20210914Bayer140-151 to PAC.pdf

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llii ttP lh PH 2: 26Randall C. Budge,ISB No. 1949
Thomas J. Budge,ISB No. 7465
RACINE OLSON, PLLP
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-139 |
Telephone: [phone]
Fax: [phone]
r andv (d.r acineo I son. com
[e-mail]
IN THE MATTER OF THr APPLICATION
OF ROCI(Y MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AFII)
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCIIEDTILES AND
REGULATIONS
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Attorneys for Intervenor P4 Production, L.L.C., an affiliate of Boyer Corporation
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E.2I-07
BAYER CORPORATION'S
FOURTEENTH SET OF DATA
REQUESTS TO ROCKY
MOUNTAIN POWER
P4 Production, L.L.C., an affiliate of Bayer Corporation (hereinafter "Bayer"), by and
through its attorneys, hereby submits this Fourteenth Set of Data Requests to Rocky Mountain
Power, pursuantto Rule 225 ofthe Idaho Public Utility Commission's Rules of Procedure, IDAPA
31.01.01.
This Data Request is to be considered continuing, and Rocky Mountain Power is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of the
person preparing the documents. Please identi$ the name, job title, location and telephone number
of the record holder.
ln addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
BAYER CORPORATION'S FOURTEENTH SET OF DATA REQI.JESTS TO ROCKY MOI.JNTATN
POWER - I
Bayer Set 14
Request No. 140: Wildfire Costs. Please provide all court documents related to
litigation involving RMP, an RMP affiliate, and the Archie Creek fire. Please include all
discovery provided by RMP or an RMP affiliate. Please include all complaints, motions,
briefs, and orders.
Request No. 141: Wildfire Costs. Please provide all court documents related to
litigation involving RMP, an RMP affiliate, and the Slater or Happy Camp fire. Please
include all discovery provided by RMP or an RMP affiliate. Please include all
complaints, motions, briefs, and orders.
Request No. 142: Wildfire Costs. Please provide all court documents related to
litigation involving RMP, an RMP affrliate, and the Beachie Creek fire. Please include all
discovery provided by RMP or an RMP affiliate. Please include all complaints, motions,
briefs, and orders.
Request No. 143: Wildfire Costs. Please refer to IAD Labor Day Fire Damage
Repair Projects (PCN).docx. For each project identified, please provide the following
data:
a) Actual and budgeted capital cost by FERC account.
b) Operating expense incurred in2020 by FERC account.
c) Adjustments made, if any, from base year to test year in the filed case
related to wildfire expenses, other than capital additions. Please include
references to workpapers or exhibits or provide supporting documentation
d) Legal costs associated with the fire, by year.
e) Please indicate whether any of the damage associated with the fire was
covered by property insurance, provide the amount of insurance proceeds,
and identiff the rate treatment of insurance proceeds.
Request No. 144: Wildfire Costs. Please refer to the response to OPUC DR 84.
For each item in each year of the attachment, please provide the following:
a) The allocation factor used for the payment.
b) Whether the payment was covered under an insurance policy and the
treatment of any insurance policy proceeds in the rate case.
c) Total legal expenses for the associated payment, by year. Please include
the allocation factor used for legal expenses. Please indicate whether legal
expenses are included in the normalization of injuries and damages. If no,
why not?
d) For payments exceeding $ 100,000, identiff each related court proceeding
and provide all complaints, motions, briefs, and orders.
e) For the 2018 payment with description "*Amount Removed" please
clarifr the description.
f) For the 2019 payment involving Bridger Coal Mine, please explain why
the payment is an RMP expense rather than a BCC expense.
BAYER CORPORATION'S FOURTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTATN
POWER - 2
g) Please explain the difference between the lines "Cumulative claims
payments for claims valued under $20k." and "Payments Less Than $50k
Each."
Request No. 145: Wildfire Costs. Please refer to the workpaper for adjustment
4.T Insurance Expense.
a) Please provide each insurance policy included in these expenses.
b) Please indicate which policies cover wildfire related property.
c) Please refer to tab 4.7.2. Please identi$ which policies include deductibles
for transmission losses, distribution losses, and non T&D losses.
Request No. 146: Wildlire Costs. Please provide all communications and reports
between RMP and RMP affiliates and the Public Utility Commission of Oregon utility
safety section regarding vegetation management.
Request No. 147: Wildfire Costs. Please provide the total labor hours spent on
vegetation management by state and year from 2010 to present. Please indicate if any
portion ofthese hours are subcontracted.
Request No. 148: Wildfire Costs. Please provide the total operating expense for
vegetation management by state and year from 2010 to present.
Request No. 149: Wildfire Costs. Please provide the total distribution and
transmission line miles, separately, by state and year from 2010 to present.
Request No. 150: Wildfire Costs. Have any PacifiCorp employees raised
vegetation management related safety concerns with PacifiCorp management? If yes,
please provide such communications or concems from 2010 to present.
Request No. 151: Deer Creek Please refer to the work paper *8.14 - Deer Creek
Mine.xlsx".
a) Please provide the total amount collected through the Idaho ECAM related
to Deer Creek from January 1,2016 to present.
b) Please provide workpapers demonstrating how RMP accounted for the
capital costs associated with the Deer Creek unrecovered investment.
c) Please provide all workpapers and discover related to Deer Creek filed
under Docket No PAC-E-15-09.
DATED this l4n day of September, 2021.
RACINE OLSON, PLLP
By:c
C.B
BAYER CORPORATION'S FOURTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER. 3
CERTtr'ICATE OF MAILING
I HEREBY CERTIFY that on this 146 day of September, 2O2l,t caused to be served a true
and correct copy of the foregoing document upon the following individuals in the manner indicated
below:
RACINE OLSON, PLLP
By c
RANDALL C. BUDGE
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720, Boise lD 83720-0074
I l33l W. Chinden Blvd, Bldg. 8, Suite 201-A
Boise,lD 83714
Jan.noriyuki@nuc. idaho. sov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 841l6
ted.weston@pac i fi corp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah St., Suite 2000
Portland, OR97232
datarequest@f acifi corp.com
Dayn Hardie
Matt Hunter
Attorneys for Commiss ion Staff
Deputy Attomeys General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-007 4
Dayn.hardie@puc. idaho. eov
[e-mail]. eov
Karl Klein
Deputy Attomey General
Idaho Public Utilities Commission
47 2 W . Washington (837 02)
PO Box 83720
Boise, ID 83720
karl. klein@.puc. idaho. sov
Emily L. Wegener
Matthew D. McVee
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 841l6
Em i ly.we gener@paci fi corp.com
Matthew.mcvee@pac ifi corp.com
BAYER CORPORATION'S FOURTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER.4
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Bradley Mullins
MW Analytics, Energy & Utilities
brmul [e-mail]
James R. Smith
Bayer Corporation
P4 Production, L.L.C.
371 S. 3rd West
Soda Springs, Idaho 83276
j [e-mail]
Brian C. Collins
Maurice Brubaker
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
bcol Iins@consu ltbai.com
[e-mail]
Lance Kaufinan
Aegis Insight
2623 NW Bluebell Place
Corvallis, Oregon 97330
I an c e @,ae sis i n s i ght. com
Eric L. Olsen
Attorney for ldaho lwigation Pumpers
Associotion, Inc.
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6l l9
Pocatello, Idaho 83205
[e-mail]
Ronald L. Williams
Attorney for P aciJiCorp ldaho Industrial
Customers
HAWLEY TROXELL ENNIS & HAWLEY
877 Main Street, Suite 1000
P.O. Box 1617
Boise, tdaho 83702
rwi Iliams@hawleytroxel l.com
PIIC Electronic Service Only:
Val Steiner: [e-mail]
Kyle Williams: wil [e-mail]
Adam Gardner: [e-mail]
Mike Veile
Bayer Corporation
P4 Production, L.L.C.
P.O. Box 816
Soda Springs, Idaho 83276
[e-mail]
Kevin C. Higgins
Energy Strategies
I I I East Broadway, Suite 1200
Salt Lake city, utah 841I I
khissin .com
Brad M. Purdy
Attorney for C ommuntty Action P artners hip
Association of ldaho
2019N. lTth st.
Boise,ID. 83702
[e-mail]
BAYER CORPORATION'S FOURTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER - 5