20210914PAC to Bayer 111-130.pdf

ROCKY MOUNTAIN
Pot'I'ER
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 14,2021
Randall C. Budge/Bayer randy@racineolson. com (C)
Thomas J. Budge/Bayer ti @rac i neo I son. com (WXC)
Brian C. Collins/Bayer bco I I ins@consu ltbai. com (WXC)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer khie gins@.enersy strat. com (C)
Lance Kaufman/Bayer lance@aeeisinsi eht. com (C)
James R. Smith/Bayer i im. r. smi th @ic loud. com (C)
Mike Veile/Bayer [e-mail]
Courtney HigginVBayer chiseins@enersJ- strat. com
Mill i Picharo lBay er mpichardo@en ersy strat.c om
Neal Townsend/Bayer ntownsend@enersystrat. com
RE: ID PAC-E-21-07
Bayer Set l0m (l I l-130)
Please find enclosed Rocky Mountain Power's Responses to Bayer 106 Set Data Requests I I l-
I 14, I 16,120-121,125-127, and 129. Also provided are Attachments Bayer 125,126, and 127.
Also provided via BOX are Confidential Attachments Bayer I 14 and 12l. Confidential
information is provided subject to protection under IDAPA 3 1 .01 .01 .067 and 3 I .01 .0 1.233, 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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC brmu I I in s@mwanalyt ics. conr
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 tony@],ankel.net (C)
Ben Otto/ICL botto@ idahoconservation. ors (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PtrC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony YankeUIIPA [e-mail] (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 /Rocky Mountain Power
Septeinber 14,2021
Bayer Data Rquest I I I
BayerData Request 111
Coal Cos6. Please provide the Bridger Coal Mine lO-year plan.
Reponse to Bayer Data Requct 111
PacifiCorp objects to this request because it falls outside ffre test pedod which is
based on 2020 costs adjusted for known and measurable changes and would not
lead to admissible evidence in fiis proceeding.
Recordholder:Daniel Moody
Michael WildingSponsor:
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
Bayer Data Request I 12
Bayer Data Request 112
Coal Costs. Please provide all planning documents related to the closure of the
Bridger Coal Mine underground mine.
Response to Bayer Data Request 112
PacifiCorp objects to this request because it falls outside the test period which is
based on2020 costs adjusted for known and measurable changes and would not
lead to admissible evidence in this proceeding. Notwiflrstanding the foregoing
objection, PacifiCorp responds as follows:
Bridger Coal's underground mine is projected to shutter near year-end202l.
Material and equipment are forecast to be recovered from the mine in early 2022.
The portal will be sealed in early 2022 and mine reclamation is forecast to occur
during 2022through2024. Reclamation expenditures will be funded from
Bridger Coal's reclamation trust fund.
Recordholder:Daniel Moody
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
BayerDataRequest ll3
Bayer Data Request 113
Coal Costs. Please explain how PacifiCorp intends to dispose of underground
mine assets.
Response to Bayer Data Request 113
PacifiCorp objects to this request because it falls outside the test period which is
based on2020 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:
Bridger Coal's underground mine assets will be disposed following prudent
company policies and procedures in accordance with statutory requirements.
Proceeds from asset disposals from competitive saleVauctions, scrap sales or
vendor retums will reduce Bridger Coal fuel costs to the Jim Bridger plant.
Recordholder:Daniel Moody
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
Bayer Data Request I 14
Bayer Data Request 114
Coal Costs. Please refer to Exhibit No. 40 Page 8.3, Jim Bridger Rate Base.
Please provide the Bridger Coal Mine plant records documenting the rate base
identified in this page. Please indicate which assets serve underground mining
operations.
Response to Bayer Data Request 114
Please see Confidential Afiachment Bayer I14.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, the ldaho 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: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
Bayer Data Request I 16
Bayer Data Request 116
Coal Costs. Please provide the Net Power Cost forecast with the depreciation and
amortization expense associated with dre underground mine excluded from the
BCC coal prices, under the assumption that ldaho's share of the remaining
balance of underground mine assets are offset against a portion of the Tax Cuts
and Jobs Act deferral balance. Such prices should continue to include other
operating expense associated with the underground mine.
Response to Bayer Data Request 116
PacifiCorp objects to this request because it is overly burdensome. Subject to and
wittrout waiving this objection, the Company responds as follows: the Company
has not performed the requested analysis.
Recordholder: Daniel Moody
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
Bayer Data Request 120
Bayer Data Request 120
Pryor Mountain. Please refer to the Direct Testimony of Robert Van
Engelenhoven Section III. Please provide the following data related to the Pryor
Mountain project:
(a) Please provide the dates for all notices to proceed.
(b) Please provide expense by month.
(c) Please provide tansfers to plant by month
Response to Bayer Data Request 120
(a) A written notice to proceed (NTP) was issued to the Balance of Plant (BOP)
contractor on September 27,2019, and a written NTP was issued to the
Turbine Supply contractor on September 30,2019.
(b) Please refer to the table below for the operations and maintenance (O&M)
expenses for the Pryor Mountain wind project by month (December 2020
through July 2021):
(c) Please refer to the table below for the plant in-service amount by month
@ecember 2020 through June 2021):
Dec-20 $74.087.939
Jan-21 $122304.783
Feb-21 $63.691.t27
Mar-21 $137.065.731
Apr-21 $5.601.782
May-21 $417,242
Jun-21 $711.070
Total $403.879.574
Recordholder:Robert Van Engelenhoven I Gary Tawwater / Tom Evans
Robert Van EngelenhovenSponsor:
Dec-20 lan-21 Feb-21 Mar-21 Apr-21 Mav-21 Jun-21 Jul-21
$2.425 $r l r.084 $4r.003 $84.701 s334.749 $25.s49 $233.9s r s260.073
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
Bayer DataRequest l2l
Bayer Data Request 121
Load. Please provide PacifiCorp's hourly load by jurisdiction from 2014 to
present.
Response to Bayer Data Request 121
Please refer to Confidential Attachment Bayer 12l. Note: 2021 data (provided for
January 2021 through June202l) is preliminary and subject to change.
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 ttre Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: David Novom
Sponsor:Steve McDougal
PAC-E-21{7 / Rocky Mountain Pover
September 14,2A2l
BayerDataRequest 125
Bayer Date Request 125
Property Tar Please provide PacifiCorp's Cholla property tax payment by year
lun2019,2CI20, and202l.
Response to Beyer Deta Request 125
Please refer to Attachment Bayer 125 which provides oopies of semi-annual
property tax paynurts made to the Navajo County Treasurer during 2A19,2020,
and202L
Recordholder: Norm Ross
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
Bayer Data Request 126
Bayer Data Request 126
Property Tax. Please refer to Confidential Exhibit 42
(a) Please provide work papers supporting the 2020 and202l assessed values for
each state.
(b) Does the202l assessed value for Arizona reflect the impact of closing Cholla
on Cholla properly tax assessment? If no, why not?
Response to Bayer Data Request 126
(a) Please refer to Affachment Bayer 126 which provides copies of fural 2020 and
2021 state assessment notices. Note: the final202l assessment for
Washington was not yet finalized when the updated estimate of 2021property
tax expense was prepared and the frnal2020 assessment amounts for certain
states vary slightly from the amounts used in the model.
(b) No. Because Arizona assessments operate on a one-year lag basis, the $ 173
million value reflected in the Arizona Department of Revenue's 2020
assessment becomes the assessed value for 2021 property tax purposes. As a
result, the Company will record property tax expense related to the $ 173
million assessed value during calendar year 2021and pay the associated
amount of property tax to Navajo County in two equal installments in
November 2021 andMay 2022. The late 2020 closure of Cholla Unit 4 is
expected to result in lower property tax expense beginning in2022.
Recordholder:Norm Ross
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
September 14,2021
Bayer Data Request 127
Bayer Data Requestl2T
Depreciation. Please refer to the Direct Testimony of Steven R. McDougal at
page22.
(a) Please provide the impact of the change in probable retirement dates for steam
plants in the referenced depreciation study on Idaho allocated depreciation
expense in this case. Please provide such data by plant.
(b) Does the early closure of Colstrip, Jim Bridger, and Craig units reduce
PacifiCorp's revenue requirement in post closure years? If no, why did
PacifiCorp accelerate the planned retirement date for these units?
(c) Does the early closure of Colstrip, Jim Bridger, and Craig units increase
PacifiCorp's revenue requirement in pre closure years?
(d) Please provide the current agreement among Colsfiip 3 and 4 owners
regarding the end of operation date for these units. Please indicate if
PacifiCorp supported this date in discussions with other owners.
(e) Does PacifiCorp currently expect Colstrip 3 and 4 to operate beyond 2027? lf
no, why not?
Response to Bayer Data Requestl?T
(a) Isolating the direct impact the change in probable retirement dates for
Colstrip, Craig Unit l, Craig Unit2, Jim Bridger Unit l, and Jim Bridger Unit
2 had on Idaho's allocated depreciation expense in this case involves a
complex calculation and would require the Company to obtain an external
depreciation consultant to conduct a separate depreciation study for those
steam plants using the probable retirement dates approved in the Company's
previous depreciation study under Docket No. PAC-E-13-02. This specific
analysis has not been performed by the Company, and as a result, such data
cannot be provided.
Please refer to Attachment Bayer l27,which provides a calculation of the
change to Idaho's allocated depreciation expense due to the change in
depreciation rates for Colstrip, Craig Unit l, Craig Unit2, Jim Bridger Unit l,
and Jim Bridger Unit 2 stipulated in the latest depreciation study under Docket
No. PAC-E-I8-08.
(b) This specific analysis has not been done and would require many unknown
assumptions that are outside the scope of this rate case.
PAC-E-21-07 / Rocky Mountain Power
Septernber 14,2021
Bayer DataRequest 127
(c) This specilic analysis has not been done andwould rcquire maoy
unknown assrmptions that are outside the soope of this rate case.
(d) There is no current agreement among Colstrip 3 and 4 owners rcgarding
the end of operation date for trese units.
(e) PacifiCorp's202llRP has Colstip 3 and 4 closing m2025, assuming an
agreement can be reaehed with the otrcr owners.
Reeordholder: Jusars Evangelista / Steve McDougal
Spoosor: Steve McDougal
PAC-E-21{7 / Rocky Mountain Power
September 14,2021
BayerDataRequest 129
Bayer Data Request 129
Load. Please provide the documents produced in response to Bayer Data Request
2l and24 for 2021 to date.
Response to Bayer Data Request 129
Please refer to the Company's ls Supplemental responses to Bayer Data Request
2l and Bayer Data Request 24.
Recordholder:Not applicable.
Not applicable.Sponsor: