20211013PAC to Bayer 151-232.pdf

ROCKY MOUNTAIN
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Salt Lake City, Utah 84116
October 12,2021
Randall C. Budge/Bayer [e-mail] (C)
Thomas J. Budge/Bayer tj @rac ineol son. com (WXC)
Brian C. Collins/Bayer bcol I in s@con sul tbai. com (WXC)
Maurice Brubaker/Bayer [e-mail] (C)
Kevin Higgins/Bayer khi g gins@enersystrat. com (C)
Lance Kaufman/B ayer lan ce @.aee isins isht. com (C)
James R. Smith/Bayer i im. r. smith@ic loud.com (C)
Mike Veile lBayer mike. [e-mail]
Courtney Higgins/Bayer chi ggins@enersvstrat. com
Milli Picharo lBay er [e-mail]
Neal Townsend/Bayer ntownsen d@ enersvstrat. conr
RE: ID PAC-E-21-07
Bayer Set l5m (l5l-232)
Please find enclosed Rocky Mountain Power's Responses to Bayer 15ft Set Data Requests 156,
160-161, 163,166-170,172-173,175-176,178, 180, 183-184, 186-19l, lg3-194,196.201,204-
206,210,214,217-221, and 227431. The remaining responses will be provided separately.
Also provided via e-mail are the non-confidential Attachments. Provided via encryption and
BOX is Confidential Attachments and Responses. 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.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-!sl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Ronald L. Williams/PIIC ron @w i I I iamsbradbury. com
Bradley G. Mullins/PIIC brmu I I in s@mwanalytics. com
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. steiner@. itafos.com (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA [e-mail] (C)
Ronald L. Williams/PIIC ron@.williamsbradburv.com
Bradley G. Mullins/PIIC brmull ins@mwanalwics. com
Adam Gardner/PlC [e-mail] (W)
Kyle Williams/PtrC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Eric L. OlsenflIPA [e-mail] (C)
Anthony YankeylPA [e-mail] (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
BayerDataRequest 156
Bayer Data Request 156
Rate Base. Please refer to the PacifiCorp 2021 IRP
(a) Please refer to sheet "PAGE 8.3.1 detaiP' row 12 Deferred Long Wall Costs.
Please explain what costs are included in deferred long wall costs.
(b) Please refer to sheet "PAGE 8.3.1 detail" row 12 Deferred Long Wall Costs.
Please identiff any applications for deferral of these costs with the Idaho
Public Utilities Commission. If no application was made why is PacifiCorp
requesting these costs be included in rate base?
Please refer to sheet "PAGE 8.3.1 detail" row 12 Deferred Long
Response to Bayer Data Request 156
The Company was not able to respond to this question as it was incomplete. The
pages referred to information not in the PacifiCorp 2021IRP. Assuming the
question refers to the same questions in Bayer Data Request 155, the Company
responds as follows:
Please refer to the Company's response to Bayer Data Request 155, specifically
subparts (a) and (b).
Recordholder:Dan Martinez
Sponsor:Not Applicable
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 160
Bayer Data Request 160
COVID Costs. Please refer to RMP's response to Bayer DR 98.
(a) Please provide all work papers and analysis supporting the estimated
$7,000,000 cost reductions.
(b) For each component ofthe cost reduction, please provide RMP's cost by
month from January 2019to present.
(c) Please provide the amount that RMP has incurred in202l to tansition
employees to work from home.
(d) Please provide the amount that RMP has incurred lri.2021to accommodate
social distancing.
(e) Please provide the amount that RMP has incurred lri'2021to accommodate
enhanced sanitation measures.
Response to Bayer Data Request 160
(a) Please refer to Attachment Bayer 160.
(b) Please refer to Attachment Bayer 160.
(c) The Company has not incurred any costs :rl.2021to transition employees to
work from home.
(d) The Company has not incurred any costs in202l to accommodate social
distancing.
(e) The Company has incurred $537,074.89 tn202l to accommodate enhanced
sanitation measures.
Recordholder:Heather Loechle
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
BayerDataRequest 16l
Bayer Data Request 161
COVID Costs. Please refer to RMP's response to PIIC DR 81. Please provide the
number of RMP employees participating in the Voluntary Work from Home
program by month from March 2020 to present.
Response to Bayer Data Request 161
Please refer to the table below for the counts for Rocky Mountain Power (RI\P)
employees. The Company's work from home (WFH) program began in June
2020.
Recordholder: Leslie Chase
Sponsor:Julie Lewis
Jun-20 I
Jul-20 I
Aue-20 I
Sep-20 5
Oct-20 5
Nov-20 5
Dec-20 5
Jan-21 6
Feb'21 6
Mar-21 7
Apr-21 l0
May-21 l0
Jun-21 74
Jul-21 76
Aue-21 82
Sep-.21 84
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 163
Bayer Data Request 163
Pryor Mountain. Please refer to the Direct Testimony of Robert Van
Engelenhoven at page 5.
(a) Do any reshictions exist that prevented RMP from selling RECs to Vitesse
from another EY 2020 or repowering project? If yes, please identiff all such
restrictions.
(b) Please provide the results of the Oregon Schedule 272 from 2018 to present.
Please include the original RFP, responses, and all scoring, evaluation, and
selection documents.
Response to Bayer Data Request 163
(a) Yes. The Oregon Schedule 2T2renewable energy certificate (REC) purchase
agreement executed between PacifrCorp and Vitesse, LLC dated June 27,
2019 is for the sale of all renewable energy credits (REC) generated from the
Pryor Mountain wind project. Other RECs, or comparable RECs, cannot be
used to meet the terms and conditions of the Oregon Schedule 272REC
purchase agreement in place of Pryor Mountain wind RECs.
(b) The Company 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:
It is unclear to PacifiCorp what "results of the Oregon Schedule 272 from
2018 to present" is intended to be requesting. Notwithstanding the foregoing
statement, the Company advises as follows:
The Oregon Schedule 272P.EC purchase agreement referenced in the direct
testimony of Robert Van Engelenhoven, page 5, was not executed as a result
of a request for proposals (RFP) issuance.
Recordholder: Paul Johnson
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 166
Bayer Data Request 166
Pryor Mountain. Please refer to the McDougal work paper "Attach IPUC 126
CONF.xlsx".
(a) Please refer to Column C assessed value as of January 1,2020. Are the
assessed values for Montana based on 2019 property values?
(b) Please also refer to Exhibit No. 42 Page 2 of 3. Please provide a detailed
explanation of the basis for the Pryor Mountain Tax Savings. Please include
documentation of the favorable county level abatements.
(c) Please refer to Column P. Please provide the basis for the change in Pryor
Mountain Tax savings from 2022to2024.
(d) Please refer to cell Pl6. Please provide the file referenced in this cell.
(e) Please refer to cell P52. Please provide the file referenced in this cell.
(f1 Please refer to cell D49. Please provide a version of this workpaper with the
original reference intact.
(g) Please refer to row 52. Please provide the amount of 2022 estimated net
property tax due to Pryor Mountain and associated facilities including
transmission.
Response to Bayer Data Request 166
(a) The assessed value for Montana for January 1,2020 is based on the Montana
Department of Revenue's @OR) January 1,2020 assessment.
(b) The property tax benefit related to the Pryor Mountain wind project results
from the following two Montana statutory provisions:
Under 15-6-157, Montana Code Annotated (MCA), the assessed value of
wind generation property is set equal to 3 percent of its market value.
This compares to the 6 percent of market value assessment ratio that
applies to other electric generation property under l5-6-156, MCA.
2. Under 15-24-1402, MCA, counties may by resolution provide certain
taxpayers with a reduction in property tax rates of either 50 percent or 75
percent. For the Pryor Mountain wind project, Carbon County agreed to a
75 percent reduction in tax rates for the frst five years of the project's
useful life. The benefit is reduced to 60 percent in year six, 45 percent in
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 166
yearseven,30percent in yeareight, l5 percent in yearnine, and 0 percent
in year 10.
Please refer to Attachment Bayer 166-l which provides a copy of the Tax
Abatement Resolution pertaining to the Pryor Mountain wind project and
Attachment Bayer 166-2 which provides a copy of the New or Expanding
Industry Classifi cation Application.
(c) When estimating the annual property tax savings for 2021 for the Pryor
Mountain wind project, assessment class specific values from the Montana
DOR 2021 assessment work papers were used. The no longer valid estimated
benefit for 2022 through 2024 relied on the net book value (NBV) of the
project. The final tax benefit amounts for 2022 through 2024 will be reflected
in2022 through 2024Montana DOR assessments.
(d) Please refer to Attachment Bayer 166-3, specifically cell C55.
(e) Referencing the Company's response to IPUC Data Request 126, specifically
Confidential Attachment IPUC 126, cell P52 contained a no longer valid
estimate of the Pryor Mountain property tax benefit. Please refer to
Attachment Bayer 166-3, cell D55 for an updated estimate of the 2022
property tax benefit that is based on 2021 assessed value information.
(f1 Please refer to Confidential AttachmentBayer 1664
(g) Please refer to Attachment Bayer 166-3, specifically cellD27. The $1,030,000
in this cell is an updated estimate of 2022 property tax associated with the
Pryor Mountain wind project and associated transmission investment.
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:Norm Ross
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 167
Bayer Data Request 167
In reference to the response to Bayer Data Request 36, please provide the average
level of full time employees by group of employees identified in the response
flBEW 125, IBEW 659, etc.) for each of the five years (2016-2020).
Response to Bayer Data Request 167
Please refer to the table below which provides the counts of full-time employees,
excluding mining, and does also not include the small number of supervisory
employees who may be eligible for overtime. The counts provided in the
Company's response to Bayer Data Request 36 included all employee groups, not
just full-time.
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 167
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 167
Recordholder:
Sponsor:
Shelley Zoller
Julie Lewis
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
BayerDataRequest 168
Bayer Data Request 168
In reference to confidential response to Bayer Data Request 35, please provide a
detailed explanation for the level of overtime hours incurred ln.2020. Did flre
pandemic have any effect on the level of 2020 overtime hours? Please explain in
detail.
Response to Bayer Data Request 168
The level of overtime hours that the Company has incurred is largely attributable
to the extreme weather events that occuned in the Company's service tenitory
during 2020. The Company does not tack overtime hours related to the COVID-
l9 pandemic.
Recordholder:Craig Stelter
Steven McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
BayerDataRequest 169
Bayer Data Request 169
In reference to the levels of overtime listed in confidential Bayer Data Request 35,
please provide the level of overtime hours that match the employee group who
incurred tlre overtime charged for each of the five years Q0l6-2020}
Response to Bayer Data Request 169
Please refer to Confidential Attachment Bayer 169 which provides a breakout of
PacifiCorp's overtime hours by employee group for calendar years 2016 through
2020.
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:Craig Stelter and David Cumow
Steven McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 170
Bayer Data Request 170
In reference to the response to Bayer Data Request 40, please reconcile the
amount of unused leave expense balance for 2020listed in the data request to the
amount included in the PacifiCorp cost of service ($5,191,972).
Response to Bayer Data Request 170
The difference between the December 31,2020 unused leave expense accrual of
$2.588 million in the Company's response to Bayer Data Request 40, and the
$5.192 million referenced above is $2.604 million. This amount represents the
calendar year 2020 unused leave expense payout.
Recordholder:Craig Stelter
Steven McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 172
Bayer Data RequestlT2
In reference to the Company work paper page number 4.2.3, please indicate if the
labor adjus0nent in that work paper reflects all RMP employees being
compensated for 2080 hours ofwork (full-time hourly employees) or an annual
salary? If the answer is no, please provide a detailed explanation for ttre response.
Response to Bayer Data RequestlT2
No. Page 4.2.3 does not represent each individual employee being compensated
for 2,080 hours or salary. Page 4.2.3 includes all base wages paid to employees by
month which includes full-time and part-time employees, as well as employees
who work a partial year due to being newly hired or separation from the Company
which occurs throughout the year.
Recordholder:Craig Stelter
Steven McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October l2,2A2l
Bayer Data Request 173
Bayer Data Request 173
In reference to confidential response to Bayer Data Request 41, does that response
include the complete description of PacifiCorp's Annual lncentive Plan (AIP)? If
not, please provide a complete copy of the AIP.
Response to Bayer Data Request 173
Please refer to Confidential Attachment Bayer 173 which provides the summary
of PacifiCorp's Annual Incentive Plan (AIP).
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:Julie Lewis
Sponsor:Julie Lewis
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 175
Bayer Data Request 175
Are awards/bonuses included in RMP salary surveys as part of the total
compensation paid to employees? [f so, how does RMP estimate the amount to be
included?
Response to Bayer Data Request 175
Yes, incentive percentages are included in ttre market pricing used to establish the
grades for PacifiCorp jobs. The Company benchmarks to the 50th percentile, then
places the job into the appropriate grade range and uses ttre target incentive
percent found in the market pricing and assigns it to ttre job.
Recordholder: Julie Lewis
Sponsor:Julie Lewis
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 176
Bayer Data Request 176
ln reference to the response to Bayer Data Request 43, please provide all
documentation that lists the specific reasons or actions why performance awards
were given for 2020. Please provide a breakdown by employee and amount
awarded without identi$ing the employee.
Response to Bayer Data Request 176
Please refer to Confidential Attachments Bayer 176-l and 176-2.
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: Leslie Chase
Sponsor: Julie Lewis
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 178
Bayer Data Request 178
To the extent that PacifiCorp is reducing its workforce, please provide a
detailed explanation justiffing the inclusion of severance pay in the RMP
Idaho's cost of service.
Response to Bayer Data Request 178
Severance expense is compensation and/or benefits an employer provides to an
employee after employment is over generally due to Company sponsored
employee layoffs, downsizing or other business-related reasons.
The Company is not currently imposing a reduction in its workforce. The
Company continues to strive for efficiencies in all areas of its business
including labor. However, the Company does incur a certain level of on-going
severance expense each calendar year in the normal course of doing business.
Severance is considered for use on a very limited basis when and only when it
is justified with a business reason and beyond the control of the employee.
In the base period (calendar year 2020) and test period (calendar year 2021) of
the Idaho general rate case (GRC), the Company recorded and forecasted $2.1
million of severance expense. Of this $2,1 million, Sl.9 million is directly
related to the closure of the Cholla plant transaction. The $1.9 million
severance expense was recorded situs to jurisdictions other than Idaho, thus
leaving a total Company severance expense of $200,000, or $l1,400 allocated
to ldaho.
Recordholder:Craig Stelter
Steven McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 180
Bayer Data Request 180
Please provide the level of hydro maintenance costs assigned to the Idaho
operations for each of the last five calendar years (20 I 6 -2020) and the amount
included in RMP Idaho's current cost of service. If the amount included in cost
of service is greater than previous year's individual totals, please provide a
detailed explanation for the increase in expense.
Response to Bayer Data Request 180
For a listing of hydro operations and maintenance (O&M), please refer to the
Company's response to Bayer Data Request 96, specifically Attachment Bayer
96 which provides the Company's Idaho 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 utility expenses
by FERC Account and subaccount are available in the below "B-Tabs" within
each report:
82 - Operations and Maintenance (O&M) Expense.
Please refer to the direct testimony of Company witness, Steven R. McDougal,
specifically Exhibit No. 40 which provides the Company's2020 ROO.
The Company assumes that "cost of seryice" refers to unadjusted 12 months
ended December 2020 base period expenses. In2020, a non-recuring Klamath
settlement obligation expense of $33 million was booked to FERC Account
545. This accounts for the difference between the 12 months ended December
2019 and the 12 months ended December 2020 amounts.
FERC
545
Description
Maintenance of Misc. Hydro Plant
Factor 12 ME Dec 2O2O t2 ME Dec 2019 Difference
sG 33,000,000 - 33,000,000
sG 3,428,585 3,698,810 1270,225l,sG 725,0',t8 679,277 45,740
37,153,603 4,378,087 32,77s,516
The $33 million expense was removed in adjustment 4.3 Remove Non-
Recurring Entries and is not reflected in ldaho's revenue requirement
calculated in this general rate case (GRC).
Recordholder:Craig Larsen
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 183
Bayer Data Request 183
ln reference to the response to Bayer Data Request 42, please provide a
breakdown ofthe bonuses paid by retention and hiring, safety/perforrnance
awards and Long-term Incentive Plan (LTIP) payments for each year (201G
2020).
Response to Bayer Data Request 183
Below is a Confidential summary of Performance Award, LTIP, Retention and
Safety Award payments:
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, 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:Dave Curnow
Sponsor:Julie Lewis
PAC-E-21-07 / Rocky Mountain Power
October 12,202I
Bayer Data Request 184
Bayer Data Request 184
Reference RMP witness Meredith Workpaper ID GRC Blocking 2020: Please
reconcile the2020 Schedule 401 special contract revenues of $5,818,167 to the
$6,791,774 of revenues reported n2020 on in PacifiCorp's 2020 FERC Form 1,
page304.12, line 9.
Response to Bayer Data Request 184
Please refer to the work papers supporting ttre direct testimony of Company
witness, Robert M. Meredith, specifically file "ID GRC Blocking2020",tab
"Table 3o', line 89 with schedule code "07SPCL0002" for the detailed
reconciliation from $6,791,774 to $5,818,167.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer DataRequest 186
Bayer Data Request 186
Does RMP agree that ttre Schedule 197 Federal Tax Act Adjustment sur-credits
will otherwise expire on January 1,2022, resulting in a revenue increase to
PacifiCorp? If no, please explain.
Response to Bayer Data Request 186
No. The Company does not agree that the expiration of the current Schedule 197
- Federal Tax Adjusfinent sur-credit on January 1,2022, will result in a revenue
increase. The Schedule 197 sur-credit was based on the difference between taxes
in retail rates at the 35 percent corporate tax rate, and the 2017 TaxCut and Jobs
Act of 2017 (TCJA) corporate tax rate of 2 I percent. The Company' s revenue
requirement in this general rate case (GRC) is based on the 2l percent federal tax
rate, therefore the expiration of that credit will not result in a revenue increase to
the Company. It simply moves the tax savings from a Schedule 197 sur-credits
into base rates.
Recordholder:Steve McDougal
Steve McDougalSponsor:
PAC-E-21{7 / Rocky MountainPower
October l2,2AZl
Bayer DataRequest 187
Bayer Data Rquest 187
Please provide actual Schedule 197 Federal Tax Act Adjusfinent sur-credit
rwenues by rate class for calendar years 2019 and2020, dEtailed separately for
each year and rate schedule.
Response toBayerData Request 187
Please refer to Attachme,nt Bayer 187.
Recordholder:James Zhang
RobertMdithSponsor:
PAC-E-2 I {7 / Rocky Mountain Power
October 12,2021
BayerDataRequest 188
Bayer Date Request ltt
Please provide acttral ECAM r€vemues by rate class for calendar years 2019 and
2020, detailed separately for each year.
Rosponse to Bayer Data Request 188
Please rcfer to Attachment Bayer I 87.
Recordholder:Janres Zhng
Robert M€redittrSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
BayerDataRequest 189
Bayer Data Request 189
Reference RMP witness McDougal work paper *3.1-.3 - Idaho Revenue
Adjusfrnent" Tab "3.1.3 -3.1.4": Please explain how RMP has treated the
Schedule 197 Federal Tax Act Adjustnent sur-credit revenues in revenue
normalization in the referenced work paper and explain whether the Schedule 197
Federal Tax Act Adjustment sur-credit revenues are included in normalized
revenue in the referenced work paper.
Response to Bayer Data Request 189
The Company has treated the Schedule 197 Federal Tax Act Adjustnent sur-
credit revenues as present base revenues and they are included in the total
normalized revenues and not included in any of the adjustnents in the referenced
work paper.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
BayerDataRequest 190
Bayer Data Request 190
Reference RMP's response to PIIC Production Request 18, Attachment PIIC l8:
Please provide 2019 and 2020base rate revenues (i.e. excluding all supplemental
schedule revenues such as the TAA, ECAM and BPA residential exchange) for
each rate schedule in the format similar to Meredith work papers "COS ID 2021,
tab "Revenues" Excel Rows "l2l2137."
Response to Bayer Data Request 190
Please refer to the Company's response to Bayer Data Request 187, specifically
Attachment Bayer 187.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer DataRequest l9l
Bayer Data Request 191
Reference RMP's response to PIIC Production Request 18, Attachment PIIC l8:
Please detail the supplemental schedule revenues such as the TCJA, ECAM, and
BPA residential exchange for each rate schedule for 2019 urd2020 in the format
similar to Meredith work papers "COS ID 2021", tab o'Revenues" Excel Rows
"l2l,137." Please provide separate detail for each supplemental rate schedule.
Response to Bayer Data Request 191
Please refer to the Company's response to Bayer Data Request 187, specifically
Attachment Bayer 187.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-2147 /Rocky Mountain Power
October 12,2021
BayerDataRequest 193
Bayer Date Request 193
Please detail the total amount of retirements with detail by FERC account
associated with fte repowering of lvlarengo 1, Idarengo 2, Dunlap and Foote
Creek. Please also state the daG ofthe retirements.
Response to Bayer Data Request 193
Please refer to Attaohment Bayer 193 for the total amount of r,atirements with
detail by FERC Account associated wift the repowering ofthe Marengo l,
Marengo 2, Dunlap and Foote Creek wind facilities.
Recordholder:Justus Evangelista
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 194
Bayer Data Request 194
Please identify the total number of customers by rate schedule with AMI meters
currently deployed and the total number of customers with AMI expected to be
deployed by the end of calendar year 2021.
Response to Bayer Data Request 194
There were no Advanced Metering Infrastucture (AMI) meters installed as of
September 30,2021. Meter installations are scheduled to begin mid-October
2021.lt is expected that 17,500 customers will have AMI meters by the end of
December 2021.
Recordholder:Douglas Mam
Steve McDougal / Curtis MansfieldSponsor:
PAC-E-21{7 / Rocky lvlountain Power
October 12,2021
Bayer Data Request 196
Bayer Date Requet 196
fihere rvas no question ll}5 submitted by Bayer Corporation in BayerData
Request 15 (152 thrcugh 232I
Recponsc to Bayer Data Rquest 196
There is no question to reqpond to.
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer DataRequest 197
BayerData Request 197
[There was no question 197 submitted by Bayer Corporation in Bayer Data
Request 15 (152 through 2321
Responce to Bayer Data Request 197
There is no question to respond to.
PAC-E 2147 / Rocky Mountain Poruer
October l2,202l
BayerDataRequest 198
Beyer Ilata Requst l9t
[Thene was no question 198 zubmitted by Bayer Corporation in Bayer Data
Request 15 (152 through 2321
Response to Bayer Dete Request 198
firere is no question to respond to.
PAC-E-21-07 / Rocky Mountain Power
October 12,2A2l
BayerDataRequest 199
Bayer Data Requost lE)
[There was no question 199 submitted by Bayer Corporation in BayerData
Request 15 (152 through 232I
Response to Bayer Data Request 199
There is no question to reqpond to.
PAC-E-21{7 / Rocky Mountain Power
October 12,2021
Bayer DataRequest 200
Bayer Data Reque$ 200
Reference RMP's response to PIIC Production Request 59: Please identify the
amount environmental spending in calendar year 2020 applid to fte regulaiory
liability accounts identified in the referenced rcqponse.
Recponse to Beyer Datr Request200
Please refer to Attachment Bayer 200.
Recordholder: Colin Sutherland
Sponsor:Steven McDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 201
Bayer Data Request 201
Reference RMP's response to PIIC Production Request 82: Please explain how
the $7,423,175 of affiliate costs are being assigned to PacifiCorp from the
afftliate. Please provide accounting work papers supporting the calculation of the
affiliate service amounts encompassing each line item in attachment PIIC 82.
Please also provide any cost allocation manuals in effect during the test period,
which determine how the affiliate service costs are to be assigned or allocated to
PacifiCorp.
Response to Bayer Data Request 201
Please reference Attachment Bayer 201 for supporting documentation l) 2020
cost allocation manual and2) sunmary of affiliated departnents charging costs to
PacifiCorp.
Recordholder:Nancy Adolphson
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request204
Bayer Data Request 204
Reference RMP's response to PIIC Data Request 90, Attachment PIIC 90: Please
provide an explanation and source accounting documentation for the following
line items included in the referenced work paper:
(a) Cholla Closure M&S RA ID Amort: $350,550
(b) Cholla Closure CWIP RA ID Amort: $57,480
Response to Bayer Data Request 204
Please refer to Attachment Bayer 204 which includes a copy of the journal entry
to record the amortization. This entry is pursuant to the Idaho Public Utilities
Commission (IPUC) accounting order authorning ttre buydown ofthe Cholla net
book value (NIBV), including materials and supplies (M&S) and construction
work-in-progress (CWIP) with tax benefits from tax reform.
Recordholder:Tom Evans lKarl Mortensen / Nancy Adolphson
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer DataRequest 205
Bayer Data Request 205
Reference RMP Witness McDougal work paper "8.9 - Regulatory Assets &
Liability Amortization", Tab "Page 8.9.6": Are the dates in column "E" ofthe
referenced work paper correct?
Response to Bayer Data Request 205
On the referenced tab "Page 8.9.6", column E contains monthly balances, column
B contains the year, and column C is the corresponding month. The years
referenced in column B should state202l md2022 respectively, instead of 2020
and202l. The months in column C is correct.
Recordholder:Sherona Cheung
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 206
Bayer Data Request 206
Reference RMP Wifrress McDougal work paper "8.9 - Regulatory Assets &
Liability Amortization", Tab "Page 8.9.6": When does PacifiCorp plan to submit
its next deprecation study and what will the effective date of the next depreciation
study be?
Response to Bayer Data Request 206
Please refer to Paragraph 20 of the filed Stipulation under Docket No. PAC-E-I8-
08. Regarding the Company's next depreciation study, it states that:
"...the Company plans to file in 2025 with new
depreciation rates effective no earlier than January l,
2026...".
At this time, the effective date of any new depreciation study has yet to be
determined.
Recordholder:Justus Evangelista
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 210
Bayer Data Request 210
Reference work paper *Bl9 - Deferred Income Tax Balance" provided in response
to PIIC Production Request 5: Please reconcile the total Company ADIT balance
identified in cell '0F256" of $2,467,789,000 to the total company ADIT balance
identified in work paper "7.4 - Power Tax ADIT Balance", Tab "Page '1.4.1", Cell
"C57" of $2,848,256, I 04.
Response to Bayer Data Request 210
Workpaper Bl9 list all of the Company's ADIT balances, whereas the ADIT
balances in Adjustnent 7.4 are a subset of the total that are maintained by the
Company's tax fixed asset system, PowerTax. Please see the requested
reconciliation in Attachment Bayer 210.
Recordholder: BrianKeyser
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request2l4
Bayer Data Request?l4
Reference work paper "Bl9 - Deferred lncome Tax Balance" provided in
response to PIIC Production Request 5: Please provide an explanation for the line
item'DTA Net Operating Loss Carryforward-State" on row I 15 in the amount of
$ 3,765,000 (Idaho allocated). Please identiff the states(s) where ttre Net
Operating Loss carry forward has been in incurred and the associated amounts of
carryforwards for each state.
Response to Bayer Data Request2l4
The detail of the State Net Operating Loss Carryforward balance as of December
31,2020 is shown below.
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:Brian Keyser
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request2lT
Bayer Data Request2lT
Reference RMP winress McDougal work paper *JAM Dec202l ID GRC", Tab
"Factors," cells "BBl3:B.Y'^25": Please provide work papers, including hourly
loads used to support the jurisdictional coincident peaks, and the associated
temperature adjustnents in cells "BB33:BK45" please provide detail suffrcient to
identiff special tariffcustomers, such as direct access customer loads, which are
being directly assigned to a particular state, the Monsanto curtailment buy-
through product, and FERC jurisdictional sales to the Navajo Tribal Authority
included in Utah' s jurisdictional allocation.
Response to Bayer Data Request2lT
Please refer to Confidential AttachmentBayer 217.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, ttre 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:Sherona Cheung
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 218
Bayer Data Request 218
Reference RMP witness McDougal work paper *JAM Dec202l ID GRC", Tab
"Factors," cells "BXl3:CG25": Please provide work papers, including hourly
loads used to support the jurisdictional loads, and the associated temperature
adjustnents in cells "BX33:CG45" please provide detail sufficient to identifr
special tariffcustomers, such as direct access customer loads, which are being
directly assigned to a particular state, the Monsanto curtailment buy-through
product, and FERC jurisdictional sales to the Navajo Tribal Authority included in
Utah' s jurisdictional allocation.
Response to Bayer Data Request 218
Please refer to the Company's response to Bayer Data Request 217 , specifically
Confidential Attachment Bayer 217 for requested supporting work paper.
Recordholder: Sherona Cheung
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 219
Bayer Data Request 219
Please provide Idaho state deferred income taxes as ofDecember 31,2020 included
in revenue requirement, and identiff any adjusftrents to Idaho state deferred taxes.
Response to Bayer Data Request 219
Please see RMP Exhibit 40, page 24, row l2l2 for Total Deferred Income Tax
expense. Idaho allocated deferred income tax expense totals $(1,671,807). For a
separate proof of Idaho allocated defened income tax expense, please see the
Company's response to Bayer Data Request22l.
Please see RMP Exhibit 40, page 35, rows 2203, 2209, 2221, and 2234 for the
ADIT balances for FERC 190, 281,282, and 283 respectively. Idaho allocated
ADIT totals $(1 46,398,485).
Adjusfinents to Idaho state deferred income tax expense and ADIT balances can be
found in RMP Exhibit40, workpapers 4.7 (page86),5.2 (page 107), 6.3 (page I l7),
6.5 (page 125 and 126), 6.6 (page 130), 7.4 lpage 140),7.6 $nge 144),8.2 (page
152), 8.5 (page 160),8.7 (page 165), 8.9 (page 169), 8.10 (page 178), 8.11 (page
182),8.12 (page 188), 8.13 (page 196), 8.14 (page 199), 8.15 (page 206) and 8.16
(page 210).
Recordholder:Brian Keyser
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request220
Bayer Data Requqt220
Did PacifrCorp recognize any excess defened taxes associated wittr the reduction
in the Idaho state tax rate from 6.925%oto 6.5%o.If yes, please identi$ the amount
of excess accumulated deferred state taxes associated wittr the Idaho state tax rate
change as ofthe date ofthe rate change.
Response to Bayer Data Request2}0
No, the Company did not recognize any excess defened income tax associated widr
the reduction in the Idatro corporate income tax rate from 6.9250/o to 6.5%o for
taxable years commencing on and after January 1,2021.
PacifiCorp's blended state statutory income tan rate, which is comprised of all the
state and local income tax jurisdictions in which PacifiCorp is subject to corporate
income tax, is 4.54% both before and after the aforementioned reduction in Idaho's
corporate income tax rate.
Please refer to Confidential Attachment IPUC ll5 for an explanation of how
PacifiCorp's blended state statutory income rate is set.
Recordholder: Brian Keyser
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request22l
Bayer Data Request2?l
Reference RMP witness McDougal work paper "JAM Dec202l ID GRC": In tab
"NRO,'Excel Row 1366, RMP reports Idaho-allocated temporary Schedule M
additions of 90,656,91I and on Excel Row 1395 reports Idaho-allocated temporary
Schedule M deductions of 98,426,978. These two values net to a total temporary
book tax difference deduction of $7,770,066, Idaho allocated. After a state tax
effect of 6.50/o, this amount implies a deferred tax expense of $ I ,525,6 52 (7 ,770,066* l2lo/o* {l - 6.5%\+6.5%l). Please reconcile that amount with the $1,671,807 of
defened tax expense that RMP has proposed in this proceeding.
Response to Bayer Data Request22l
Please see the requested reconciliation of Idaho allocated deferred income tax
expense in the following table:
Itcm Dercrllor Arrrount
khcduh H Additbns - Tcmporery
khcduh lrl Nustiont -
Tctd Tcnpctzry Scheduh Ff Acdvlt,
fucrd A St tc thndcd Strtutory lncom Trx Retc
90,656,9il
(98t126,9781
(r,710,044
21.WX
TcaJ Ddtrnd lnocrne Ter Bgmr t (!rnrtt) cn Trapgnry 3dredth 1{ Acift&t
Dcftrrtd Tex Only Adlustmmt Sohr ITC Blstr Ddhrcncc
Dcfcrrcd Ter Onry Aqun ncnc Dcprcchtk n Fbrr-Through
Dc&rcd Trx Only Adu*ncnt hotcctcd Exccr Dclarrtd lncornc Trx fuiortizrtbn
I,il0,ttt
838
(670,59r)
(2.9 r 2,,155)
6
Tctr| lddrc Allccsd Deirrlod lncne Ter Ereorr, (Mc)(!,a7t,aol)
Additionally, the Company's federal and state blended statutory income rate is
24.5866%. Please refer to Confidential Attachment IPUC I 15 for an explanation of
how this rate is set.
Recordholder: BrianKeyser
Sponsor: Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data RequestzzT
Bayer Data Request22T
Please state the total revenue requirement associated with Pryor Mountain and
Foote Creek included in revenue requirement in this proceeding, individually for
each resource. Please provide work papers supporting the calculation, including
supporting detail for each revenue requirement component.
Response to Bayer Data Request22T
For the Pryor Mountain wind project revenue requirement calculation, please
refer to Bayer Data Request 70. For the Foote Creek repowering project revenue
requirement calculation, please refer to Confidential Attachment Bayer 227.
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: Craig Larsen
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request22S
Bayer Data Request22S
Reference RMP Witness McDougal work paper *8.15 -New Wind & Repowering
Capital Additions REDACTED": Please provide the end of period 2020 gross
plant in service, depreciation reserves and ADIT associated with each new wind
resource, tansmission resource and repowering resource identified in the
referenced work paper.
Response to Bayer Data Request 228
The Company assumes that this request for end of period 2020 balances is
specifically referring to the resources listed on work paper page 8.15.1. Please
refer to Confidential Attachment Bayer 228 for the end ofperiod 2020 gross plant
in service, depreciation reserve and accumulated deferred income ta,xes (ADIT)
associated with each new wind resource, transmission resource and repowering
resource identified in the referenced work paper.
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:Justus Evangelista / Brian Keyser
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request229
Bayer Data Request229
Reference RMP Witress McDougal work paper "8.l5 -New Wind & Repowering
Capital Additions REDACTED": Please provide the annualized depreciation
expenses included in revenue requirement for each of the new wind resour@,
transmission resource, and repowering resources identified in the referenced work
paper.
Response to Bayer Data Request229
The Company.Nsumes that this request for annualized depreciation expense is
specifically referring to annualized depreciation expense amounts on work paper
page 8.15.1, since the depreciation expense amounts on 8.15.2 are already annual
amounts. Please refer to the Company's response to Bayer Data Request 68 which
has all the information needed to calculate the annual depreciation expense.
Recordholder:Craig Larsen
Steve McDougalSponsor:
PAC-E-2 I {7 / Rocky Mountain Power
October l2,2A2l
Bayer Data Request 230
Bayer Data Request 230
Reference RMP Reference RMP Witness McDougal work paper*8.15 -New
Wind & Repowering Capital Additions REDACIED": Please state the e4pected
End ofPeriodz0zl ADIT balances associated with each of 0re new wind
resource, transmission resouroe, and repowering resources identified in the
referpnced workpaper.
Response to Bayer Data Roquest230
Please refer to Confidential Afiachment Bayer 68.
Recordholder: Brian Keyser
Sponsor: Steve MeDougal
PAC-E-21-07 / Rocky Mountain Power
October 12,2021
Bayer Data Request 231
Bayer Data Request 231
Reference RMP Reference RMP Witness McDougal work paper "8.l5 - New
Wind & Repowering Capital Additions REDACTED": Please provide the
confidential attachment provided in response to AWEC Data Request 07 in
Washington Utilities Transportation Commission Docket No. UE-2 I 0 532 Q02l
Limited Issue Rate Filing), where PacifiCorp calculated the202l end of period
ADIT balances for the new wind and repowering resources at issue in that
proceeding.
Response to Bayer Data Request 231
The Company 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 the foregoing objection, the Company responds as follows:
Please refer to Confidential Attachment Bayer 231.
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: Dan Martinez
Sponsor:To Be Determined