20210902PAC to PIIC 22-54.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 2, 2021
Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail] (C) Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
RE: ID PAC-E-21-07
PIIC Set 2 (22-54)
Please find enclosed Rocky Mountain Power’s Responses to PIIC 2nd Set Data Requests 28-31, 33-37, 39, 41-43, 45-46, 49, and 53-54. The remaining responses will be provided separately.Provided via e-mail are the non-confidential Attachments and provided via encryption and BOXis the Confidential Response PIIC 43 and Confidential Attachment PIIC 35-1. Confidential
information is provided subject to protected under IDAPA 31.01.01.067 and 31.01.01.233, theIdaho Public Utilities Commission’s Rules of Procedure No. 67 – Information Exempt fromPublic 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,
____/s/____ J.Ted WestonManager, Regulation
Enclosures C.c.: Jan Noriyuki/IPUC [e-mail] (C)Eric L. Olsen/IIPA [e-mail] (C) Anthony Yankel/IIPA [e-mail] (C) Randall C. Budge/Bayer [e-mail] (C)
Thomas J. Budge/Bayer [e-mail] (W)(C)
Brian C. Collins/Bayer [e-mail] (W)(C) Maurice Brubaker/Bayer [e-mail] (C) Kevin Higgins/Bayer [e-mail] (C) Lance Kaufman/Bayer [e-mail] (C) James R. Smith/Bayer [e-mail] (C) Brad Purdy [e-mail] (C) Ben Otto/ICL [e-mail] (C)
RECEIVED
2021 SEP 2 PM 4:56
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 28
PIIC Data Request 28 Reference McDougal work paper “8.5 - Major Plant Additions”, Tab “8.5.2”: For each project where the in service date is listed as various, please provide a
monthly schedule of transfers to plant assumed for each such project.
Response to PIIC Data Request 28
Please refer to Attachment PIIC 28. The intangible portion of the project Monarch
upgrade in-service date was listed as various on page 8.5.2. It should have been listed as Sep-21. Recordholder: Craig Larsen
Sponsor: Steve McDougal.
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 29
PIIC Data Request 29 Reference McDougal work paper “8.5 - Major Plant Additions, Tab “8.5.2”, Cell “G46”, Project “AMI - Idaho 2019 meters”:

(a) Please provide a work paper detailing the calculation of the hardcoded value in the referenced cell.
(b) Please explain why Rocky Mountain Power is proposing an adjustment for
meters placed into service in 2019, prior to the start of the test period. (c) Please provide a general explanation of Rocky Mountain Power’s AMI program in Idaho and the nature of the referenced pro-forma adjustment.
(d) Please identify the transfers to plant by month associated with Rocky
Mountain Power’s Idaho AMI program over the period January 1, 2016 through July 31, 2021.
(e) Please identify the plant in service associated with Idaho meter retirements by
month over the period January 1, 2016 through July 31, 2021. (f) Please state the % of customers by rate schedule with an AMI meter deployed as of December 31, 2019, December 31, 2020 and July 31, 2021. Response to PIIC Data Request 29
(a) Please refer to Attachment PIIC 29-1.
(b) “AMI – Idaho 2019 meters” is the name of the project based on when the project was first set-up. The $6,995,000 included in the revenue requirement for this proceeding includes only 2021 in-service amounts. (c) The Idaho Advanced Metering Infrastructure (AMI) project involves replacing approximately 87,000 existing Idaho-customer meters with a comprehensive, advanced metering system. The AMI system includes the installation of new meter technology and telecommunications infrastructure needed for Rocky
Mountain Power to establish two-way communication with meters. The enhanced functionality achieved with the project will enable remote meter reading, presentation of hourly interval consumption data directly to customers, remote connect and disconnect capabilities and improved outage restorations via outage notifications received directly from the meter. The AMI system also positions Rocky Mountain Power to take advantage of additional smart grid technologies as they become available and economically feasible. As mentioned in part b, the pro-forma adjustment is for 2021 in-service amounts.
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 29
(d) Please refer to Attachment PIIC 29-2. (e) No meter retirements related to the AMI project occurred over the period
January 1, 2016 through July 31, 2021. AMI meter retirements are
scheduled to begin in Q4 2021. (f) No AMI meters were installed as of December 31, 2019, December 31,
2020 or July 31, 2021. AMI meter installations are scheduled to begin in
Q4 2021. Recordholder: Craig Larsen / Trevor Stuart
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 30
PIIC Data Request 30 Reference McDougal work paper “8.5 - Major Plant Additions, Tab “8.5.2”, Cell “G25”, “Lloyd Center Tower Open Office”:

(a) Please provide a description of the referenced capital project, including supporting project justification forms and project approvals from management.

(b) Did the referenced project result in the retirement of previous leasehold improvements at the Lloyd Center? If yes, please identify the plant in service that was, or will be retired, in connection with the referenced project. (c) Please state the date that Rocky Mountain Power expects the project to be
completed.
Response to PIIC Data Request 30
(a) Please refer to Confidential Attachment PIIC 30 which includes the
description and documentation for the Lloyd Center Tower Open Office project (LCT Project). The description for the LCT Project is provided in the LCT Open Office Plan Financial Review_2019 within Confidential Attachment PIIC 30 and is stated as follows:
“It is recommended that the company spend approximately $30 million
remodeling the Lloyd Center Tower (LCT) to a concept that allows for greater employee engagement. The remodel is expected to create a sustainable competitive advantage ultimately benefitting customers through higher
employee retention and recruitment, enhanced productivity, and greater
operational performance. PAC also evaluated the alternative of constructing an equivalent sized building with the same collaborative design concept. The LCT Open Office Plan is recommended because it would result in a $1.6 million present value revenue requirement benefit to customers over relocating.”
(b) The LCT Project involved no retirements of leasehold improvement assets.
(c) The Company expects the project to be completed by December 31, 2022. The LCT Project is being placed into service in phases. The general rate case (GRC) includes the projected 2021 additions.
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.
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 30
Recordholder: Jeff Keyser / Marcy Lanners / Laura Miller
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 31
PIIC Data Request 31 Reference McDougal work paper “8.5 - Major Plant Additions, Tab “8.5.2”, Cell “G25”, “Lloyd Center Tower Open Office”:

(a) Please provide a description of the referenced capital project, including supporting project justification forms and project approvals from management.

(b) Did the referenced project result in the retirement of previous leasehold improvements at the Lloyd Center? If yes, please identify the plant in service that was, or will be retired, in connection with the referenced project. (c) Please state the date that Rocky Mountain Power expects the project to be
completed.
Response to PIIC Data Request 31
Please refer to the Company’s response to PIIC Data Request 30.
Recordholder: Not applicable Sponsor: Not applicable
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 33
PIIC Data Request 33 Reference McDougal work paper “8.5 - Major Plant Additions, Tab “8.5.2”, Project Transmission Wildfire Mitigation:

(a) Please explain why there are two projects identified as wildfire mitigation under the Transmission category.
(b) Please provide detailed project justification documentation and planning
documents supporting Rocky Mountain Power’s proposed wildfire mitigation activities on its transmission system. Response to PIIC Data Request 33
(a) The Wildfire Mitigation – Trans project pertains to Rocky Mountain Power
(RMP) and the Wildfire Mitigation Plan – T pertains to Pacific Power (PP). (b) For the “Wildfire Mitigation – Trans” item on row 34 of the McDougal work
paper (Plan Additions of $27,260,954), Attachment PIIC 33-1 contains the list
of 2021 active projects in support of the Utah Wildland Fire Protection plan. Please refer to the two Utah Wildland Fire Protection Plan filings, Attachment PIIC 33-3, for the detail planning and justification information. For the “Wildfire Mitigation – Trans” item on row 42 of the McDougal work
paper (Plan Additions of $ 19,370,177), Attachment PIIC 33-2 contains the
list of 2021 active projects in support of the California Wildfire Mitigation plan. Please refer to the California Wildfire Mitigation plan filing, Attachment PIIC 33-3, for the detail planning and justification information.

Recordholder: Jeff Keyser Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 34
PIIC Data Request 34 Reference McDougal workpaper “8.5 - Major Plant Additions, Tab “8.5.2”, Project “C7 Data Centers, Load Increase”:

(a) Please provide a detailed description, supporting project justification analyses, and management approval documentation for the referenced project.
(b) Please identify the amount of the load increase associated with the referenced
project both in terms of MWhs and 12-CP demand. (c) Please identify the jurisdiction where the load is or will be located. Response to PIIC Data Request 34

(a) The Company cannot provide the requested customer specific data without the explicit permission of the customer.
(b) The Company cannot provide the requested customer specific data without the
explicit permission of the customer. (c) Utah.
Recordholder: Nathan Adent
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 35
PIIC Data Request 35 Reference McDougal work paper “Exhibit No. 43 - TCJA Regulatory Liability Balance (Clean)”: Please provide work papers, will all links and formulae intact,
supporting the calculation of the following hardcoded values in the referenced
work paper: (a) Cell “H10” Classification Correction
(b) Cell “F12:F15” Deferred Amortization
(c) Cell “F17” Gross-up Factor (d) Cell “H19”, “J19”, and “L19” Amounts Used (e) Cell “H28” Current Tax Benefit (f) Cell “H29” Wheeling Revenue Offset (g) Cell “H39:H40”, “J39:J40” ECAM Offset
(h) Cell “L41” Plant Buy-Down (Cholla”)
(i) Cell “N43” Powerdale Decommissioning (j) Cell “N44” Electric Plant Acquisition Adjustment – Craig and Hayden (k) Cell “N45” 2017 Protocol
(l) Cell “N46” Intervenor Funding
(m) Cell “N47” Cholla Balances Response to PIIC Data Request 35 The Company does not have any additional work papers other than those already
provided. Values supporting the following requests can be found using the
references provided below. (a) Cell “H10” Classification Correction – Please refer to Confidential
Attachment PIIC 35-. The Company previously submitted a similar model
with its response to PIIC Data Request in Case No. GNR-U-18-01. The Company’s 1st Supplemental response to PIIC Data Request 3 was provided in Case GNR-U-18-01 on July 25, 2018, and the Company’s 2nd Supplemental response to PIIC Data Request 3 was provided in Case GNR-U-18-01 on December 7, 2018, respectively. During the process of
extracting non-protected property excess deferred income taxes (EDIT)
balances from the Company’s tax fixed asset system so it could be returned to customers in the manner approved by the Idaho Public Utilities Commission (IPUC), the Company determined that portions of the prior reclasses were not necessary. In addition, the Company identified a minor
reclassification between protected and non-protected for EDIT balances related to Pacific Minerals, Inc. Please refer to the table below for a comparison of the balances submitted in PIIC Data Request 3 2nd Supplemental to the final balances included in Exhibit No. 43.
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 35

(b) Cells “F12:F15” Deferred Amortization. Please refer to Attachment PIIC 35-2.
(c) Cell “F17” Gross-up Factor – The Gross-up Factor is calculated as follows, using the Combined Tax Rate as listed in Exhibit No. 40, Page 2.1.
= 1.326024
(d) Cells “H19”, “J19”, and “L19” Amounts Used - Cells “P39”, “P40” and “P41” sum to the total in cells “H19”, “J19” and “L19”.
(e) Cell “H28” Current Tax Benefit – Please refer to Table 1 included in Case No. GNR-U-18-01, Final Report, filed June 15, 2018. For ease of reference, a copy of Table 1 is provided below:
(f) Cell “H29” Wheeling Revenue Offset – Please refer to Table 1 included in Case No. GNR-U-18-01, Final Report, filed June 15, 2018. For ease of reference, a copy of Table 1 is provided above. (g) Cells “H39:H40”, “J39:J40” ECAM Offset - Please refer to Case No. GNR-
U-18-10, Order 34331, paragraph 3 of the Phase II Stipulation. For ease of reference, paragraph 3 is provided below:

PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 35
Cells “J39:J40” - Please refer to Case No. GNR-U-18-01, Order 34331, paragraph 5 of the Phase II Stipulation. For ease of reference, paragraph 5 is
provided below:

(h) Cell “L41” Plant Buy-Down (Cholla) – Exhibit No. 40, page 8.11.5. (i) Cell “N43” Powerdale Decommissioning – Exhibit No. 40, page 8.7. (j) Cell “N44” Electric Plant Acquisition Adjustment – Craig and Hayden – Exhibit No. 40, page 8.9.2. (k) Cell “N45” 2017 Protocol – Exhibit No. 40, page 8.9.7.

(l) Cell “N46” Intervenor Funding – Exhibit No. 40, page 8.9.8. (m) Cell “N47” Cholla Balances – Exhibit No. 40, page 8.11.5.
Recordholder: Steve McDougal Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 36
PIIC Data Request 36 Reference McDougal work paper “Exhibit No. 43 - TCJA Regulatory Liability Balance (Clean)”: Did the retirement of wind facilities in connection with the Wind
repowering program result in incremental amortization of Protected EDFIT
balances and/or deferred amortization? If yes, please identify the amounts of the incremental amortization and explain how the amounts were considered in the referenced work papers.
Response to PIIC Data Request 36 The cost basis of the replaced components of the repowered of wind facilities was retired to FERC Account 108 (Accumulated Depreciation) and in that way continues to be recovered in rates over the remaining regulatory life of the
associated facility. The Protected Excess Deferred Federal Income Taxes (EDFIT)
is being similarly amortized over the remaining regulatory life as detailed in the Company’s response to PIIC Data Request 35, specifically Attachment PIIC 35-2, tab “Attach PIIC 35(b)-2”.

Recordholder: Ryan Fuller Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 37
PIIC Data Request 37 Reference McDougal work paper “7.6 - TCJA Tax Deferred” Tab “Page 7.6.1”:
(a) Please explain the difference between the protected EDFIT balances accrued
to SAP Account 288932 and SAP Account 288942. (b) Please explain why SAP Account 288942 is expected to amortize to zero by
December 31, 2021.
(c) Please explain why the cumulative change in Protected EDFIT account balances in 2021 for SAP Account 288932 and SAP Account 288942 of $10,392,381 (sum of cells “E9” and “E13”) is different than the $2,912,455 of protected EDFIT amortization for 2021 identified cell “E45.”
Response to PIIC Data Request 37 (a) SAP Account 288932 represents the regulatory liability recorded for Idaho’s
portion of protected property, plant, and equipment (PP&E) Excess Deferred
Income Taxes (EDIT). SAP Account 288942 represents the regulatory liability recorded for the deferral of Idaho’s portion of amortization of protected PP&E EDIT for 2018 through 2021, grossed up for taxes, that will be given back to customers. Essentially, as the protected EDIT amortizes out of SAP Account 288932, the amount is then deferred into a new regulatory
liability in SAP Account 288942.
(b) SAP Account 288942 is not expected to amortize to zero by December 31, 2021. The adjustment for this account in McDougal’s work paper “7.6 - TCJA
Tax Deferred”, tab “Page 7.6.1” is to remove the base period balance from
rate base, as the Company has proposed that any remaining non-protected EDIT balances will be returned to customers via a separate mechanism outside of base rates beginning January 1, 2022, or the effective date of the pending general rate case (GRC).
(c) The $2.9 million protected EDIT amortization in cell E45 represents an
amount before the tax gross-up, whereas the $3.7 million in cell E9 represents an amount that includes the tax gross-up. In addition, the $2.9 million amount in cell E45 is made up of $2.8 million of protected property EDIT amortization for PacifiCorp assets and $0.1 million of protected property EDIT amortization for Pacific Minerals, Inc.’s (PMI) portion of Bridger Coal Company (BCC) assets. Please refer to the table provided below for reference. The regulatory liability accounted for in SAP Account 288932 is the protected property EDIT balance for PacifiCorp assets only. The activity in cell E9 and cell E25 total the $2.8 million protected property amortization for PacifiCorp
assets. The amount in cell E13 is unrelated to the amount of protected EDIT
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 37
amortization for 2021 and solely represents the adjustment to remove the base period balance from rate base.
Ref. PacifiCorp Ref. PMI Ref. Total
E9 + E25 E44 E45

E9 Recordholder: Brian Keyser Sponsor: Steven McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 39
PIIC Data Request 39 Please identify the remaining fuel stock balances at Cholla on December 31, 2020. Please also include a description of how the fuel was disposed and
identification of any sales proceeds and dates received or expected to be received.
Response to PIIC Data Request 39
The remaining PacifiCorp-owned coal at Cholla on December 31, 2020 totaled
$245,387.94. This coal was sold to Arizona Public Service Company as part of an agreement signed in August 2020 to manage the end-of-life coal balance for Cholla unit 4. Per the terms of the agreement the coal was sold for $181,605.54, and this amount was credited to PacifiCorp in January 2021 as an offset to coal costs due from PacifiCorp.

Recordholder: Daniel Moody
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 41
PIIC Data Request 41 Please identify the amount of Fly Ash in storage at Cholla 4 as of December 31, 2020 and describe plans for selling the remaining fly ash at the facility. Please
also identify all such sales of Cholla 4 Fly Ash in 2020 and to date.
Response to PIIC Data Request 41
Fly ash is not tracked as an inventory item. Fly ash sales only occur on fly ash as
it exits the power generation unit. Any fly ash in excess of what is sold is transported to an impoundment and covered, making it no longer suitable for sale. PacifiCorp’s Cholla Unit 4 ceased operations in December 2020, and fly ash sales are received from the Cholla operator on a one month lag. Therefore the last month of PacifiCorp’s fly ash sales was in January 2021.

The following table shows ash sales for 2020 and 2021:
Year Month Billed Amount Description
Total $1,813,368.88
Recordholder: Daniel Moody

Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 42
PIIC Data Request 42 Reference McDougal work paper “8.11 - Cholla 4,” Tab “8.11.2”, Cell “F9”: Please provide detail of each type of materials and supplies expenses that are
expected to be recognized in connection with the Cholla 4 retirements. Response to PIIC Data Request 42
The types of items in the M&S Inventory, with their respective share of the total
balance, generally include: Motors – 6 percent Bearings – 5 percent Kits, Valves – 4 percent each
Seals, Pumps, Bushings, Studs, Blades, Transformers – 3 percent each
Assemblies, Impellers, Rings, Shafts, Gears, Packing – 2 percent each 34 other items – 1 percent each

Recordholder: Mike Johanson Sponsor: Steven McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 43
PIIC Data Request 43 Reference McDougal work paper “8.11 - Cholla 4,” Tab “8.11.2”, Cell “F11”:
(a) Have the referenced liquidated damages amounts been paid? If yes, please
provide invoices supporting the liquidated damages amount. If no, please state when the amounts are expected to be paid.
(b) Please provide a copy of the contract(s) where the obligation to pay liquidated damages are included and identify the specific contract language requiring the payment of liquidated damages. Response to PIIC Data Request 43 (a) It is assumed that the request is for the liquidated damages amount that is referenced in cell F10, not F11, since F11 references severance, not liquidated damages. The referenced liquidated damages have been paid. Regarding the request for a copy of the invoice, the invoice (and the related contract) are considered highly confidential since it is commercially sensitive due to market sensitivity and the confidentiality of the agreement. The Company requests special handling. Please contact Ted Weston at [phone] to make
arrangements to review. (b) Please refer to the Company’s response in subpart (a) above regarding request to see a copy of the contract. The following is a summary of the liquidated damages provision of the contract: In accordance with the relevant coal supply agreements (CSA):

PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 43
The total is summarized below:

Total Liquidated Damages $19,606,070.80 These damages are the result of an agreement with a third party. 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: Daniel Moody Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 45
PIIC Data Request 45 Reference McDougal work paper “6.5 - New Depreciation Study”, Tab “6.5.4”: Please provide detail supporting the 2020 depreciation and amortization expenses
by FERC account and FERC sub account. Please include monthly detail of the
plant balances (gross plant), the associated depreciation rate applied and the applicable Idaho jurisdictional allocation factor. Please reconcile the response to the $40,448,993 of depreciation expense and $2,682,363 amortization expenses
included in the unadjusted result of operations for the Idaho jurisdiction for
calendar year 2020. Response to PIIC Data Request 45 Please refer to the ‘B3 – Depreciation Expense Dec’ B-Tab report that was
provided in data response PIIC 5 for the detail supporting the depreciation
expense amount for 2020 by FERC Account and Secondary Account. If FERC 4032000, Secondary 565247 that has the OTHER factor, was excluded, that subtotal will match the total referenced on page 6.5.4. The ‘B3 – Depreciation
Expense Dec’ B-Tab report also provides the detail for the Idaho Allocated
amount of $40,448,993. Please refer to the ‘B4 – Amortization Expense Dec’ B-Tab report that was provided in data response PIIC 5 for the detail supporting the Idaho Allocated amortization expense amount of $2,682,363 for 2020 by FERC Account and Secondary Account.
The monthly detail of the plant balances and the associated depreciation rate
applied to calculate the monthly depreciation expense is not readily available to extract from the accounting system. This data would be burdensome to pull together.

Recordholder: Laura Miller Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 46
PIIC Data Request 46 Reference McDougal work paper “6.5 - New Depreciation Study”, Tab “6.5.4”: Please provide detail supporting the old and new depreciation rates. Specifically,
please provide electronic copies (in Excel format) of Attachment 1, Attachment 2,
and Attachment 3 supporting the Phase I Stipulation in Case No. PAC-E-18-08, or provide workpaper(s) with a comparable set of data.
Response to PIIC Data Request 46
Please refer to Attachment PIIC 46 for electronic copies in excel format of Attachment 1, Attachment 2, and Attachment 3 supporting the Phase I Stipulation in Case No. PAC-E-18-08.

Recordholder: Laura Miller Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 49
PIIC Data Request 49 Please identify the amount of plant retirements by month associated with each of the repowering projects, including the cumulative amount of plant retirements for
each project.
Response to PIIC Data Request 49
Please refer to Attachment PIIC 49 for the gross plant retirements, by month,
associated with each of the wind repowering projects. Recordholder: Justus Evangelista
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 53
PIIC Data Request 53 Please provide Rocky Mountain Power’s Idaho results of operations over the period 2012 through 2020, including actual and normalized results and supporting
adjustments. Please provide supporting RAM and JAM files.
Response to PIIC Data Request 53
Please refer to Attachment PIIC 53. Please note the filing requirement for Idaho
results of operations (ROO) for the 12 months ending December 2020 was waived in anticipation of this general rate case (GRC) proceeding. Recordholder: Aaron Rose

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 2, 2021 PIIC Data Request 54
PIIC Data Request 54 Please state Rocky Mountain Power’s actual and normalized return on equity earned in Idaho over the period 2012 through 2020.
Response to PIIC Data Request 54 Please refer to the Company’s response to PIIC Data Request 53.

Recordholder: Steve McDougal Sponsor: Steve McDougal