20211007PAC to Bayer 140-151.pdf

Salt Lake City, Utah 84116
October 7, 2021
Randall C. Budge/Bayer [e-mail] (C) Thomas J. Budge/Bayer [e-mail] (W)(C) Brian C. Collins/Bayer [e-mail] (W)(C)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer [e-mail] (C) Lance Kaufman/Bayer [e-mail] (C) James R. Smith/Bayer [e-mail] (C)
Mike Veile/Bayer [e-mail] Courtney Higgins/Bayer [e-mail] Milli Picharo/Bayer [e-mail] Neal Townsend/Bayer [e-mail]
RE: ID PAC-E-21-07
Bayer Set 14th (140-151)
Please find enclosed Rocky Mountain Power’s Responses to Bayer 14th Set Data Requests 140-142, 148-149, and 151. The remaining responses will be provided separately. Also provided via e-mail or BOX are the non-confidential Attachments. Provided via BOX is Confidential Attachment Bayer 151-3. 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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____ J.Ted WestonManager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail] Adam Gardner/PIIC [e-mail] (W) Kyle Williams/PIIC [e-mail] (W) Val Steiner/PIIC [e-mail] (W) Eric L. Olsen/IIPA [e-mail] (C)
RECEIVED
2021 OCT -7 PM 5:00
IDAHO PUBLIC
UTILITIES COMMISSION
Anthony Yankel/IIPA [e-mail] (C) Ben Otto/ICL [e-mail] (C) Ronald L. Williams/PIIC [e-mail] Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/PIIC [e-mail] (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) Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power October 7, 2021 Bayer Data Request 140
Bayer Data Request 140 Wildfire Costs. Please provide all court documents related to litigation involving RMP, an RMP affiliate, and the Archie Creek fire. Please include all discovery
provided by RMP or an RMP affiliate. Please include all complaints, motions,
briefs, and orders. Response to Bayer Data Request 140

The Company objects to this request as overly broad, unduly burdensome, outside the scope of this proceeding, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, the Company responds as follows:
Please refer to Attachment Bayer 140.
Recordholder: Frank Grey

Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power October 7, 2021 Bayer Data Request 141
Bayer Data Request 141 Wildfire Costs. Please provide all court documents related to litigation involving RMP, an RMP affiliate, and the Slater or Happy Camp fire. Please include all
discovery provided by RMP or an RMP affiliate. Please include all complaints,
motions, briefs, and orders. Response to Bayer Data Request 141

The Company objects to this request as overly broad, unduly burdensome, outside the scope of this proceeding, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, the Company responds as follows:
Please refer to Attachment Bayer 141.
Recordholder: Frank Grey
Sponsor: Steve McDougal

PAC-E-21-07 / Rocky Mountain Power October 7, 2021 Bayer Data Request 142
Bayer Data Request 142 Wildfire Costs. Please provide all court documents related to litigation involving RMP, an RMP affiliate, and the Beachie Creek fire. Please include all discovery
provided by RMP or an RMP affiliate. Please include all complaints, motions,
briefs, and orders. Response to Bayer Data Request 142

The Company objects to this request as overly broad, unduly burdensome, outside the scope of this proceeding, and not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, the Company responds as follows:
Please refer to Attachment Bayer 142.
Recordholder: Frank Grey
Sponsor: Steve McDougal

PAC-E-21-07 / Rocky Mountain Power October 7, 2021 Bayer Data Request 148
Bayer Data Request 148 Wildfire Costs. Please provide the total operating expense for vegetation management by state and year from 2010 to present.
Response to Bayer Data Request 148 PacifiCorp objects to this request as outside the scope of this proceeding and not
reasonably calculated to lead to the discovery of admissible evidence. Without
waiving this objection, the Company responds as follows: Please refer to Attachment Bayer 148 which provides the total operating expense for vegetation management by state and year from 2010 to present.

Recordholder: Jeff Vickers / Scott Liedtke Sponsor: To Be Determined

PAC-E-21-07 / Rocky Mountain Power October 7, 2021 Bayer Data Request 149
Bayer Data Request 149 Wildfire Costs. Please provide the total distribution and transmission line miles, separately, by state and year from 2010 to present.
Response to Bayer Data Request 149 Please refer to Attachment Bayer 149. Note: distribution mileage information is
available from 2012, and transmission line miles information is available from
2014. Recordholder: Yuichiro Miyata
Sponsor: Rick Vail

PAC-E-21-07 / Rocky Mountain Power October 7, 2021 Bayer Data Request 151
Bayer Data Request 151 Deer Creek. Please refer to the work paper “8.14 - Deer Creek Mine.xlsx”.
(a) Please provide the total amount collected through the Idaho ECAM related to
Deer Creek from January 1, 2016 to present. (b) Please provide work papers demonstrating how RMP accounted for the capital
costs associated with the Deer Creek unrecovered investment.
(c) Please provide all work papers and discovery related to Deer Creek filed under Docket No PAC-E-15-09. Response to Bayer Data Request 151

(a) Please refer to Attachment Bayer 151-1 which provides the total amount collected through the Idaho energy cost adjustment mechanism (ECAM) related to Deer Creek from January 1, 2016 to November 2018.

(b) Please refer to Exhibit No. 40, page 8.14.2 for details of capital costs associated with Deer Creek unrecovered investment. Per Case No. PAC-E-14-10, the unrecovered plant balance was set up as a regulatory asset and fully amortized by November 2018. The Company is including all other mine closure costs and savings that have been deferred in this general rate case
(GRC) and proposing to amortize all deferred balances resulting from the
mine closure in rate base to be amortized over three years. Please refer to the direct testimony of Company witness, Steven R. McDougal, page 42 line 9 to page 43, line 9 for a detailed discussion on the Company’s proposed treatment
of Deer Creek balances in this GRC.
(c) PacifiCorp objects to this request as overly broad, outside the scope of this proceeding and not reasonably calculated to lead to the discovery of admissible information. Without waiving this objection, the Company responds as follows:

Please refer to Attachment Bayer 151-2 and Confidential Attachment Bayer 151-3. 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.

PAC-E-21-07 / Rocky Mountain Power October 7, 2021 Bayer Data Request 151
Recordholder: Justin Waterman / Dan Martinez Sponsor: Steve McDougal