20210921Staff 200-212 to PAC.pdf

DAYN HARDIE (ISB No. 9917)
JOHN R. HAMMOND, JR. (ISB No. 5470)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC.E.2I-07
NINTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and John R. Hammond, Jr., Deputy Attorneys General, request that Rocky
Mountain Power ("Company") provide the following documents and information as soon as
possible, but no later than TUESDAY, OCTOBER 5,2021.r
This Production Request is to be considered as continuing, and the Company 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
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
NINTH PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
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I SEPTEMBER2I,2O2I
the person preparing the documents. Please also identifr 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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO.200: Please provide the Idaho Allocated Unadjusted Results for Rate
Base and depreciation expense using the Average Monthly Average method for the Company's
test year ending December 31,2020.
REQUEST NO.201: Please provide the Company's additional plant in service
adjustments (8.5, 6.1,6.2, etc.) using the Average Monthly Average method.
REQUEST NO.202: Please provide documentation of the amounts of the Company's
cash working capital provided by shareholders.
REQUEST NO.203: Please provide a schedule showing the amount of capital
investments for the year ending December 31,2021. Please break these out by month to show
these investments by each account number and the amounts allocated to Idaho.
REQUEST NO.204: Please provide monthly depreciation expense by account, and all
plant retirements for each month during 2021. Please break these out by account number and
Idaho allocation.
REQUEST NO. 205: For each rate base component, please provide the month-end
balances for each month from December 2079 to present.
REQUEST NO.206: Please provide the number of persons who left employment at
PacifiCorp for years 2018-2021. For each instance indicate if the departure was voluntary,
involuntary, or retirement.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBEF.2I,2O2I
REQUEST NO. 207: Regarding the Company's response to Production Request
No. 2, please provide a list of all transactions bookedin2020 that were allocated or directly
assigned to the Company's Idaho jurisdiction for FERC Account 921. Please include date, total
system amount, Idaho allocated amount, and any other identiflring information.
REQUEST NO. 208: Regarding the Company's response to Production Request
No. 120, please provide all criteria or metrics used for the objective targets and scorecards used
to determine Annual Incentive Plan incentive awards.
REQUEST NO. 209: Please provide the average annual rate of employee turnover at
the Company for the years 2018 through 2021 year-to-date.
REQUEST NO.210: In reference to the tabs "Demand Factors," "Dist. Factors," and
"Energy Factors" in Company witness Meredith's workpaper titled "COS ID 2021" that was
provided with the Application, please respond to the following:
a. Why Contract 2 shows a value of zero in the month of October in each tab.
b. If the value is not supposed to be zero explain the effect of the missing data on the
results of the Company's Cost of Service (COS) study provided in the Application
and provide an updated COS study.
c. Explain for each tab where the source input data comes from, the time period the
data comes from, and any adjustments made to the original data.
d. Provide the source input data in each tab in electronic format with links intact and
formulas enabled.
REQUEST NO. 211: Regarding the Company's response to Production Request No. 90,
please respond to the following:
a. The Company's response shows a difference in the Schedule 401 load shape and
load factor compared to current Schedule 9 customers. Please explain why the
Schedule 401 load shape and load factor are reasonable to include in a combined
schedule with the current Schedule 9 customers.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1J SEPTEMBER 2I , 2O2L
b. File "ID GRC Blocking2}Z}.xlsx" referenced in the Company's response, shows
Schedule 9 customers will have a bill increase of ten percent compared 5.7
percent for Schedule 401. Please provide any rate design options that would bring
the increase for each set of customers in each schedule closer to the same value by
combining them into the same schedule per the Company's proposal. Please
provide workpapers supporting these options.
c. Please explain why it is reasonable for Schedule 401 customers to receive a 5.7
percent increase when the Company's COS Study shows Schedule 401 has a Rate
of Return Index of 0.76.
d. Please provide a COS study that combines Schedule 401 and Schedule 9.
REQUEST NO. 212: In Company witness Meredith's testimony, page26, he states
"[t]he Company estimates that bills would rise on average by 13 percent for Schedule l9
customers when they are moved into Schedule 23." Please respond to the following:
a. Please explain why it is reasonable for Schedule 19 to receive a 13 percent
increase when all other rate schedules are limited to ten percent and the
Company's COS Study shows Schedule 19 has a Rate of Return Index of 1.09.
b. Please provide a comparison of the load shape and load factor from the last three
years for the Schedule 19 rate class and the Schedule23 rate class.
c. Please explain why it is reasonable for Schedule 19 to be moved into Schedule 23
based on any differences in load factors and load shapes of the two classes.
d. Please provide rate design options that would limit the overall increase to
Schedule 19 customers when combined with Schedule 23. Please provide
workpapers supporting these options.
e. Please provide a COS study that combines Schedule 19 and Schedule 23.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 2I , 2O2I
DATED at Boise, Idaho, *r, 2f Uay of Septemb er 2021.
Dayn
DepW
i:umiscprodrcq/paceOl.Tdhmhjt prod req 9
NINTH PRODUCTION REQUEST
TO ROCKY MOt]NTAIN POWER 5
General
SEPTEMBER 2I, 2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING NINTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWE& IN CASE NO. PAC-E-21-07, By E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : [e-mail]
idahodockets@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pac i fi corp.com
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #I4O
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
mbrubaker@,c on su ltbai. co m
LANCE KAUFMAN
AEGIS INSIGHT
E-MAIL : [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL : emi ly.wegener@paciflcorp. col11
matthew.mcvee@paci tjcorp.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX l39l
POCATELLO ID 83204
E-MAIL: [e-mail]
[e-mail]
JAMES R SMITH
MIKE VEILE
BAYER CORPORATION
E-MAIL: jim.r.smith(@icloud.com
mike.vei .com
KEVIN HIGGINS
COURTNEY HIGGINS
MILLI PICHARO
NEAL TOWNSEND
ENERGY STRATEGIES
E-MAIL: khiggins@energ),strat.com
chieeins@energy strat. com
mpichardo@.energ),strat.com
ntownsend@energ)rstrat. com
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: val..com
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N ITTH ST
BOISE ID 83702
E-MAIL: [e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL : [e-mail]
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-MAIL : [e-mail]
S
CERTIFICATE OF SERVICE