20210923PAC to Bayer 111-130.pdf

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ROCKY MOUNTAIN
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
September 23,2021
Randall C. Budge/Bayer randv@.racineolson.com (C)
Thomas J. Budge/Bayer ti @racineol son. com (WXC)
Brian C. Collins/Bayer bco I I [e-mail] (WXC)
Maurice Brubaker/Bayer mbrubaker@consu ltba i. com (C)
Kevin HigginsiBayer [e-mail] (C)
Lance KaufinanlBayer lance@aesisinsi eht. com (C)
James R. Smith/Bayer i im.r. smith@ic loud.com (C)
Mike Veile lBayer [e-mail]
Courfrrey Higgins/Bayer chissins@enerqy strat. com
Milli Picharo lBayer mpichardo@enerev strat.com
Neal Townsend/Bayer [e-mail]
RE: ID PAC-E-21-07
Bayer Set 1Oft (l I l-130)
Please find enclosed Rocky Mountain Power's Responses to Bayer lOs Set Data Requests 124,
128, and 130.
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 [e-mail]
Adam GardneriPIIC A Gardner@idahoan. com (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Ben Otto/lCL [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC brmu I I ins@mwanal),t ics. com
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Srciner/PIIC val.steiner@.itafos.com (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
September 23,2021
Bayer Data Request 124
Bayer Data Requestl24
Plant Additions. Please refer to Exhibit No. 40 Page 8.5.2.
(a) Please provide all work papers used to allocate or assign expenses and
revenues for the Lloyd center between utility and non-utility.
(b) Please provide budgeted and actual expenses and revenues for the Lloyd
center by month and account from January 2018 to December 2021.
(c) Please explain why the C7 Data Center Load Increase project is not directly
assigned to the associated customer or jurisdiction.
(d) Has PacifiCorp adjusted test year expenses to account for AMI infrastructure
labor reductions? If no, why not?
Response to Bayer Data Requestl24
(a) The Company assumes that "Lloyd Center" refers to the corporate
headquarters of PacifiCorp, the Lloyd Center Tower (LCT) open office. The
plant function is general plant and is allocated using the system overhead (SO)
allocation factor per the 2020 Protocol Methodology. There are no general
plant costs that are allocated non-utility.
(b) Please refer to Confidential AttachmentBayer 124
(c) Please refer to PIIC Data Request 34.
(d) No, while meter reading expense savings are expected from the Idaho
Advanced Metering Infrasfucture (AMI) program, no meter reading savings
are expected for 2021. Meter reading savings are projected to begin n 2022.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,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: Scott Liedtke I Craig Larsen
Sponsor: Steve McDougal
PAC-E'21-07 / Rocky Mountain Power
September 23,2021
Bayer Data Request 128
Bayer Data Request 128
Expenses. Please provide fransaction details for nonJabor costs recorded FERC
accounts n2020. Please include:
(a) Total amount charged.
(b) Assignments and allocations to Utility/non-utility.
(c) Assignments and allocations to Idaho.
(d) Description of cost.
(e) Business unit charged.
(D All other transaction detail generally maintained.
(g) Please include a table describing each code, account, or subaccount used.
Response to Bayer Data Request 128
The Company objects to this request because it is overly broad and unduly
burdensome. Subject to and without waiving its objection, the Company responds
as follows:
Please refer to the Exhibit No. 40, tab *B'2. O&M Expense", pages I through 12,
which details expenses by FERC Account, and FERC subaccount from 500 to
935.
Recordholder:Catherine Docekal lCraig Stelter
Steven R, McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
September 23,2021
Bayer Data Request 130
Bayer Data Request 130
Transmission. Does the Company attach sub-hansmission and tansmission
conductors to the same poles or towers for any portion of the transmission
system? If yes, please explain how the cost of such poles and towers are allocated
between plant accounts. If nq why not?
Response to Bayer Data Request 130
Yes. When a disfribution line is attached to transmission sffuctures, it is referred
to as a disfribution underbuild. The conductor (wire) and attaching hardware is
capitalized as a distibution plant. The structure (tower or pole) is reported as
transmission. The upper conductors, insulators, etc. are also transmission plant.
ln the case of a distibution underbuild, the pole/tower is classified as
transmission because that is its main function with disfibution conductor as a
secondary attachment. There is no provision within the Federal Energy
Regulatory Commission (FERC) code of federal regulations (CFR) to split the
same asset between more than one plant account.
Recordholder: Adam Lint / Rob Schroeder
Sponsor:To Be Determined