20210902PAC to Staff 161-174.pdf

ROCKY MOUNTAIN
HP.YYE,N*,1407 W Norlh Temple, Suite 330
Salt Lake City, Utah 841'16
September 2,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.noriyuki(@puc. idaho. eov (C)
RE: ID PAC-E-21-07
IPUC Set 6 (16l-174)
Please find enclosed Rocky Mountain Power's Responses to IPUC 56 Set Data Requests l6l-
164, 168, arrd 173-174. The remaining response will be provided under separate cover.
Provided via e-mail are non-confidential Attachment IPUC 168 and 174 and provided via
encryption and BOX is the Confidential Attachment 164. 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.: Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC bmrullins@mwanalytics. com
Adam Gardner/?IlC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
Randall C. Budge/Bayer randy @racineolson. com (C)
Thomas J. Budge/Bayer ti @.racineolson. com $D(C)
Brian C. Collins/Bayer bcollins(Econsul tbai. com (!VXC)
Maurice B rubaker/B ay er mbrubaker@c on sultba i. c om (C )
Kevin Higgins/Bayer khie eins@enereystrat. com (C)
Lance Kaufinan/Bayer lance@aeeisinsieht. com (C)
James R. Smith/Bayer i im. r. smith@ic loud. com (C)
Brad Purdy [e-mail] (C)
Ben Otto/ICL botto@.idahoconservation.ors (C)
PAC-E-21-07 / Rocky Mountain Power
September 2,2021
IPUC DataRequest 16l
IPUC Data Request 161
Please provide a list of all business function codes used by the
Company and include the abbreviations and descriptions of each business
function code.
Response to IPUC Data Request 161
Please refer to the "Func Factors" and "FuncStudy" tabs within the work paper
supporting the direct testimony of Company witness, Robert M. Meredith's
specifically file *COS lD 202l.xlsx" for functional factors including their
description and how they are used in the cost of service (COS) study. The
functional factors are no longer used within the jurisdictional allocation model
(JAIO, and therefore not part of revenue requirement calculations, but are rather
used entirely in the COS model.
Recordholder:Robert M. Meredith
Sponsor:Robert M. Meredith
PAC-E-21-07 / Rocky Mountain Power
September 2,2021
IPUC DataRequest 162
IPUC Data Requqt162
In reference to Company Wihess McDougal's Exhibit No. 40, page 56 of 350,
Joint Use Revenue (adjustnren8.T), what is the total joint use revenue from the
agreements with ExteNet and Cingular Wireless to date?
Responso to IPUC Data Request 152
The total joint use revenue from the agreements with ExtNet and Cingular
Wireless to date is zero dollars.
Recordholder:Virginia Trask/ Jeftey Kent
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
September 2,2021
IPUC Data Request 163
IPUC Data Request 163
How many attachments from ExteNet and Cingular Wireless does the Company
currently have and what is the basis for the expected additional joint use revenue
in this adjusftnent?
Response to IPUC Data Request 163
Neither ExteNet nor Cingular Wireless currently have attachments. The basis for
the expected additional revenue is that each of the companies' forecast one
attachment per year for the next 10 years. Each attachment is valued at $500 per
year ($/year).
Recordholder:Diana Winchester / Jeffiey Kent
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
September 2,2021
IPUC Data Request 164
IPUC Data Request 164
With reference to Company Witress McDougal's Exhibit 40, page 57 of 350, Ash
Sales Revenue (adjustnent 3.8), please provide a copy of the recently executed
conftact for ash from the Jim Bridger plant.
Response to IPUC Data Request 164
Please refer to Confidential Attachment IPUC 164
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 Moody
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
September 2,2021
IPUC Data Request 168
IPUC Data Request 16E
With reference to Company Witness McDougal's Exhibit 40, page 6l of 350,
Miscellaneous General Expense & Revenue (adjustnent4.l), please provide the
source documents, including invoices, and the workpapers for the Gain on
Property Sales allocated to Idaho. In addition, please provide the source
documents, including invoices, and the workpapers for the adjusfrnents to
expense.
Response to IPUC Data Request 168
Please refer to Attachment IPUC 168.
Recordholder: Colin Sutherland
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
September 2,2021
IPUC Data Request 173
IPUC Data Request 173
With reference to Company Witress McDougal's Exhibit 40, page 87 of 350,
Insurance Expense (adjusnnent 4.7.1), please provide the journal entries
supporting the Net Accrued Expense of $139,075,877. Please provide the source
documents, including any invoices and workpapers.
Response to IPUC Data Request 173
The Company objects to this request as overly broad, unduly burdensome, and not
reasonably calculated to lead to the discovery of admissible evidence to the extent
that it requests information that is covered by attorney-client privilege. Subject to
and without waiving this objection the Company responds as follows:
The net accrued expense amount of $139,075,877 was replaced with the three-
year average of cash payments in Adjusrnent4.T as the Company is normalizing
injury and damage expense. Please refer to the Company's response to Bayer
Data Request 84, specifically Confidential Attachment Bayer 84 which provides a
list of payments that were over $50,000 for 201 8, 2019 , and 2020, and were used
to calculate the average.
Recordholder:Laura Miller
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
September 2,2021
IPUC Data Request 174
IPUC Data Request 174
With reference to Company Winress McDougal's Exhibit 40, page 86 of 350,
Insurance Expense (adjusftnent 4.7), please provide the work papers supporting
the calculation of the Adjustnents to Tax, including the Schedule M
Adjustnents allocated and directly assigned to Idaho, Deferred Income Tan
Expense allocated and directly assigned to Idaho, Accumulated Defened Income
Tax Balance.
Response to IPUC Data Request 174
Please refer to Attachment IPUC 174 which illustates the removal from base
period the income tax accounts related to the book Insurance Expense accounts as
reflected in adjustment 4.7.
Recordholder:Brian Keyser
Steve McDougalSponsor: