20210831PAC to PIIC-Redacted.pdf

ROCKY MOUNTAIN
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'1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 31,2021
Ronald L. Williams/PIIC ron@williamsbradburv. com
Bradley G. Mullins/PIIC brmullins@mwanalytics. com (C)
Adam GardnerlPIIC AGardner(didahoan. com (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
RE: ID PAC-E-21-07
PIIC Set 2 (22-s4)
Please find enclosed Rocky Mountain Power's Responses to PIIC I't Set Data Requests22-27,
38, 40, 44, arrd 4748. The remaining responses will be provided separately. Provided via e-
mail are the non-confidential Attachments and provided via encryption is the Confidential
Response PIIC 40. Confidential information is provided subject to protected 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 any subsequent 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 [e-mail] (C)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IPA tonv(@yankel. net (C)
Randall C. Budge/Bayer randy @rac ineolson. com (C)
Thomas J. Budge/Bayer [i @racineolson.com (WXC)
Brian C. Collins/Bayer bcollins@consul tbai. com $D(C)
Maurice B rubaker/B ayer mbrubaker@c onsu ltba i. c om (C )
Kevin Higgins/Bayer khi esins@enerey strat. com (C)
Lance Kaufrnan/Bayer lance@ae sisinsisht. com (C)
James R. Smith/Bayer i im. r. smith@ic loud. com (C)
Brad Purdy [e-mail] (C)
Ben Ouo/ICL [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 22
PIIC Data Request 22
Please identifu the historical test period, or base period that is being proposed in
this proceeding, along with the accounting conventions being used (e.g. year-end,
1 3-month averages, etc.).
Response to PIIC Data Request22
Please refer to the direct testimony of Company witness, Steven McDougal,
specifically pages 6 through 8, for the Company's base period, proposed test
period, and rate base accounting convention.
Recordholder:Steve McDougal
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 23
PIIC Data Request 23
Reference McDougal work paper "8.5 - Major Plant Additions", Tab"8.5.2":
Please explain why an adjustnent is necessary for major plant placed into service
in calendar year in 2020 ("e.9. Vantage Pomona Heights 230kV Line") when the
unadjusted results used in this proceeding in the RAM are already based on Year
End balances as of December 31,2020.
Response to PIIC Data Request 23
The in-service date listed on Tab 8.5.2 reflects the in-service date of the listed
asset, but does not represent the date of final project spend. As such, an
adjusfrnent can be required for assets that have in-service dates listed in calendar
year 2020 to include tailing dollars which are required to fully complete a
project.
Recordholder: Steve McDougal
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 24
PIIC Data Request 24
Reference McDougal work paper "6.1 and 6.2Depr and Amort Exp_Reserve",
Tab "6. 1.1": Please explain why an adjustnent is necessary for depreciation
expenses associated with major plant placed into senrice in calendar year 2020
when the unadjusted results used in this proceeding in the RAM are already based
on Year End plant balances as of December 31, 2020.
Response to PIIC Data Request24
Please refer to the Company's response to PIIC Data Request 23.
Recordholder:Steve McDougal
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mormtain Power
August 31,2021
PIIC DataRequest 25
PIIC Date Request 25
Reference McDougal work paper *8.5 - Major Plant Additions", Tab "8.5.2":
Please provide similar project detail for the major plant additions proposed for
calendar year 202A, including the actual cost and in service dates for each project.
Response to PIIC Data Requeat25
Please referto Attachment PIIC 25.
Recordholder: Steve McDougal
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 26
PIIC Data Request 26
Reference McDougal work paper "8.5 - Major Plant Additions", Tab "8.5.2":
Please provide monthly construction work in progress balances and actual
transfers to plant associated with each project identified in the referenced work
paper through July 2021.
Response to PIIC Data Request 26
Construction work in progress (CWP) is not included in the revenue requirement
calculation. The capital addition projects on page 8.5.2 represent in-service
amounts that will be booked to electric plant in-service (EPIS). For a listing of the
acfual plant in-service amounts through July 2021, please refer to the Company's
response to PIIC Data Request 32.
Recordholder: Craig Larsen
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 27
PIIC Data Request 27
Reference McDougal, Di at 38:3-5: Rocky Mountain Power states that "The
Company identified capital projects with expenditues over $5 million that will be
used and useful by December 31, 2021:" Please explain why the expenditures
identified in McDougal work paper *8.5 - Major Plant Additions", Tab "8.5.2"
include several projects with capital budgets of less than $5 million.
Response to PIIC Data Request2T
Certain projects the Company has included are functionalized in multiple Federal
Energy Regulatory Commission (FERC) categories. For example, the Monarch
Upgrade project includes a portion of the project categorized as General plant and
another portion categorized as Intangible plant. The total cost of the project sum
to an amount greater than $5 million. In addition, the Company has included any
trailing dollars of major projects such as the Vantage Pomona Heights 230
kilovolt (kV) Line in which the total project is greater than $5 million.
Recordholder:Steve McDougal
Steve McDougalSponsor:
PAC-E41-07 / Rocky Mountain Power
August 3l,202l
PIIC DataRequest 38
PIIC Dete Request 38
Reference McDougal work paper *8.11 - Cholla 4," Tab "8.11.3", Cell"Cl'l":
Please detail the monthly deprecation expen$es associated with the referenced
value, including detail of the monthly plant balances, and the assumed
depreciation rates.
Response to PIIC Data Request 38
Please referto Attachment PIIC 38 which details the monthly depreciation
expense, gross plant balances, and approved depreciation rates associate.d with the
referenced value.
Recordholder:Ju$us Evangelista
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 3I,2021
PIIC Data Request 40
PIIC Data Request 40
Please identifu all salvage proceeds recognized, or expected, in connection with
the retirement of Cholla 4.
Confidential Response to PIIC Data Request 40
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: Justus Evangelista / Tom Evans
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 44
PIIC Data Request 44
Reference McDougal work paper "8.l I - Cholla 4," Tab "8.l l": Please identifr
the protected EDFIT balances associated with Cholla4 as of December 31, 2020,
and provide a description of how those freed-up EDFIT amounts are being treated
in revenue requirement.
Response to PIIC Data Request 44
All of the Excess Deferred Federal Income Taxes (EDFIT) amortization related to
Cholla Unit 4 was deferred and included in Exhibit No. 43. The total EDFIT
balance related to Cholla Unit 4 that was defened as of December 31, 2020 is
91,643,567, before tax gross-up, or $2,179,409, including tax gross-up. Please
refer to the Company's response to PIIC Data Request 35, specifically
Attachment PIIC 35-2, tab "Attach PIIC 35(b)-2", cells Ml26 and M127. The
Company has proposed to use the remaining non-protected EDFIT balances
consistent with the proposals made in the testimonies of Company witress, Steven
R. McDougal and Joelle R. Steward. Furttrer details on this proposal are included
in Exhibit No. 43.
Recordholder: Brian Keyser
Sponsor:Steve McDougal / Joelle Steward
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 47
PIIC Data Request 47
Reference Attachment 3 of the Phase I Stipulation in Case No. PAC-E-I8-08:
Please provide actual plant in service as of December 31, 2020 for each FERC
Account, FERC sub account, including separate detail for each generation unit
using the same account classifications and level of detail identified in the
referenced Stipulation Attachment.
Response to PIIC Data Request 47
Please refer to Attachment PllC 47 which provides actual plant in service as of
December 31,2020 for the items in Attachment 3 of the Phase I Stipulation in
Case No. PAC-E-I8-08.
Recordholder:Justus Evangelista
Steve McDougalSponsor
PAC-E-21-07 / Rocky Mountain Power
August 31,2021
PIIC Data Request 48
PIIC Data Request 48
Reference McDougal work paper o'6.5 - New Depreciation Study", Tab"6.5.4":
Please explain why there is no adjustnent removing the property plant and
equipment associated with wind property plant and equipment that was retired in
2020 n connection with the repowering program.
Response to PIIC Data Request 48
Assets retired prior to December 31,2020 were already removed from FERC
Account l0l (Electic Plant in Service) in unadjusted data, and therefore no
adjustnent was required on Page 6.5.4.
Recordholder: Steve McDougal
Sponsor:Steve McDougal