20210903PAC to PIIC 55-93-Redacted.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 3, 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 3 (55-93)
Please find enclosed Rocky Mountain Power’s Responses to PIIC 3rd Set Data Requests 59-61, 64-69, 74, 76-81, 83-84, and 87-93. The remaining responses will be provided separately.Provided via BOX is voluminous Attachment PIIC 77-1. Provided via e-mail are the non-confidential Attachments and provided via encryption and BOX are the Confidential
Attachments and Response PIIC 87. Confidential information is provided subject to protectedunder IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission’s Rules ofProcedure No. 67 – Information Exempt from Public Review, and further subject to anysubsequent 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 3 PM 3:58
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 59
PIIC Data Request 59 Reference RMP’s Response to PIIC Production Request 5, work paper “B16 Regulatory Assets.xlsm:” For each regulatory asset identified under Account
“1823910 ENVIR CST UNDR AMORT” with amounts allocated to Idaho,
please: (a) Provide a brief description of the environmental costs, including the date that
the costs were incurred;
(b) Identify the order in which the regulatory asset was approved; (c) Identify the amortization period; and,
(d) Detail the amount of amortization expense associated with the regulatory asset
included in revenue requirement, including detail of both the system and Idaho-allocated amortization amounts.
Response to PIIC Data Request 59
(a) Please refer to Attachment PIIC 59 which provides brief descriptions of the environmental costs that have occurred within the last 10 years. (b) Environmental regulatory assets began being reported under FERC account
1823910 in 2003 and amortized over ten years. All regulatory filing since
have included this balance in rate base. (c) The amortization period for costs recorded to this regulatory asset is straight-
line over 10-years.
(d) Please refer to Attachment PIIC 59. Recordholder: Colin Sutherland

Sponsor: Steven McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 60
PIIC Data Request 60 Reference RMP’s Response to PIIC Production Request 5, work paper “B16 Regulatory Assets.xlsm:” For the regulatory asset titled “Reg Asset Current
Energy West Mining” booked to account “1823990”, please:
(a) Provide a brief description of the regulatory asset;
(b) Identify the order in which the regulatory asset was approved;
(c) Identify the amortization period; and, (d) Detail the amount of amortization expense associated with the regulatory asset included in revenue requirement, including detail of both the system and
Idaho-allocated amortization amounts.

Response to PIIC Data Request 60
Reg Asset Current Energy West Mining is an account which represents the current portion of the regulatory asset (12 months in the future) and reclassed to Reg Asset Non-Current Energy West Mining, net $0. Following Generally Accepted Accounting Principles (GAAP), the Company is required to split-up our financial books between current vs non-current balances. Because this balance is representative of a GAAP reclass, there is no corresponding order approving this type of regulatory assets. Also, as the net balance of all portions of this regulatory asset net to zero, there is no corresponding amortization expense or established
amortization period.
During the preparation of this data response, it was discovered that the account balances involved net to zero on a total Company basis but not on a jurisdictional basis, which they should. The result left a rate base balance of $46,263 in revenue requirement on an Idaho situs basis. The Company will correct this error in its rebuttal filing. Recordholder: Nancy Adolphson and Craig Stelter
Sponsor: Steven R. McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 61
PIIC Data Request 61 Reference RMP’s Response to PIIC Production Request 5, work paper “B16 Regulatory Assets.xlsm:” For the regulatory asset titled “REG ASSET -
CARBON PLT DECOM/INVENTORY” booked to account “1823990,” please:
(a) Provide a brief description of the regulatory asset;
(b) Identify the order in which the regulatory asset was approved;
(c) Identify the amortization period. (d) Detail the amount of amortization expense associated with the regulatory asset included in revenue requirement, including detail of both the system and
Idaho-allocated amortization amounts.
Response to PIIC Data Request 61
(a) This regulatory asset tracks Obsolete Materials and Inventory from the
decommissioning of Carbon plant to be recovered later. (b) As described in the Company’s application in Case No. PAC-E-12-08, the Carbon plant was retired in 2015 to comply with environmental and air quality regulations. In Idaho Public Utilities Commission (IPUC) Order 32701 and
Order 32910, the IPUC approved the transfer of the net book value (NBV) of
the Carbon plant to a regulatory asset once the facility is retired and amortization of the regulatory asset through 2020, the remaining depreciable life of the facility. This approval of regulatory assets to track the net plant
balance and depreciation impacts from Carbon plant closure. This regulatory
asset is set up in a manner similar to those regulatory assets. (c) In the current proceeding, the Company is proposing to amortize this balance over three years starting January 2022.
(d) System amortization proposed is $1,149,556, which translates to $65,778 on
an Idaho allocated basis. Recordholder: Justin Waterman Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 64
PIIC Data Request 64
Please detail the number of FTE employees employed at the deer creek mine business unit by job title over the period 2012 through 2020.
Response to PIIC Data Request 64
PacifiCorp objects to this request because information prior to closure of the Deer
Creek mine is outside the test period and therefore unlikely to lead to admissible
evidence in this proceeding. Notwithstanding the foregoing objection, PacifiCorp responds as follows:
Coal production was shuttered on January 7, 2015 at the Deer Creek mine. No FTE’s were employed at the Deer Creek mine at year-end 2015 or thereafter.
Recordholder: Brad Davis
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 65
PIIC Data Request 65
Please detail the number of FTE employees employed by Energy West by job title over the period 2012 through 2020.
Response to PIIC Data Request 65
PacifiCorp objects to this request because information prior to closure of the Deer
Creek mine is outside the test period and therefore unlikely to lead to admissible
evidence in this proceeding. Notwithstanding the foregoing objection, PacifiCorp responds as follows:
Please refer to Attach PIIC 65 CONF. The attachment provides a year-end summary of Energy West FTE’s by job title for 2015 through 2020.
Recordholder: Brad Davis
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 66
PIIC Data Request 66
Please detail the O&M expenses incurred, by FERC account, by Energy West for the deer creek mine over the period 2012 through 2020.
Response to PIIC Data Request 66
PacifiCorp objects to this request because operations and maintenance (O&M)
expenses incurred prior to closure of the Deer Creek mine are outside the test
period and are therefore unlikely to lead to admissible evidence in this proceeding. Notwithstanding the foregoing objection, PacifiCorp responds as follows:
Please refer to the Company’s response to PIIC Data Request 14, specifically Attachment PIIC 14. The attachment folder includes Deer Creek mine closure
cost information by account and by period incurred. Fuel expenses are recorded to
FERC Account 501.
Recordholder: Dan Moody
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 67
PIIC Data Request 67
Please provide operating results for Energy West over the period 2012 through 2020.
Response to PIIC Data Request 67
Please refer to the Company’s response to PIIC Data Request 66.
Recordholder: Dan Moody
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 68
PIIC Data Request 68
Please provide an operating cost summary, including operating results by month, for the Deer Creek Mine business unit and/or cost centers over the period 2012
through 2020.
Response to PIIC Data Request 68
Please refer to the Company’s response to PIIC Data Request 66.
Recordholder: Dan Moody
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 69
PIIC Data Request 69
Have all closure activities at the Deer Creek Mine been completed? If no, please identify all future closure activities expected at the Deer Creek Mine through
2025 and provide cost projections supporting the closure activities.
Response to PIIC Data Request 69
No. Deer Creek mine reclamation costs are forecast to continue through 2031, the
estimated period when bond relinquishment will be received from oversight agencies. Please refer to Confidential Attachment PIIC 69 which provides a forecast of remaining mine related reclamation costs.
Additionally, recovery-based royalties have not been finalized with the Office of
Natural Resources Revenue (ONRR). Please refer to the Company’s response to
PIIC Data Request 78, specifically Confidential Attachment PIIC 78 which provides an estimate of future recovery-based royalty costs.
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 3, 2021 PIIC Data Request 74
PIIC Data Request 74 Referenced the RMP witness McDougal work paper “8.14 – Deer Creek Mine”, Tab “8.14.6”, Cell “C12”: Please provide work papers supporting the $2,291,034
amount identified in the referenced cell.
Response to PIIC Data Request 74
Please refer to Attachment PIIC 74 which provides the work papers which support
the $2,291,034. Recordholder: Laura Miller
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 76
PIIC Data Request 76 Reference RMP’s response to AWEC Data Request 0100, Attach AWEC 0100 in Oregon Docket No. UE 374: Please provide an updated version of the referenced
work papers including a reconciliation of the $75,550,723 of total closure costs
identified in adjustment 8.14.3 in this matter to the closure costs identified in Case No. PAC-E-14-10.
Response to PIIC Data Request 76
Please refer to Confidential Attachment PIIC 76. 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 3, 2021 PIIC Data Request 77
PIIC Data Request 77 Reference RMP’s response to AWEC Data Request 0100, Attach AWEC 0100 in Oregon Docket No. UE 374: In the referenced response, RMP identified the 225%
budget variance in “Reg Asset-Deer Creek-Misc Closure Costs” as follows:
“Increase primarily due to extending the closure period from 2016 to 2018 and plan changes required by oversight agencies. The inability to gain approval of the in-mine bulkhead engineering designs and additional time required to permit and
construct the alternate de-watering pipeline resulted in delays spanning
approximately two years.”: (a) Please provide all internal documentation supporting the decision to extend the closure period from 2016 to 2018.
(b) Please provide the original mine closure plans, including the in-mine bulkhead
engineering designs, and identify when the original plans were prepared. (c) Did the mine produce coal over the period 2016 to 2018, prior to when the
mine was actually closed?
(d) Please provide all internal memoranda or documentation over the period 2015 to 2020 discussing the inability to gain approval of the in-mine bulkhead engineering designs.
(e) Please provide all communications from oversight agencies over the period
2015 to 2020 discussing the approval of the in-mine bulkhead engineering designs.
(f) Please provide all internal memoranda or documentation over the period 2015
to 2020 discussing the need to construct the alternate de-watering pipeline. (g) Please provide all communications from oversight agencies over the period 2015 to 2020 discussing the need to construct an alternate de-watering pipeline.
Response to PIIC Data Request 77
(a) To clarify, PacifiCorp did not make a “decision to extend the closure period from 2016 to 2018.” PacifiCorp’s original plan was to prevent a prohibited post-mine discharge of wastewater from the portals by constructing bulkheads and impounding water in the mine. The original plan assumed the bulkheads would be constructed and mine portals sealed by the end of March 2016. PacifiCorp representatives had frequent discussions and met with individuals from oversight agencies during 2015 and early 2016 and were not able to obtain project approval. PacifiCorp coordinated a meeting with stakeholders
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 77
in April 2016 to consider installing a de-watering pipeline from the Rilda Canyon portals to the Huntington Plant Raw Water Pond. PacifiCorp received approval to install the pipeline on July 6, 2017 and completed the pipeline installation on December 1, 2017. The mine portals were sealed in December
2017 which is nearly two years later than assumed in the original application.
PacifiCorp worked diligently and prudently with stakeholders to identify an acceptable solution to preventing a new source discharge of wastewater into protected waters.
Please refer to the Company’s responses to subparts (b) and (d) through (g)
below for documentation supporting the process explained above.
(b) PacifiCorp objects to this request on the basis that it is overly broad and unduly burdensome, and not likely to lead to admissible evidence relevant to this proceeding. Notwithstanding the foregoing objection, PacifiCorp responds as follows:
Please refer to Attachment PIIC 77-1 which provides a copy of the original bulkhead plan submittal to the Mine Safety and Health Administration (MSHA) in January 2015. (c) No. Coal production shuttered on January 7, 2015.

(d) PacifiCorp objects to this request on the basis that it is overly broad and unduly burdensome, and not likely to lead to admissible evidence relevant to this proceeding. Notwithstanding the foregoing objection, PacifiCorp responds as follows:
Please refer to Attachment PIIC 77-2 which provides two documents containing a chronology of events associated with obtaining an acceptable solution to preventing a new source discharge of wastewater into protected waters.
(e) PacifiCorp objects to this request on the basis that it is overly broad and
unduly burdensome, and not likely to lead to admissible evidence relevant to this proceeding. Notwithstanding the foregoing objection, PacifiCorp responds as follows:
Please refer to Attachment PIIC 77-3 which provides the following information:
1. The original Deer Creek bulkhead plan submitted to MSHA in January 2015 with amendments (six files). 2. MSHA letter dated February 23, 2015 – technical review.
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 77
3. MSHA letter dated May 15, 2015 – technical review. 4. MSHA letter dated August 21, 2015 – technical review.
5. MSHA letter dated December 1, 2015 – MSHA informs PacifiCorp they
do not have the authority to approve the bulkheads. 6. Utah Department of Natural Resources, Division of Oil, Gas and Mining
(DOGM) letter dated April 12, 2016 – amendment denial.
7. PacifiCorp Internal/External email string – August 2015 / September 2015 (f) PacifiCorp objects to this request on the basis that it is overly broad and unduly burdensome, and not likely to lead to admissible evidence relevant to
this proceeding. Notwithstanding the foregoing objection, PacifiCorp
responds as follows:
Please refer to Attachment PIIC 77-4.
(g) PacifiCorp objects to this request on the basis that it is overly broad and unduly burdensome, and not likely to lead to admissible evidence relevant to
this proceeding. Notwithstanding the foregoing objection, PacifiCorp
responds as follows:
Please refer to Attachment PIIC 77-5 which provides the following information:
1. United States (U.S.) Bureau of Land Management (BLM) Offer Letter UTU-91700 dated July 6, 2017. 2. BLM Right-of-Way (ROW) Notice to Proceed (NTP) dated July 6, 2017.
3. BLM ROW Serial Number UTU-91700 dated July 6, 2017.
4. U.S. Department of Agriculture, U.S. Forestry Services (USFS) Final Decision Notice and Finding of No Significant Impact (FONSI) date July 6, 2017. 5. USFS Special Use Permit PRI-1606 dated July 6, 2016 Recordholder: Dan Moody
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 78
PIIC Data Request 78 Referenced the RMP witness McDougal work paper “8.14 – Deer Creek Mine”, Tab “8.14.7”, Cell “B8”: Please itemize RMP’s estimated abandonment royalties
and recovery royalties of $15,557,244 by agency or counterparty, and provide
work papers supporting the estimate. Response to PIIC Data Request 78

Please refer to Confidential Attachment PIIC 78. 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 3, 2021 PIIC Data Request 79
PIIC Data Request 79 For each agency or counterparty in which RMP has an abandonment or recovery royalty obligations, please provide the following:

(a) The statute, regulation, or contract under which the royalties may be assessed. (b) All communications between RMP and the agency regarding abandonment or
recovery royalty obligations over the period 2015 through 2021 (to date).
Response to PIIC Data Request 79 (a) Federal and state coal leases royalty obligations are due in accordance with provisions contained in the Code of Federal Regulations (CFR) Title 30, Part
1206 – Product Valuation, Subpart F – Federal Coal.
(b) Please refer to the Company’s response to PIIC Data Request 80, specifically Attachment PIIC 80 for communications regarding royalty abandonment.
Concerning recovery-based royalties, PacifiCorp has not received
correspondence from the Office of Natural Resources Revenue (ONRR) in connection with the Deer Creek mine closure. Recordholder: Dan Moody

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 80
PIIC Data Request 80 Reference RMP’s response to AWEC Data Request 0100, Attach AWEC 0100 in Oregon Docket No. UE 374: With regard to abandonment royalties, the
referenced work papers states “No coal lease abandonment royalty obligation was
assessed by the BLM as the agency found maximum economic recovery had been achieved”.
(a) Please provide the communications from the BLM stating that no
abandonment royalties would be assessed. (b) Please explain how the referenced statement is consistent with RMP’s proposal to recover estimated abandonment royalties in this proceeding.
Response to PIIC Data Request 80
(a) Please refer to Attachment PIIC 80.
(b) PacifiCorp is not proposing to recover abandonment royalty costs because
none were incurred, as documented in the Company’s response to subpart (a) above. PacifiCorp is asking to be reimbursed for recovery-based royalties as identified in the work papers supporting the direct testimony of Company witness, Steven R. McDougal, specifically file “8.14 – Deer Creek Mine”, tab “8.14.7”.

Recordholder: Dan Moody
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 81
PIIC Data Request 81 Please describe PacifiCorp’s current policy regarding remote working following the pandemic.
Response to PIIC Data Request 81 PacifiCorp assumes that the reference of “pandemic” is intended to be a reference
to the COVID-19 pandemic. Based on the foregoing assumption, the Company
responds as follows: PacifiCorp has a Voluntary Work from Home Policy that allows employees to change their work location from the office to their home. Employees electing this program have their pay reduced by 10 percent. Employees participating in this
program will not have their career opportunities or progression
impacted. Employees remain eligible for benefits coverage and the annual incentive plan. Life insurance, disability benefits, 40l(k) contributions and any approved annual incentive plan (AIP) award will be based on the employee’s
modified 90 percent base salary. Employees continue to accrue personal time off
(PTO) at the same rate. Recordholder: Julie Lewis
Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 83
PIIC Data Request 83 Please identify all new debt issuances that PacifiCorp has made since the preparation of Kobliha Exhibit 3 and provide the terms of all such debt issuances
in the same format as provided in Kobliha Exhibit 3.
Response to PIIC Data Request 83
PacifiCorp issued $1,000,000,000 of its 2.90 percent Green First Mortgage Bonds
due 2052 in July 2021. Please refer to Attachment PIIC 83-1 for the calculation of the cost of debt for this new series in the same format as provided in the direct testimony of Company witness, Nikki L. Kobliha, specifically Exhibit No. 3. Additionally, please refer to Attachment PIIC 83-2, the Report of Securities Issued, filed with the Idaho Public Utilities Commission (IPUC) in Docket No.
PAC-E-20-15 on October 14, 2020, following the issuance, which provides
additional detail as to the current actual and estimated costs and net proceeds from the issuance.

Recordholder: Matt Fechner Sponsor: Nikki Kobliha
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 84
PIIC Data Request 84 Please identify all expected debt issuances that PacifiCorp plans to make through December 31, 2022 and provide the expected terms of all such debt issuances in
the same format as provided in Kobliha Exhibit 3.
Response to PIIC Data Request 84
The Company has no plans to issue debt through December 31, 2022 at this time,
however, as the planning process progresses the Company may include additional debt issuances if needed. Recordholder: Kristi Olsen

Sponsor: Nikki L. Kobliha
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 87
PIIC Data Request 87 Please provide the most recent 10-year plan for Bridger Coal Company, including all of the “OPEX-CAPEX” supporting work papers ( e.g. “01
OpsCostSchedules”, “03 Labor- SURF,” etc.) that are typically provided along
with RMP’s net power cost filings. Response to PIIC Data Request 87

PacifiCorp objects to this request because it falls outside the test period which is based on 2020 costs adjusted for known and measurable changes and would not lead to admissible evidence in this proceeding. Notwithstanding the foregoing objection, PacifiCorp responds as follows:
As noted below, coal deliveries in the initial PAC-E-21-07 filing assumed Bridger
Coal Company delivered the following quantity of coal to the Jim Bridger plant in 2021:

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: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 88
PIIC Data Request 88 Please provide work papers supporting the cost of coal from each of RMP’s coal fired power plants in the same manner as provided in the confidential work papers
supporting the Direct Testimony of Pacific Power witness Ralston in Oregon
Docket UE 390. Response to PIIC Data Request 88

Please refer to Confidential Attachment PIIC 88 which provides details of coal costs by plant. 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: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 89
PIIC Data Request 89 Please provide RMP’s calculation of the Idaho ECAM balance for calendar year 2021 including 2021 cost data through the most recent month available.
Response to PIIC Data Request 89 PacifiCorp objects to this data request as not relevant to this general rate case
(GRC) proceeding and is unlikely to lead to admissible evidence in this
proceeding. PacifiCorp’s energy cost adjustment mechanism (ECAM) contains historical data not forecasted data. Notwithstanding the foregoing objection, the Company responds as follows: The Company files its annual ECAM with the Idaho Public Utilities Commission
(IPUC), for the previous calendar year deferral period, typically each April.
During the course of each calendar year, PacifiCorp also submits three quarterly filings to the IPUC (Q1 (May), Q2 (August) and Q3 (November)). Note: representatives from IPUC staff, the PacifiCorp Idaho Industrial Customers
(PIIC), the Idaho Irrigation Pumpers Association, Inc. (IIPA), and P4 Production,
LLC / Bayer Corporation (Bayer) are simultaneously furnished with copies of the three quarterly filings. Based on the foregoing information, the Company responds as follows: Please refer to Attachment PIIC 89-1 and Confidential Attachment PIIC 89-2
which provides a copy of PacifiCorp’s Q2 2021 ECAM quarterly filing, which
was submitted to the IPUC on August 30, 2021. Note: this filing was simultaneously provided to PIIC on August 30, 2021.
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: Jack Painter
Sponsor: Michael Wilding
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 90
PIIC Data Request 90 Please provide transaction level (i.e. invoice level) detail for FERC Account 9210000, OFFICE SUPPL & EXP. Please include all fields stored in RMP’s
accounting system, including description, date, vendor, allocation factor and all
other information stored with respect to a particular accounting entry. Response to PIIC Data Request 90

Please refer to Attachment PIIC 90 for calendar year 2020, transactional detail in FERC Account 921. Recordholder: Catherine Docekal / Craig Stelter

Sponsor: Steven McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 91
PIIC Data Request 91 Please provide transaction level (i.e. invoice level) detail for all Outside Services expenses incurred in 2020: Please include all fields stored in RMP’s accounting
system, including description, date, vendor, allocation factor and all other
information stored with respect to a particular accounting entry. Response to PIIC Data Request 91

Please refer to Attachment PIIC 91 for a transactional detail in calendar year 2020, for FERC Account 923 (Outside Services) associated with a vendor transaction, excluding any legal vendor activity. For vendor activity related to legal costs, please refer to the Company’s response to PIIC Data Request 92.

Recordholder: Catherine Docekal / Craig Stelter Sponsor: Steven McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 92
PIIC Data Request 92 Please provide transaction level (i.e. invoice level) detail for legal expenses incurred in 2020: Please include all fields stored in RMP’s accounting system,
including description, date, vendor, allocation factor and all other information
stored with respect to a particular accounting entry. For each entry, please also include a description of the legal matter for which the legal services were acquired.
Response to PIIC Data Request 92 The Company objects to this request to the extent the information is protected by the attorney-client privilege. Subject to and without waiving this objection, the Company provides the following information:

Please refer to Confidential Attachment IPUC 3 for legal expenses incurred in calendar year 2020, including general ledger (G/L) account, FERC Account, posting date, vendor, and allocation factor.

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: Catherine Docekal / Craig Stelter Sponsor: Steven McDougal
PAC-E-21-07 / Rocky Mountain Power September 3, 2021 PIIC Data Request 93
PIIC Data Request 93 Please provide annual detail of each depreciation study deferred account that RMP has had in place over the period 2012 through 2021 (to date). Specifically,
please detail the amount deferred, the amount amortized, the docket where the
amount was amortized, the beginning and ending balances, and any other adjustments to the deferred account (e.g. carrying-charges).
Response to PIIC Data Request 93
In Case No. PAC-E-13-04, Order 32910, the Idaho Public Utilities Commission (IPUC) authorized the Company to establish a regulatory asset to allow for the deferral of any aggregate net increase or decrease in Idaho allocated share of depreciation expense.

In Case No. PAC-E-18-01, the IPUC ordered the Company to include the depreciation regulatory asset created in Case No. PAC-E-13-02 (Application to Change Deprecation Rates) in future Idaho energy cost adjustment mechanism
(ECAM) filings.
Please refer to Attachment PIIC 93 for the regulatory asset included in the ECAMs.
Recordholder: Laura Miller
Sponsor: Steve McDougal