20210921Bayer 152-232 to PAC.pdf

Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box I39l;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Far [phone]
randy@rac ineo lson.com
ti@rac lson.com
Attorneys for Intervenor P4 Production, L.L.C., an afiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMI\{ISSION
IN TIIE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS RATES
AI\[D CHARGES IN IDAHO ANID
APPROVAL OF PROPOSED ELECTRIC
SERYICE SCHEDULES AND
REGULATIONS
CASE NO. PAC.EAI-07
BAYER CORPORATION'S
FIFTEENTH SET OF DATA
REQUESTS TO ROCKY
MOTINTAIN POWER
P4 Production, L.L.C., an affiliate of Bayer Corporation (hereinafter "Bayer"), by and
through its attorneys, hereby submits this Fifteenth Set of Data Requests to Rocky Mountain
Power, pursuant to Rule 225 of the ldaho 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 identiff the name, job title, location and telephone number
of the record holder.
In 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 FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER. I
Bayer Set 15
Request No. 152: Rate Base. Please refer to the McDougal workpaper "S.l4 -
Deer Creek Mine.xlsx".
a) Please refer to sheet "8.14.2". Were any of the items listed in this account
included in rate base ofbase rates from 2015 to present? Ifyes, please
indicate the amounts. [f no, why not?
b) Please refer to sheet "8.14.2". Please provide continuing property records
or other documentation of supporting the amounts of plant in each
account.
c) Please refer to row 21. Please provide the amount recovered from ldaho
rate payers through the ECAM mechanism related to Deer Creek by
month from January 1,2015, to present.
Request No. 153: Rate Base. Please refer to the McDougal workpaper "8.2 -
Trapper Mine Rate Base.xlsx".
a) Please refer to sheet "PAGE 8.2.1" line 13. Please explain why
accumulated depression declines from December 2020 to December 2021.
b) Please provide Trapper Mine actual accumulated depreciation by month
from January 2017 to present.
c) Please refer to "PAGE 8.2.1" line 17. Please explain why inventories are
forecasted to increase by 20 percent from December 2020 to December
2021.
d) Please provide actual inventories by month from January 2017 to present.
e) Please refer to sheet "PAGE 8.2.1" line 18. Please explain what is
included in prepaid expenses and provide the basis for the December 2021
forecast.
0 Please refer to sheet "PAGE 8.2.2 line 21. Please explain why only the
inoemental change in reclamation liability is included in the adjustment
rather than the full amount.
g) Please refer to sheet "PAGE 8.2.2" line 21. Please explain why no
equivalent adjustment is made for Bridger Coal Mine.
h) Please refer to sheet "PAGE 8.2 line 12 and 14. Please explain why end
of year 2021 amount is used for the Other Tangible Property but the 12
month average is used for reclamation liability.i) Does Trapper Mine coal cost include a component for reclamation? If yes,
please explain how Trapper Mine and PacifiCorp account for this.j) Please provide the year end 2020 balance sheet, income statement,
statement of cash flows, and statement of shareholders equity for the
Trapper Mine.
Request No. 154: Rate Base. Please refer to the response to Bayer DR I l2 which
indicates Bridger Coal's undergtound mine is projected to shutter near year end 2021.
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
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Please explain why this is not reflected in the response to Bayer DR I14, which shows
underground materials and supplies in December 2021are mone than double December
2020 and underground coal inventory is $1.5 million higher in December 2021 compared
to December 2020.
Request No. 155: Rate Base. Please refer to the confidential attachment provided
in response to Bayer DR I14.
a) Please refer to sheet "PAGE 8.3.1 detail" row l2 Deferred Long Wall
Costs. Please explain what costs are included in deferred long wall costs.
b) Please refer to sheet "PAGE 8.3.1 detail" row 12 Deferred Long Wall
Costs. Please identiff any applications for deferral of these costs with the
Idaho Public Utilities Commission. If no application was made why is
PacifiCorp requesting these costs be included in rate base?
c) Please refer to sheet "PAGE 8.3.1 detail" row l2 Deferred Long Wall
Costs. Is the amortization of these costs included in Jim Bridger coal
cost? If yes, why?
d) Please refer to sheet "PAGE 8.3.1 detail" row l2 Deferred Long Wall
Costs. Do any of the deferred costs relate to the recovery effort or
abandonment of the Joy Longwall?
e) Please refer to sheet "PAGE 8.3.1 detail" row 9 Structure, Equipment,
Mine Dev. Please provide documents supporting the September 2021
increase in plant. Has Bridger Coal made the plant investment included in
the forecast for September 2021? If no, why not? If yes, what was the
actual capital addition?
0 Please refer to sheet "PAGE 8.3.1 detail" row l4 Accumulated
Depreciation. Please reconcile the annual change in accumulated
depreciation from December 2020 to December 2021with the amount
shown in Sheet "CONF Attach I 14" from 2019 to 2020.
g) Please refer to sheet "PAGE 8.3.1 detail" Please provide the actual
amounts for lines 22through 43.
Request No. 156: Rate Base. Please refer to the PacifiCorp 2021 IRP.
a) Please refer to sheet "PAGE 8.3.1 detail" row l2 Deferred Long Wall
Costs. Please explain what costs are included in deferred long wall costs.
b) Please refer to sheet "PAGE 8.3.1 detail" row l2 Defened Long Wall
Costs. Please identiff any applications for deferral of these costs with the
Idaho Public Utilities Commission. If no application was made why is
PacifiCorp requesting these costs be included in rate base?
Please refer to sheet "PAGE 8.3.1 detail" row l2 Deferred Long
Request No. 157: Rate Base. Please refer to the response to IPUC DR 48,
Confidential Attachment Ponderosa-Vitesse 60MW Load Addition-PCN 94009142 l0-8-
20lg.pdf.
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOLINTAIN
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a. Please reconcile the total cost in this document with the amounts included
in Attach IPUC 48-l CONF.xlsx.
b. Please provide all studies and analysis related to "existing Prineville area
I l5kV system." Please include the date the study or analysis was
performed.
c. Please provide all workpapers used to calculate the original CIAC for this
project.
d. Please provide all workpapers used to calculate the final CIAC for this
project.
e. Please provide the coincident peak demand and annual load of the
Prineville area, excluding customers over l0 MW from 2016 to 2020.
f. Please provide the coincident peak demand and annual load of the
Prineville area for customers over l0 MW and customers referenced in
Attachment Ponderosa-Vitesse 60MW Load Addition-PCN 9 4009 I 42 l0-
8-20l9.pdf from 2016 to2020.
g. Please identiff the three most recent transmission line extensions
performed in Idaho. Please include the total cost of the extension, the
customer contribution, the extension allowance, and the amount of load
served by the extension.
Request No. 158: Wildfire Costs. Please refer to Exhibit No. 40 Page I 62 of 350
which indicates that costs associated with two fire damage related capital projects are
included in the proposed rates. Please also refer to the FERC Docket No. IN2l -6-000
Order to Show Cause and Notice of Proposed Penalty issued April I 5,2021.
a) Please provide the Enforcement Staff Report referenced in this order.
b) Please provide all material available to PacifiCorp and cited in the
Enforcement Staff Report.
c) Please provide all material provided to the FERC in as part of Docket No.
IN2l-6-000.
Request No. 159: Wildfire Costs. Please provide each work order or request
created by either Company employees or third parties related to vegetation management
issued between January 1,2017 to present and provide the date that the work order was
completed.
Request No. 160: COVID Costs. Please refer to RMP's response to Bayer DR
a) Please provide all workpapers and analysis supporting the estimated
$7,000,000 cost reductions.
b) For each component of the cost reduction, please provide RMP's cost by
month from January 2019 to present.
c) Please provide the amount that RMP has incurred in202l to transition
employees to work from home.
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
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98.
d) Please provide the amount that RMP has incurred in202l to accommodate
social distancing.
e) Please provide the amount that RMP has incurred in202l to accommodate
enhanced sanitation measures.
Request No. 161: COYID Costs. Please refer to RMP's response to PIIC DR 81.
Please provide the number of RMP employees participating in the Voluntary Work from
Home program by month from March,2020 to present.
Request No. 162: Pryor Mountain. Please refer to the Direct Testimony Robert
of Van Engelenhoven at page 4.
a) Please provide average annual wind speed for Prior Mountain.
b) Please provide the forecasted annual capacity at Pryor Mountain for the
Vestas Model Vl 10-2.0 MW.
c) Please provide the forecasted annual capacity at Pryor Mountain for the
Vestas Model Vll0-2.2 MW safe harbor turbines.
d) Please provide the forecasted annual capacity at Pryor Mountain for the
General Electric Model 116-2.3 MW safe harbor turbines.
e) Please provide the forecasted annual capacity at Pryor Mountain for the
Vestas Model Yll0-2.2 MW follow-on turbines.
0 Please provide all invoices related to the purchase and delivery of the
General Electric Model 116-2.3 MW safe harbor turbines.
g) Please provide all invoices related to the purchase and delivery of the
Vestas Model Vl l0-2.2 MW.
h) Please refer to RMP Exhibit No. 32. Please provide each revision of the
Pryor Mountain Wind Farm turbine layout and all associated wind studies.
i) Please explain why the Vestas Model Vll0-2.2 MW was selected for the
follow-on turbines at this site.j) Please provide the actual output, by turbine at the most granular time
interval available, for Prior Mountain for August 2021.
Request No. 163: Pryor Mountain. Please refer to the Direct Testimony Robert
of Van Engelenhoven at page 5.
a) Do any restrictions exist that prevented RMP from selling RECs to Vitesse
from anotherEY 2020 or repowering project? If yes, please identiff all
such restrictions.
b) Please provide the results of the Oregon Schedule 272 from 2018 to
present. Please include the original RFP, responses, and all scoring,
evaluation, and selection documents.
Request No. 164: Pryor Mountain. Please refer to the Link workpaper "Table 4,
Figure 34, FB_PryorMtn_Analysis_20 I 9- I 2-06 v3.xlsx".
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQI.JESTS TO ROCKY MOUNTAIN
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a) Please refer to the sheet name "Pryor Mountain Economics". Are the
future values on this sheet provided in nominal dollars? If yes, what was
the assumed inflation rate?
b) Please refer to the sheet name "Pryor Mountain Economics". Please
provide all models and assumptions used to generate the highlighted
values in l0 through 21.
c) Please refer to the sheet name "Pryor Mountain Economics" row 20.
Please explain why the values in this row are declining.
d) Please provide the annual property tax and assessed value for Foote Creek
facility from 1999 to2019.
e) Please refer to the sheet "System Value". Please provide all models and
assumptions used to generate the blue text in rows 10, I l, 13, 34,35, and
38.
Request No. 165: Pryor Mountain. Please refer to the confidential attachment
provided in RMP's response to Bayer DR I18. Please describe the nature of the
capitalized maintenance included in the column I.
Request No. 166: Pryor Mountain. Please refer to the McDougal Workpaper
"Attach IPUC 126 CONF.xlsx".
a) Please refer to Column C assessed value as of January 1,2020. Are the
assessed values for Montana based on 2019 properly values?
b) Please also refer to Exhibit No. 42 Page 2 of 3. Please provide a detailed
explanation of the basis for the Pryor Mountain Tax Savings. Please
include documentation of the favorable county level abatements.
c) Please refer to Column P. Please provide the basis for the change in Pryor
Mountain Tax savings from 2022 to 2024.
d) Please refer to cell Pl6. Please provide the file referenced in this cell.
e) Please refer to cell P52. Please provide the file referenced in this cell.
0 Please refer to cell D49. Please provide a version of this workpaper with
the original reference intact.
g) Please refer to row 52. Please provide the amount of 2022 estimated net
property tax due to Pryor Mountain and associated facilities including
transmission.
Request No. 167: In reference to the response to Bayer Data Request 36, please
provide the average level of full time employees by group of employees identified in the
response (IBEW 125, IBEW 659, etc.) for each of the five years (2016-2020).
Request No. 168: In reference to confidential response to Bayer Data Request 35,
please provide a detailed explanation for the level of overtime hours incurred in 2020. Did
the pandemic have any effect on the level of 2020 overtime hours? Please explain in detail.
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
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Request No. 169: In reference to the levels of overtime listed in confidential Bayer
Data Request 35, please provide the level of overtime hours that match the employee group
who incurred the overtime charged for each of the five years Q0l6-2020).
Request No. 170: In reference to the response to Bayer Data Request 40, please
reconcile the amount of unused leave expense balance for 2020listed in the data request to
the amount included in the PacifiCorp cost of service ($5,191,972).
Request No. 171: Please provide a detailed explanation as to why the unused leave
expense balance should be included in RMP's Idaho cost of service?
Request No. 172: In reference to the Company workpaper page number 4.2.3,
please indicate if the labor adjustrnent in that workpaper reflects all RMP employees being
compensated for 2080 hours of work (full-time hourly employees) or an annual salary? If
the answer is no, please provide a detailed explanation for the response.
Request No. 173: In reference to confidential response to Bayer Data Request 41,
does that response include the complete description of PacifiCorp's Annual Incentive Plan
(AIP)? If not, please provide a complete copy of the AIP.
Request No. 174: [n reference to the response to Bayer Data Request 42, please
reconcile the bonus award amount listed in the data request to the test year (2020)
PacifiCorp amount included in the cost of service ($6,887,562).
Request No. 175: Are awards/bonuses included in RMP salary surveys as part of
the total compensation paid to employees? If so, how does RMP estimate the amount to
be included?
Request No. 176: In reference to the response to Bayer Data Request 43, please
provide all documentation that lists the specific reasons or actions why performance awards
were given for 2020. Please provide a breakdown by employee and amount awarded
without identifuing the employee.
Request No. 177: [n reference to the Company's request to collect approximately
$2.1 million (total company) in severance costs, please provide the following information:
a) The date each employee was severed from the Company.
b) The date a new employee was hired to replace an employee. To the extent an
existing employee was used to replace that employee, the date, if applicable,
that an employee was added to the workforce as a result of that employee being
severed. Please provide the salary of the new employee.
c) The amount of severance pay and the date paid to each employee
Request No. 178: To the extent that PacifiCorp is reducing its workforce, please
provide a detailed explanation justifing the inclusion of severance pay in the RMP ldaho's
cost of service.
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
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Request No. 179: Please provide the actual level of severance costs for each of the
last five calendar years (2016-2020).
Request No. 180: Please provide the level of hydro maintenance costs assigned to
the Idaho operations for each of the last five calendar years (2016-2020) and the amount
included in RMP Idaho's current cost of service. If the amount included in cost of service
is greater than previous year's individual totals, please provide a detailed explanation for
the increase in expense.
Request No. 181: Please provide the level of injuries and damages expense
assigned to the Idaho operations for each of the last five calendar years (2016-2020) and
the amount included in RMP Idaho's current cost of service. If the amount included in cost
of service is greater than previous year's individual totals, please provide a detailed
explanation for the increased expense.
Request No. 182: ln reference to PAC-E-ll-l2, please provide the amount of
depreciation expense, operating expenses, maintenance expenses, property taxes and rate
of retum impacts included in RMP Idaho's proposed cost of service related to the operation
of the Cholla plant. Please indicate if these totals were total Company totals or Idaho
allocated amounts. Note, if a more curent rate proceeding identified the above costs, please
use that proceeding to respond to the request. If different amounts were included in a
Stipulated rate case, please use those figures in the response.
Request No. 183: [n reference to the response to Bayer Data Request 42, please
provide a breakdown of the bonuses paid by retention and hiring, safety/perfornance
awards and Long-term Incentive Plan ("LTIP") payments for each year (2016-2020).
Request No. 184: Reference RMP witness Meredith Workpaper tD GRC
Blocking 2020: Please reconcile the2020 Schedule 401 special contract revenues of
$5,818,167 to the $6,791,774 of revenues reported in2020 on in PacifiCorp's 2020
FERC Form I, page 304.12,line 9.
Request No. 185: Reference RMP witness McDougal workpaper "3.l-.3 - Idaho
Revenue Adjustment" tab *3.1.3 - 3.1.4": Please provide an explanation for the following
amounts identified in the referenced workpaper:
a. Income Tax Deferral Adjustments
b. Revenue Adj Property Insur
c. Revenue Accounting Adjustments
Request No. 186: Does RMP agree that the Schedule 197 Federal Tax Act
Adjustment surcredits will otherwise expire on January 1,2022, resulting in a revenue
increase to PacifiCorp? If no, please explain.
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQI.JESTS TO ROCKY MOUNTAIN
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Request No. 187: Please provide actual Schedule 197 Federal Tax Act
Adjustment surcredit revenues by rate class for calendar years 2019 and2020, detailed
separately for each year and rate schedule.
Request No. 188: Please provide actual ECAM revenues by rate class for
calendar years 2019 and2020, detailed separately for each year.
Request No. 189: Reference RMP witness McDougal workpaper "3.l-.3 - Idaho
Revenue Adjustment" Tab *3 .l .3 - 3.1 .4": Please explain how RMP has treated the
Schedule 197 Federal Tax Act Adjustment surcredit revenues in revenue normalization in
the referenced workpaper and explain whether the Schedule 197 Federal Tax Act
Adjustment surcredit revenues are included in normalized revenue in the referenced
workpaper.
Request No. 190: Reference RMP's response to PIIC Production Request 18,
Attachment PIIC l8: Please provide 2019 and2020base rate revenues (i.e. excluding all
supplemental schedule revenues such as the TAA, ECAM, and BPA residential
exchange) for each rate schedule in the format similar to Meredith Workpapers "COS ID
2021", tab "Revenues" Excel Rows "l2l:137."
Request No. 191: Reference RMP's response to PIIC Production Request 18,
Attachment PIIC l8: Please detail the supplemental schedule revenues such as the TCJA,
ECAM, and BPA residential exchange for each rate schedule for 2019 and 2020 in the
format similar to Meredith Workpapers "COS lD 2021", tab "Revenues" Excel Rows
"l2l:137." Please provide separate detail for each supplemental rate schedule.
Request No. 192: Reference RMP witness McDougal workpaper "3.l-.3 - Idaho
Revenue Adjustment" tab "3.1.3 - 3.1.4": Please provide an explanation and workpapers
supporting each of the hardcoded numbers in the following columns:
d. Excel Column "D" Reconciling Adjustment
e. Excel Column "F" Normalization
f. Excel Column "E" ECAM
g. Excel Column "K" Blocking
Request No. 193: Please detail the total amount of retirements with detail by
FERC account associated with the repowering of Marengo l, Marengo 2, Dunlap and
Foote Creek. Please also state the date of the retirements.
Request No. 194: Please identiff the total number of customers by rate schedule
with AMI meters currently deployed and the total number of customers with AMI
expected to be deployed by the end ofcalendar year 2021.
Request No. 195: Reference RMP's response to PIIC Production Request 56:
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
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h. Were the reimbursements identified in the referenced request related to
property damage to PacifiCorp property, a litigation claim, or some other
reimbursement. Please explain.i. Please provide source documentation from the insurer demonstrating the
nature and scope of the reimbursements identified in the referenced response.
Request No.200: Reference RMP'S response to PIIC Production Request 59:
Please identiff the amount environmental spending in calendar year 2020 applied to the
regulatory liability accounts identified in the referenced response.
Request No.201: Reference RMP's response to PIIC Production Request 82:
Please explain how the $7,423,175 of affiliate costs are being assigned to PacifiCorp
from the affiliate. Please provide accounting workpapers supporting the calculation of
the affiliate service amounts encompassing each line item in attachment PIIC 82. Please
also provide any cost allocation manuals in effect during the test period, which determine
how the affiliate service costs are to be assigned or allocated to PacifiCorp.
Request No.202: Reference RMP's response to PIIC Production Request 83:
Please provide an updated version of Kobliha Exhibit 3 incorporating the debt issuance
identified in the referenced response, and any other necessary change to the exhibit
associated with the new debt issuance.
Request No.203: Reference RMP's response to PIIC Data Request 88: Please
provide the workpapers used to support the coal costs included in net power costs in this
proceeding, including all of the supporting workpapers (e.g. "01 OpsCostSchedules", "03
Labor- SURF," etc.) that are typically provided along with RMP's net power cost filings.
Please include all of the budget and operating cost information at Bridger coal company
and account for each coal contract, and any other costs, proposed to be included in rates
for each power plant.
Request No. 204: Reference RMP's response to PIIC Data Request 90,
Attachment PIIC 90: Please provide an explanation and source accounting documentation
for the following line items included in the referenced workpaper:
j. Cholla Closure M&S RA ID Amort: $350,550k. Cholla Closure CWIP RA ID Amort: $57,480
Request No. 205: Reference RMP Witness McDougal Workpaper "8.9 -
Regulatory Assets & Liability Amortization", Tab "Page 8.9.6": Are the dates in column
"8" of the referenced workpaper correct?
Request No.206: Reference RMP Witness McDougal Workpaper "8.9 -
Regulatory Assets & Liability Amortization", Tab "Page 8.9.6": When does PacifiCorp
plan to submit its next deprecation study and what will the effective date of the next
depreciation study be?
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Request No. 207: Please provide a copy of the workpapers supporting
PacifiCorp's lead-lag study proposed in this proceeding.
Request No. 208: Please state whether the lead-lag study proposed in this
proceeding considered the following prepaid expense items, for each item:
l. Prepaid taxes
m. Prepaid insurance
n. Prepaid employee benefits
o. Prepaid commission fees
p. Prepaid hardware & software fees
q. Prepaid O&M.r. Vacation (i.e. time-off) accruals
Request No.209: Reference RMP's response to PIIC Production Request 55:
Please identiff where specifically in the B-Tab workpapers the amounts identified as
"insurance premiums and the expenses related to handling damages" have been included.
Request No.210: Reference workpaper *Bl9 - Deferred lncome Tax Balance"
provided in response to PIIC Production Request 5: Please reconcile the total Company
ADIT balance identified in cell *F256" of $2,467,789,000 to the total company ADIT
balance identified in workpaper "T .4 - Power Tax ADIT Balance", Tab "Page 7 .4.1", Cell
"C57" of $2,848,256, I 04.
Request No. 211: Reference RMP witness McDougal workpaper "7.4 - Power
Tax ADIT Balance", Tab "Page 7.4.1": Please provide an explanation for the item titled
"Avoided Cost" on row 28.
Request No.212: Reference workpaper "Bl9 - Deferred Income Tax Balance"
provided in response to PIIC Production Request 5: Please provide an explanation for the
line item'DTA720.560 Pension Liab UMWA Withdraw" on row 75 in the amount of
$1,847,000 (Idaho allocated), and explain whether the amount is appropriately considered
a deferred tax cost to Idaho, given that the withdrawal liability is not included in Idaho
rates.
Request No.213: Reference workpaper *Bl9 - Deferred lncome Tax Balance"
provided in response to PIIC Production Request 5: Please provide an explanation for the
line item 'DTA 910.530 Injuries & Damages Accrual -" on row 107 in the amount of
$3,532,000 (Idaho allocated), and explain whether the amount is appropriately considered
a deferred tax cost to Idaho, given that the underlying injuries and damages contingent
liability accruals are not included in ldaho rates.
Request No. 214: Reference workpaper "Bl9 - Deferred Income Tax Balance"
provided in response to PIIC Production Request 5: Please provide an explanation for the
line item'DTA Net Operating Loss Carryforward-State" on row I l5 in the amount of $
3,765,000 (ldaho allocated). Please identiff the states(s) where the Net Operating Loss
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
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carry forward has been in incurred and the associated amounts of carryforwards for each
state
Request No. 215: Please provide Schedule 401 monthly loads and demand over
the period 2019 through the latest month available
Request No. 216: Please identiff the original cost of the schedule 401 customer
meters, and associated accumulated depreciation.
Request No. 217: Reference RMP witness McDougal workpaper "JAM Dec
2021 lD GRC", Tab "Factors," cells "BBl3:BK25": Please provide workpapers,
including hourly loads used to support the jurisdictional coincident peaks, and the
associated temperature adjustments in cells "BB33:8K45" please provide detail
sufficient to identiff special tariff customers, such as direct access customer loads, which
are being directly assigned to a particular state, the Monsanto curtailment buythrough
product, and FERC jurisdictional sales to the Navajo Tribal Authority included in Utah's
jurisdictional allocation.
Request No. 218: Reference RMP witness McDougal workpaper "JAM Dec
2021 lD GRC", Tab "Factors," cells "BXl3:CG25": Please provide workpapers,
including hourly loads used to support the jurisdictional loads, and the associated
temperature adjustments in cells "BX33:CG45" please provide detail suffrcient to
identiff special tariff customers, such as direct access customer loads, which are being
directly assigned to a particular state, the Monsanto curtailment buythrough product, and
FERC jurisdictional sales to the Navajo Tribal Authority included in Utah's jurisdictional
allocation.
Request No. 219: Please provide Idaho state deferred income taxes as of
December 31,2020 included in revenue requirement, and identifu any adjustments to
Idaho state deferred taxes
Request No. 220: Did PacifiCorp recognize any excess deferred taxes associated
with the reduction in the Idaho state tax rate from 6.925%to 6.5oh. If yes, please identi$
the amount of excess accumulated defened state taxes associated with the Idaho state tax
rate change as ofthe date ofthe rate change.
Request No.221: Reference RMP witness McDougal workpaper "JAM Dec
2021lD GRC": In tab .'NRO," Excel Row 1366, RMP reports Idaho-allocated
temporary Schedule M additions of 90,656,91I and on Excel Row 1395 reports Idaho-
allocated temporary Schedule M deductions of 98,426,978. These two values net to a
total temporary book tax difference deduction of $7,770,066, Idaho allocated. After a
state tax effect of 6.5Yo, this amount implies a deferred tax expense of $1,525,652
(7,770,066 * l2l%* {l - 6.50/ol+6.5%l). Please reconcile that amount with the
$1,671,807 of deferred tax expense that RMP has proposed in this proceeding.
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Request No.222z Reference RMP witness McDougal workpaper "JAM Dec
2021 lD GRC", Tab "UCTR", cell "Ql29l": Please provide an explanation for the
amount identified as Interest & Dividends and provide workpapers supporting the total
company amount of $98,1 15,567.
Request No.223: Reference workpaper "B6 - lnterest Expense & RETC"
provided in response to PIIC Production Request 5, Cell "F23": Please explain whether
the amount identified as AFUDC (Other) consists of amounts associated with AFUDC
equity, and/or AFUDC Debt. Please also provide workpapers supporting the amounts in
the referenced cell.
Request No. 224: Reference Washington Utilities and Transportation docket UE-
210328, concerning "the revenue generated from the allocation of RECs to Vitesse, LLC
(Vitesse) as a result of the Pryor Mountain wind facilities":
a. Please provide an unredacted copy of the company's filing in the referenced
docket.
b. Please provide the total-company estimated annual revenue associated with
the referenced REC sales to Vitesse.
c. Please describe how the REC sales to Vitesse were considered in revenue
requirement in this docket.
Request No.225: Please identiff the total benefits of Pryor Mountain and Foote
Creek Repowering in RMP's proposed revenue requirement, including, but not limited to,
Net Power Cost benefits, Production Tax Credit benefits, and REC sales benefits.
Request No. 226: Please state the capacity factor of Foote Creek both before and
after the repowering project.
Request No. 227: Please state the total revenue requirement associated with Pryor
Mountain and Foote Creek included in revenue requirement in this proceeding,
individually for each resource. Please provide workpapers supporting the calculation,
including supporting detail for each revenue requirement component.
Request No.228: Reference RMP Witness McDougal workpaper "8.l5 - New
Wind & Repowering Capital Additions REDACTED": Please provide the end of period
2020 gross plant in service, depreciation reserves and ADIT associated with each new
wind resource, transmission resource and repowering resource identified in the
referenced workpaper.
Request No. 229: Reference RMP Witness McDougal workpaper "8.l5 - New
Wind & Repowering Capital Additions REDACTED": Please provide the annualized
depreciation expenses included in revenue requirement for each of the new wind
resource, transmission resource, and repowering resources identified in the referenced
workpaper.
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTATN
POWER - 13
Request No.230: Reference RMP Reference RMP Witness McDougal
workpaper "S.l5 - New Wind & Repowering Capital Additions REDACTED": Please
state the expected End of Period202l ADIT balances associated with each of the new
wind resource, transmission resource, and repowering resources identified in the
referenced workpaper.
Request No.231: Reference RMP Reference RMP Witness McDougal
workpaper "8.l5 - New Wind & Repowering Capital Additions REDACTED": Please
provide the confidential attachment provided in response to AWEC Data Request 07 in
Washington Utilities Transportation Commission Docket No. UE-210532 (2021Limited
Issue Rate Filing), where PacifiCorp calculated the 2021end of period ADIT balances for
the new wind and repowering resources at issue in that proceeding.
Request No. 232: Please provide PacifiCorp's most recent lO-year business plan,
including supporting workpapers in Excel format with all formulas and links intact.
(Note: The shaded areas reflect confidential information available only to parties who have
signed the Protective Agreement.)
DATED this 2lst day of September, 2021.
RACTNE OLSON, PLLP
c.
C
By:
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER - 14
CERTIF'ICATE OF MAILING
I HEREBY CERTIFY that on this 2l$ day of September, 2021,1caused to be served a true
and correct copy of the foregoing document upon the following individuals in the manner indicated
below:
RACTNE OLSON, PLLP
UDGEB
c
C.
By
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720, Boise ID 83720-0074
I l33l W. Chinden Blvd, Bldg. 8, Suite 201-A
Boise,ID 83714
Jan.noriyuki@puc. idaho. eov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 841l6
ted.weston@pac ifi corp.com
Dayn Hardie
John Hammond, Jr.
Deputy Attorneys General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg No. 8,
suite 201-4, (83714)
PO Box 83720
Boise, ID 83720-0074
dayn.hardie@puc. idaho. gov
iohn.hammond@puc. idaho.eov
Emily L. Wegener
Matthew D. McVee
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake city, uT 841l6
Ernily.wegener@paci fi corp.conr
Matthew.mcvee@pac ifi corp.com
Eric L. Olsen
Attorney for ldaho lrrigation Pumpers
Associotion, Inc. (IIPA)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello,Idaho 83205
eloGDechohawk.com
Data Request Response Center
PacifiCorp
datareq ificom.com
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTATN
POWER - 15
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Bradley Mullins
MW Analytics, Energy & Utilities
brm ul I ins@mwanal),tics.com
James R. Smith
Bayer Corporation
P4 Production, L.L.C.
371 S. 3rd West
Soda Springs, Idaho 83276
j im.r.smith@,icloud.com
Brian C. Collins
Maurice Brubaker
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
bcol I ins@consu ltbai.com
[e-mail]
Kevin C. Higgins
Courtney Higgins
Neal Townsend
Milli Pichardo
Energy Strategies
I I I East Broadway, Suite 1200
Salt Lake City, Utah 841I I
kh [e-mail]
chi [e-mail]
ntown send @energystrat.com
moichardo@enerq)rstrat. com
Ronald L. Williams
Attorney for PacifiCorp ldaho Industrial
Customers
HAWLEY TROXELL ENNIS & HAWLEY
877 Main Street, Suite 1000
P.O. Box 1617
Boise,ldaho 83702
[e-mail]
PIIC Electronic Service Only:
Val Steiner: [e-mail]
Kyle Williams: [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]
Lance Kaufman
Aegis Insight
2623 NW Bluebell Place
Corvallis, Oregon 97330
lance@aegisinsi eht.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,lD 83702
botto@ idahoconservation.org
BAYER CORPORATION'S FIFTEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER - 16
Brad M. Purdy
Auo. nqfur Cowttunity Aetiwr Pwtwrshlp
Assacia$lonaf ldslro.
2019N. lTth st.
Boiss,ID. 83702
[e-mail]
BAYER CORPORATION'S FIF',IEENTT{ SET OF DATA REQT,JESTS TO ROCKY MOIJNTAIN
POWER- 17