20210907PAC to Bayer Supplemental 21.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 7, 2021
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)
Mike Veile/Bayer [e-mail] Courtney Higgins/Bayer [e-mail] Milli Picharo/Bayer [e-mail] Neal Townsend/Bayer [e-mail]
RE: ID PAC-E-21-07
Bayer Set 1st (1-33)
Please find enclosed Rocky Mountain Power’s 1st Supplemental Response to Bayer 1st Set Data Request 21. Provided via encryption and BOX to Bayer and IPUC only is Customer-Specific Confidential Attachment Bayer 21 1st Supplemental. Customer-Specific Confidential Attachments contain customer-specific information and are considered business confidential. The Company requests special handling which includes destroying or returning customer-specific information within 30 days after the docket is completed. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the IPUC’s Rules
of Procedure No. 67 – Information Exempt from Public Review, and further subject to the 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 Weston
Manager, Regulation
Enclosures C.c.: Jan Noriyuki/IPUC [e-mail] (C)Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail] Adam Gardner/PIIC [e-mail] (W) Kyle Williams/PIIC [e-mail] (W)
RECEIVED
2021 SEP 7 PM 2:54
IDAHO PUBLIC
UTILITIES COMMISSION
Val Steiner/PIIC [e-mail] (W) Eric L. Olsen/IIPA [e-mail] (C) Anthony Yankel/IIPA [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 [e-mail] (W)
Val Steiner/PIIC [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 September 7, 2021 Bayer Data Request 21 – 1st Supplemental
Bayer Data Request 21 Please provide Bayer’s actual hourly load data for the test year and all adjustments made to that actual hourly load data for purposes of:

• The jurisdictional allocations.
• The class cost of service allocations.
1st Supplemental Response to Bayer Data Request 21 Further to the Company’s response to Bayer Data Request 21 dated July 6, 2021, and as requested in Bayer Data Request 129, specifically “Please provide the
documents produced in response to Bayer Data Request 21 and 24 for 2021 to
date”, the Company provides the following supplemental response for Bayer Data Request 21:
The requested information is customer specific confidential information. The
Company requests special handling. The Company objects to this request on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence in this case. Notwithstanding the foregoing objection, the Company responds as follows:
Please refer to Confidential Attachment Bayer 21 1st Supplemental which provides P4 Production, LLC / Bayer Corporation (Bayer) actual hourly load for calendar year 2021 to-date (January 1, 2021 through June 30, 2021).
The Company has not performed the requested analysis. Jurisdictional allocation factors are based on historical calendar year jurisdictional load data that are available approximately 120 days after the end of any calendar year. As such, 2021 loads information for jurisdictional allocation factor purposes is not yet available.
Customer-Specific Confidential Attachment Bayer 21 1st Supplemental contains customer-specific information and is considered business confidential. The Company requests special handling which includes destroying or returning
customer-specific information within 30 days after the docket is completed. Confidential information is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, the IPUC’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 7, 2021 Bayer Data Request 21 – 1st Supplemental
Recordholder: Lee Elder / Sherona Cheung Sponsor: Steve McDougal