20210910PAC to PIIC 55-93-Redacted.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 10, 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 55-56, 58, 62-63, 70-73, 75, 82, and 85-86. The remaining response will be provided separately. Provided via BOX is voluminous Attachment PIIC 71. Provided via e-mail are the non-confidential Attachments PIIC 82-1 and 82-2 Provided via encryption and BOX are the
Confidential Attachments and Confidential Response PIIC 56. 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,
____/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)
RECEIVED
2021 SEP 10 PM 4:08
IDAHO PUBLIC
UTILITIES COMMISSION
Ben Otto/ICL [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 55
PIIC Data Request 55 Reference RMP witness McDougal work paper “4.7 - Insurance Expense”, Tab “4.7.1”: Please reconcile the “$139,075,877” amount in cell “E25”, of the
referenced work paper to the “$149,446,000” amount of injuries and damages
expense accrued in Account 925.0 identified in response to PIIC Production Request 5, work paper “B2 - Operations & Maintenance Expense Dec,” cell “F711.”
Response to PIIC Data Request 55 The $139 million included on page 4.7.1 is the net of injuries and damages accrual and provisions for claims receivable from outside insurance. The difference between the $139 million and the $149 million are the insurance
premiums and the expenses related to handling damages which are also booked in
FERC Account 925.
Recordholder: Laura Miller
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 56
PIIC Data Request 56 Reference RMP witness McDougal work paper “4.7 - Insurance Expense”, Tab “4.7.1”: Please provide a description for the $1,671,915 amounts in cell “B15”
identified as “Third party insurance claim proceed amounts not requested”.
Response to PIIC Data Request 56
The $1,671,915 was insurance reimbursements related to the
where the costs have also been excluded. 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: Laura Miller

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 58
PIIC Data Request 58 Please detail all insurance proceeds that RMP has received over the period 2018, 2019, and 2020 by insurance policy.
Response to PIIC Data Request 58 Please refer to Confidential Attachment PIIC 58 for an accounting of insurance
proceeds RMP received in 2018. The Company did not receive any insurance
proceeds n 2019 or 2020. 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: Mariya Coleman

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 62
PIIC Data Request 62 Reference RMP’s Response to PIIC Production Request 5, work paper “B16 Regulatory Assets.xlsm:” Please provide an explanation for the amounts booked
to 1823930DSR COSTS NOT AMORT, and explain why those amounts from
2006 are still included in rate base. Please also identify the order where the regulatory assets were approved.
Response to PIIC Data Request 62
The 1823930DSR COSTS NOT AMORT net to zero on a dollar basis in the B16 report, however they do not net to zero on an allocation basis. DSR related balances of $1,687,321 situs to Idaho will be removed from rate base in the Company’s rebuttal filing.

Recordholder: Craig Stelter
Sponsor: Steven McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 63
PIIC Data Request 63 Please describe the status of the UMWA 1974 Pension Trust withdrawal settlement negotiations, and explain how the costs associated with the UMWA
1974 Pension Trust withdrawal settlement negotiations are being included in
revenue requirement. Response to PIIC Data Request 63

The Company is pursuing litigation against the United Mine Workers of America (UMWA) pension plan concerning the amount of the withdrawal liability assessment. The District Court affirmed the assessment on May 22, 2020, and the Company appealed. The appeal has been fully briefed and the Company awaits oral argument. There has been no change in the withdrawal obligation as a result
of litigation or associated settlement negotiations. The Company’s continued
annual payments to the trust of $2.967 million on a total-company basis have been included in revenue requirement as a result of this amount being included in fuel costs in the test period.

Recordholder: Jennifer Kahl Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 70
PIIC Data Request 70 Please provide an unredacted copy of the Direct Testimony and exhibits of Douglas K Stuver in Case No. PAC-E-14-10, including electronic copies of work
papers provided in response to Monsanto Production Request 2 in that case.
Response to PIIC Data Request 70
PacifiCorp objects to this request as outside the scope of this proceeding, and not
reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection, PacifiCorp responds as follows: Please refer to Confidential Attachment PIIC DR 70 for copies of Mr. Stuver’s confidential testimony and exhibits. The Company does not waive any objections
raised in the data request responses included in the attachments.
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: Ted Weston

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 71
PIIC Data Request 71 Please provide Pacific Power’s confidential response to Sierra Club Data Request 1, Attach Sierra Club 1.1 CONF from Oregon Docket UM 1712. Note that this
response was provided in Case No. PAC-E-14-10 in response to Monsanto
Production Request 1. (see also AWEC Data Request 0094 in Oregon Docket No UE 374).
Response to PIIC Data Request 71
PacifiCorp objects to this request as outside the scope of this proceeding, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving the foregoing objection, PacifiCorp responds as follows:
Please refer to Confidential Attachment PIIC 71. The Company does not waive
any objections raised in the data request responses included in the attachments. 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 Martinez

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 72
PIIC Data Request 72 Please provide confidential, unredacted versions of testimony and legal briefs submitted by RMP or any other party in Oregon Docket No. UE 374.
Response to PIIC Data Request 72 Rocky Mountain Power (RMP) objects to this request on the grounds that it seeks
information not relevant to this proceeding, is overly broad, and is not reasonably
calculated to lead to the discovery of admissible evidence. The request seeks information specific to issues relevant to Oregon regulatory requirements that are not relevant to the Idaho Commission’s evaluation of RMP’s general rate case. Further, the request seeks documents that are subject to a protective order in a separate jurisdiction, to which PIIC is not a signatory.

Recordholder: Matt McVee

Sponsor: To Be Determined
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 73
PIIC Data Request 73 Reference RMP’s response to PIIC Production Request 16, Attach PIIC 16: Please explain why the $8,323,073 retiree medical settlement loss is greater than
the amount identified in Case No. PAC-E-14-10 (See e.g. Stuver, Di – 13). Please
also itemize each difference in the calculation between Attach PIIC 16 and the amount from Case No. PAC-E-14-10 that led to such a material change in the settlement amount.
Response to PIIC Data Request 73 The amount of the retiree medical settlement loss included in the direct testimony of Company witness, Douglas K. Stuver in Case No. PAC-E-14-10 was based on estimates obtained from the Company’s actuaries in Fall 2014, near the time the
testimony was filed. The actual retiree medical settlement loss was not known
until the triggering event occurred and the plan values were re-measured as of May 31, 2015. The difference between the $4 million estimated at the time of Mr. Stuver’s testimony and the actual settlement loss of $8 million included was
driven by changes in the discount rate and mortality tables at the time of re-
measurement in May 2015. The Company does not have access to details that would delineate the impact of these changes on the settlement loss. Recordholder: Steve McDougal

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 75
PIIC Data Request 75 Reference RMP’s response to PIIC Production Request 17: In Case No. PAC-E-14-10, RMP represented that the settlement of the “existing unrecognized
actuarial losses currently reflected in the Company’s regulatory assets that would
otherwise have been amortized to FAS 106 expense in the future and thus represents a significant benefit to customers.” See Stuver, Di -13. Please identify the reduction in the FAS 106 expense attributable to the reduction in unamortized
losses resulting from the settlement of the UMWA Retiree Medical Obligation for
each year over the period 2015 through 2021 and provide workpapers supporting the calculations. Response to PIIC Data Request 75
The Company is unable to provide the actual reduction in retiree medical expense
from 2015 through 2021 as a result of the settlement. While the settlement accounting triggered in May 2015 as a result of the settlement of the United Mine Workers of America (UMWA) Retiree Medical Obligation (RMO) impacted the
amount of existing unrecognized actuarial losses that would have otherwise been
recognized to expense in future periods, the amount of amortization of those actuarial losses that would have occurred in subsequent years absent the settlement accounting is not available and would require analyses and assumptions to be made by the Company’s actuaries. Any resulting cost savings would have been reflected in net power costs via fuel expense and thus subject to
deferral through the Idaho energy cost adjustment mechanism (ECAM).
Recordholder: Jennifer Kahl

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 82
PIIC Data Request 82 Reference RMP’s Response to PIIC Production Request 5, workpaper “B2 - Operations & Maintenance Expense Dec,” Account “9239990 - AFFL SERV
EMPLOYED”: Please provide all cost allocation manuals and work papers
supporting the amounts accrued to the referenced account. Response to PIIC Data Request 82

Please refer to Attachment PIIC 82-1 for the account detail with allocation factors and the Idaho allocated amount. The Federal Energy Regulatory Commission’s (FERC) Uniform System of Account’s (USOA) definition for FERC Account 923 is as follows:
923 Outside services employed.
A. This account shall include the fees and expenses of professional
consultants and others for general services which are not applicable to a particular operating function or to other accounts. It shall include also the pay and expenses of persons engaged for a special or temporary administrative or general purpose in circumstances where the person so engaged is not considered as an employee of the utility.
B. This account shall be so maintained as to permit ready summarization
according to the nature of service and the person furnishing the same.
ITEMS
1. Fees, pay and expenses of accountants and auditors, actuaries, appraisers, attorneys, engineering consultants, management consultants, negotiators,
public relations counsel, tax consultants, etc.
2. Supervision fees and expenses paid under contracts for general management services.
NOTE: Do not include inspection and brokerage fees and commissions chargeable to other accounts or fees and expenses in connection with security issues which are includible in the expenses of issuing securities.
FERC Account 923 is part of administrative and general (A&G) expense. The allocation factors for A&G are shown on page 3 of the 2020 Protocol Appendix B. Please refer to Attachment PIIC 82-2 for a copy of the 2020 Protocol.
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 82
Recordholder: Catherine Docekal / Craig Larsen Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 85
PIIC Data Request 85 Reference RMP’s Response to PIIC Production Request 5, workpaper “B2 - Operations & Maintenance Expense Dec,” Account “9020000”: Does RMP
expect meter reading expense savings associated with its Idaho Advanced
Metering Infrastructure Program? If yes, please identify the amount of meter reading savings that RMP expects in calendar year 2021.
Response to PIIC Data Request 85
Yes, while meter reading expense savings are expected from the Idaho Advanced Metering Infrastructure (AMI) program, no meter reading savings are expected for 2021. Meter reading savings are projected to begin in 2022.

Recordholder: Trevor Stuart Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power September 10, 2021 PIIC Data Request 86
PIIC Data Request 86 Please provide all cost benefit analyses that RMP has prepared in connection with the implementation of Advanced Metering Infrastructure in Idaho.
Response to PIIC Data Request 86 Please refer to Confidential Attachment PIIC 86.

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: Trevor Stuart Sponsor: To Be Determined