID Report shown in
RMP witress Michael G. Wilding's Exhibit No. 37 that shows the monthly
energy production and cost per unit production by resource. If not clear from the
complete GRID report please provide the monthly energy production included in
GRID model for each phase of Pryor Mountain and TB Flats wind plants.
Response to Bayer Data Request 105
Please refer to the Company's response to PIIC Data Request 2, specifically
Confidential Attachment PIIC 2,fie "ID GRC2I_NPC_FINAL CONF 2021 05
13". Note: the available information in the net power costs (NPC) report is by
resource, not by individual unit.
Recordholder:Lori Oathes
Sponsor:Michael G. Wilding
PAC-E-21-07 / Rocky Mountain Power
August 24,2021
Bayer Data Request 106
Bayer Data Request 106
Craig Unit 2 SCR. Please identifu the plant balances, accumulated depreciation,
and ADIT for this project for each month since it was placed in service through
the end of the test period. Also, identifr the relevant monthly balances included in
RMP's requested revenue requirement. Please provide any documentation and
work papers that support each of the requested amounts in Excel format with
formulas intact.
Response to Bayer Data Request 106
Please refer to Attachment Bayer 106 for the Craig Unit 2 selective catalytic
reduction (SCR) plant balances, accumulated depreciation, and accumulated
defened income taxes (ADIT). The attachment also includes the monthly
balances for those items.
Recordholder:Laura Miller
Sponsor:Steven McDougal