20211005PAC to Staff 200-212-Redacted.pdf

Y ROCKY MOUNTAIN
POWER
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October 5,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.norivuki@nuc. idaho. eov (C)
RE:ID PAC.E.ZI.O7
IPUC Set 9 (200-213)
Please find enclosed Rocky Mountain Power's Responses to IPUC 9m Set Data Requests 200-
213. Also provided are Attachments IPUC 203,204,207,21I {l-3), and2l2 {l-3). Provided
via BOX is Confidential Attachment IPUC 208 and Confidential Responses IPUC 206 and209.
Confidential information is provided subject to protected under IDAPA 3 I .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 any subsequent Non-Disclosure Agreement
(NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
---!sl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PIIC ron@,williamsbradbury.com
Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/PIIC AGardner@,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)
Randall C. Budge/Bayer randy @rac ineo lson. com (C)
Thomas J. Budge/Bayer ti @rac ineolson. com (WXC)
Brian C. CollinJBayer bcol I ins@consultbai. com (WXC)
Maurice Brubaker/Bayer mbru baker@.con su ltba i. com (C)
Kevin Higgins/Bayer kh [e-mail] (C)
Lance Kaufman/Bayer lance@aee i sin si sht. com (C)
James R. Smith/Bayer i im.r. sm ith(Oic loud.com (C)
Brad Purdy [e-mail] (C)
Ben Otto/[CL botto@idahocon servation. ore (C)
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Request 200
IPUC Data Request 200
Please provide the ldaho 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.
Response to IPUC Data Request 200
PacifiCorp objects to this request as overly burdensome and requiring the creation
of a new analysis that is beyond the scope of discovery in this proceeding.
Notwithstanding the foregoing objection, the Company responds as follows:
The Company has not performed the requested calculation. To provide the
requested information or restate any adjusfrnents prepared in this case on the
requested methodology would require gathering additional information. The test
period in this general rate case (GRC) has been prepared in a manner that is
consistent with the Company's prior Idaho general rate case proceedings, which
the ldaho Commission has approved. Notably, the use of an end-of-period
calendar year 2021test period ensures that costs associated with capital
invesfinent is used in useful and properly aligned with customer rates beginning
with the January 1,2022 rate effective date proposed in this proceeding.
Recordholder: Craig Larsen
Sponsor: Steve McDougal
PAC-E-2147 /Rttcky Mountain Power
October 5,2021
IPUC DafaRequest 201
IPUC Data Request 201
Please provide the Company's additional plant in service adjusrnents (8.5, 6.1,
6.2, stu.) using the Average Monthly Average method.
Response to IPUC Data Request 201
Please refer to the Company's response to IPUC 200.
Recordholder: Craig Larsen
Sponsor: Steve McDougal
PAC-E-21-07 / Rooky Mountain Power
October 5,2021
IPUC DataRequer"20z
IPUC Dete Requst?tr2
Please provide documentation of the amounts of the Company's cash working
capital provided by shareholderc.
Recponse to IPUC Data Request 202
Please refer to the Company's reqponse to Data Request IPUC 66.
Recordholder: Craig Larsen
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC DafaRequest203
IPUC Data Request 203
Please provide a sohedule showing the amount of capital invesilnents for the year
ending December 31,2021. Please break these out by month to show these
invesfrnents by each account number and fie amounts allocated to lddro.
Response to IPUC Dah Request 203
The Company assumes that capital invesfinents mealr actral plant additions.
Please refer to Attachment IPUC 203 for actral 2021 monthly plant additions
from January to August.
Recordholder: Craig Larsen
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Itdountain Power
October,zWl
IPUC DataReque$z04
IPUC Date Roquest 204
Please provide monthly depreciation expen$e by accormt and all plant rotiremens
for each month during 2021. Please break trese out by account number and Idaho
allocation.
Rerponse to IPUC lleta Request 2M
For monthly depreciation expense please refer to the Company's response to
Bayer 96. The Company assumes that plant retirements meen astual plant
retirements. Please referto Attachment IP-UC 204for acural 2021plantretirement
data from January to August
Recordholder: Craig Larsen
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Request 205
IPUC Data Request 205
For each rate base component please provide the month-end balances for each
month from December 2019 to present.
Response to IPUC Data Request 205
PacifiCorp objects to this request as overly burdensome. Due to the volume of
data requested, completion of the request on a monthly basis would require a
significant amount of time and resources to complete. Subject to and without
waiving this objection, the Company responds as follows:
Please refer to Attachment Bayer 96 which provides the Company's ldaho Results
of Operations (ROO) that have been filed with the Idaho Public Utilities
Commission (IPUC) for 2014 through 2019. Details of total-Company and ldaho
allocation rate base components by FERC Account and subaccount are available
in the below "B-Tabs" within each report referenced below:
B8 -EPIS
89 - Capital Lease
B l0 - Plant Held for Future Use
Bll -DeferredDebits
Bl3 -Materials & Supplies
Bl4 - Cash Working Capital
Bl5 - Miscellaneous Rate Base
816 -Regulatory Assets
Bl7 -Depreciation Reserve
B I 8 - Amortiz-ation Reserve
Bl9 -Defened lncome Tax Balance
B 19 - Investnent Tax Credit Balance
B.20 - Customer Advances
The 2020 ROO were provided as Exhibit No. 40 to Steven R. McDougal's
testimony. The202l Idaho ROO will become available for review on or around
Apil30,2AL
Recordholder: Craig Larsen
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Request 206
IPUC Data Request 206
Please provide the number of persons who left employment at PacifiCorp for
years 20 I 8-202 I . For each instance indicate if the departure was voluntary,
involuntary, or retirement.
Response to IPUC Data Request 206
The counts below are for employees who terminated from active full-time or part-
time employment from 2018 - September202l. This data excludes employees
who transitioned from active employment to long-term disability, as well as
employees who work at the mine.
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 the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Shelley Zoller
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC DataRequest20T
IPUC Data Rqust207
Regarding the Company's response to Production RequestNo.2, please provide a
list of all tansactions booked n2020 that were allocated or directly assigned to
the Company's ldaho jurisdiction for FERC Account 921. Please include date,
total system amount, Idaho allocakd amount and any other identiffing
information.
Response to IPUC Data Request 207
Please refer to Attachment IPUC 207
Recordholder:Craig Stelter
Steven McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Request 208
IPUC Data Request 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.
Response to IPUC Data Request 208
Please see Confidential Attachment IPUC 208.
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 the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Dana Connors
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Requestz0g
IPUC Data Rquest 209
Please provide the average annual rate of employee turnover at the Company for
the years 2018 throughzDzl year-to-date.
Response to IPUC Data Request 209
The rates below are for employees who terminated from active full-time or part-
time employment from 2018 - September 2021. This data excludes employees
who tansitioned from active employment to long-term disability, as well as
employees who work at the mine.
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 - lnformation Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Shelley Zoller
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Request 210
IPUC Data Request 210
In reference to ttre tabs "Demand Factors," "Dist. Factors," and
"Energy Factors" in Company witness Meredith's work paper "COS ID 2021" that
was provided with the Application, please respond to the following:
(a) Why Contact 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.
Response to IPUC Data Request 210
(a) The billing cycle for Contract 2 changed such that an invoice was not
produced for the October 2019 accounting month. No energy was therefore
posted for the month of October for Contract 2. Demand measurements
which are scaled to monthly energy were consequently set at zero as well.
(b) The Company does not believe that having zero values for October for
Contract 2 is problematic for its cost of service results, since demand, energy,
and revenue are all less in tandem.
(c) The data for all three tabs comes from the *2020 Adjusted Load Research"
workpaper filed with Mr. Meredith's testimony. The study was conducted for
calendar year 2019 and adjusted to the overall difference in Idaho energy sales
between calendar year 2020 and2019. The data on the "Demand Factors" tab
comes from the "MERGED" tab, dataon the "Dist. Factors" tab comes from
the "Dist" and "NCP" tabs, and data for the "Energy Factors" tab comes from
the "MWH" tab.
(d) Please refer to the Company's response to subpart (c) of this request.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Request 2l I
IPUC Data Request 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.
(b) File "lD GRC Blocking 2020.x1sx" 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 work papers 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 Retum Index of 0.76.
(d) Please provide a COS study that combines Schedule 401 and Schedule 9.
Response to IPUC Data Request 211
(a) Please refer to Attachment IPUC 2ll-1. While the load factors for Schedule
9 and Schedule 401 are different, both classes have higher load factors than
smaller customer classes like residential, inigation, and Schedule 23. More
importantly, they share the characteristic of being served at a higher
transmission voltage level.
(b) One rate design option to bring the price changes closer together for Schedule
401 and Schedule 9 is to decrease the power charge and increase the enerry
charge. Please refer to Attachment IPUC 2ll-2 where the summer power
charge for Schedule 9 on the 'Exhibit No 45 - Billing Det' tab was set to
$6.93 which results in the same percentage increase for both classes.
(c) The lower increase for Schedule 401 is a result of the Company's proposed
rate design for the consolidated Schedule 9 class under which power charges
were given a higher increase than energy charges. As described in subpart b
to this request, a higher percentage increase for Schedule 401 could be
achieved by decreasing power charges and increasing energy charges.
(d) The Company 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. Notwithstanding the foregoing objection, the Company
responds as follows:
PAC-E, l-07 I Rocky Mountain Power
October 5,2021
IPUC DataRequest 2ll
Recordholder: James Zhang
Sponsor: Robert Meredittt
Please refer to Attachment IPUC 2ll-3 which provides a consolidated cost of
service summary table for both classes that shows whatthe Company believes
would be a very similar result to a qpecific cost of seryice study wtrere both
classes are combined.
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC DataRequest2l2
IPUC Data Request 212
ln Company witness Meredith's testimony, page26, he states "[t]he Company
estimates that bills would rise on average by 13 percent for Schedule 19
customers when they are moved into Schedule23." 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 l9 has a Rate of Retum Index of 1.09.
(b) Please provide a comparison of the load shape and load factor from the last
three years forthe Schedule 19 rate class andthe Schedule 23 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
work papers supporting these options.
(e) Please provide a COS study that combines Schedule 19 and Schedule 23
Response to IPUC Data Request2l2
(a) Schedule 19 is a relatively small class with about 84 customers whose rate
structure is very similar to that of Schedule 23. Presently, the major
difference in rate structure between these two classes is the higher basic
charge and larger summer to winter differential for seasonal energy charges
for Schedule 19. While the cost of service study does specifically examine
seasonality, the Company did compare seasonal differences in winter versus
summer EIM pricing to inform its proposed rate design in this case. The
higher increase for Schedule 19 is largely a result of the proposed rate design
for a consolidated Schedule 23 that has a smaller summer to winter energy
price differential.
(b) Please refer to Attachment 212-1. The Company only prepared load research
for Schedule23 and Schedule 19 for calendar years 2019 and2020. Load
research for Schedule 23 and Schedule 19 for calendar year2018 is not
readily available.
(c) It is reasonable, because both have mid-range load factors and have very
similar rate stuctures. Further Schedule 19 is closed to new service and new
commercial and industial space heating customers do not have the option of
going onto Schedule 19, but would need to go onto Schedule 23. Given the
PAC-E-21-07 / Rocky Mountain Power
October 5,2021
IPUC Data Request2l2
similarities, there is no compelling reason to continue to have Schedule l9
customers pay different rates than customers on Schedule 23.
(d) Rate design options to mitigate the increase for Schedule 19 include
increasing the summer to winter energy price differential and the basic charge
for the consolidated class. Please refer to Attachment IPUC 212-2 where dre
seasonal energy price differential for Schedule 23 was set 130 percent and the
basic charge was set to $20 on the 'Exhibit No 45 - Billing Det' tab on cells
M697 and H687 for examples of rate design changes that can mitigate the
impact to Schedule 19 customers.
(e) The Company 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. Notwithstanding ttre foregoing objection, the Company
responds as follows:
Please refer to Attachment IPUC 212-3 which provides a consolidated cost of
service summary table for both classes that shows what the Company believes
would be a very similar result to a specific cost of service study where both
classes are combined.
Recordholder:James Zhang
Robert MeredithSponsor: