20211004PAC to Bayer 136-139.pdf

.-".;r'=lliEfl-.;-';t7LV
;::; i:tT *tl PFl 5: OiiYROCKY MOUNTAIN
BP,:ly,E*"R"."
Salt Lake City, Utah 84116
October 4,2021
Randall C. Budge/Bayer randv@rac ineolson. com (C)
Thomas J. Budge/Bayer ti (Erac ineol son. com (WXC)
Brian C. Collins/Bayer bcol I in s@consu ltbai.com (WXC)
Maurice Brubaker/Bayer mbru baker@con su ltba i. com (C)
Kevin Higgins/Bayer [e-mail] (C)
Lance Kaufman/Bayer I an ce @ae e i sin s i eht. c om (C)
James R. Smith/Bayer i im.r. smith@.ic loud. com (C)
Mike VeilelBayer m ike. vei [e-mail]
Courtrey Higgins/Bayer chissins@enersy strat. com
Mill i Picharo/Bayer mpich ardo @enersy strat.conr
Neal Townsend/Bayer [e-mail]
RE: ID PAC-E-21-07
Bayer Set 136 (136-139)
Please find enclosed Rocky Mountain Power's Responses to Bayer 13ft Set Data Requests 136
and 138-139. The response to Bayer 137 will be provided separately.
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 ron@wil I iam sbradburv. conr
Bradley G. Mullins/PIIC brmu I I ins@mwanalyt ics. com
Adam GardneriPIIC AGardner(D idahoan.com (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/tlPA [e-mail] (C)
Ben OttoflCL [e-mail] (C)
Ronald L. Williams/PIIC ron@wi lliamsbradbury.com
Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/PIIC A Gardn er@idahoan. com (w)
Kyle Williams/PlC [e-mail] (W)
Val Steiner/PIIC [e-mail] (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
October 4,2021
Bayer Data Request 136
Bayer Data Request 136
Request No. 135: Plant Retirements Regarding any 2Al plant retirements:
(a) Has RMP made any adjushnent to reflect 2021plant retirements (or some
portion thereof) in its filing?
(b) Please identiff the specific RMP adjusfrnents, if any, where any plant
retirement adjustments are included.
(c) Does RMP's proposed rate base incorporate all expected 2021plant
retirements? If no, please identift the202l retirements that are included and
explain the rationale for excluding the remaining 2021 retirements.
Response to Bayer Data Request 136
(a) The Company did not include any 2021forecast retirements. The Company's
test period did not update plant balances or depreciation expense for changes
lrr.2021other than for major plant additions and the depreciation study. For
retirements, the Company credits the asset and debits accumulated
depreciation for the same amount. Therefore, there is no impact on rate base
and retirements were not included.
(b) Please refer to the Company's response to subpart (a).
(c) Please refer to the Company's response to subpart (a).
Recordholder: Laura Miller
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 4,2021
Bayer Data Request 138
Bayer Data Request 138
Transmission Bad Debt In response to IPUC Data Request No. 123, RMP
provided detailed information supporting the transmission bad debt in 2019 &,
2020.For the transmission bad debt amount in2019 for the reserve for bad debt -
81 8212 (Assi gnment 8 I 8212) :
(a) Please explain the circumstances that resulted in the need to record the reserve
amount shown in the response.
(b) Please describe the process, if any, undertaken by RMP to resolve the disputed
amount shown in the response?
(c) Has there been a resolution to the disputed amount? If so, please describe tre
resolution and the related amount.
(d) If there is a process to resolve the disputed amount, does RMP adjust or
reverse the bad debt amount shown in the response?
(e) If there is a process to resolve the disputed amount, do customers receive a
revenue credit to offset the reserve for transmission bad debt shown in the
response? Please explain how any such revenue credit would be realized by
customers.
Response to Bayer Data Request 138
(a) PacifiCorp performed work to effectuate a customer interconnection request
which the customer disputes was approved to proceed. As a result of the
dispute, customer suspension, and upon evaluation a reserve was established
against the receivable balance.
(b) At present, given the interconnection rules, the project is on hold until 2023. If
the customer re-engages the project, those costs will be required to be
reimbursed by the customer and the reserve will be reversed.
(c) No resolution as customer has until 2023 to withdraw the project.
(d) Yes. If the customer elects to resume project construction, then the customer
will need to provide funds covering the outstanding amount due and the
reserve will be reversed.
(e) If the customer resumes the project, then the Company will reverse the reserve
as customer will be required to pay to resume ttre project. If the customer does
not resume the project then the Company will need to evaluate any remaining
options to collect.
PAC-E-21-07 / Rocky Mountain Power
October 4,2021
Bayer Data Request 138
Recordholder: Emie Knudsen
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
October 4,2021
Bayer Data Request 139
Bayer Data Request 139
Accumulated Deferred Income Taxes. On p. 5 of 350 (p. L3) of RMP wihress
Steven R. McDougal's Exhibit 40, Mr. McDougal provides Idaho's share
($144,690,910) of the unadjusted 2020 accumulated deferred income tax balance
in Col. (l). Please provide a2021forecast of accumulated defened income taxes
(both Total Company and Idaho allocated) that is not otherwise included in the
various RMP adjustments summarized on p. 6 of 350 (p. 1.4) of Exhibit 40.
Please provide this forecasted amount broken down by function (e.g. generation,
transmission, distribution, etc.). Please provide any workpapers supporting this
response in Excel format with formulas intact.
Response to Bayer Data Request 139
PacifiCorp objects to this request as overly broad, unduly burdensome, requiring
the creation of a new analysis that is beyond the scope of discovery in this
proceeding, and not reasonably calculated to lead to the discovery of admissible
evidence.
In addition, this forecast would be inconsistent with the test period used and with
plant additions and depreciation expense included in this proceeding. Without
waiving the foregoing objection, the Company responds as follows:
Please refer to page 160 of Exhibit No. 40, Major Plant Additions, the
accumulated deferred income taxes (ADIT) were aligned with the plant additions
included in this proceeding.
Recordholder:Steve McDougal
Steve McDougalSponsor: