20210430PAC to PIIC 1-10.pdf

t.,t I. i'-i- LROCKY MOUNTAIN
POWER
A DMSIOI{ OF
'ACIFICORP
l.:i irl 30 f'H B' L0
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
Apil29,2Al
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
ron@williamsbradburv. com
RE: ID PAC-E-21-09
PIIC Set I (l-10)
Please find enclosed Rocky Mountain Power's Responses to PIIC I't Set Data Requests l-10.
Also provided are Attachments PIIC l-1, 2-1,8, and 10. Confidential Attachments PIIC l-2,2-
2,3, 4, and 6 will be provided upon receipt of a signed non-disclosure agreement. Confidential
information is provided subject to protected 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 any subsequentNon-Disclosure Agreement (NDA)
executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jst-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan NoriyukiAPUC [e-mail] (C)
Joseph Terry/IPU C ioseph.terrv@puc. idaho.qov
Donn English/IPUC [e-mail]. eov
PAC-E-21-09 / Rocky Mountain Power
Apil29,202l
PIIC Data Request I
PIIC Data Request 1
Please provide electronic versions of all exhibits and work papers, with all
formulas and links intact, supporting Rocky Mountain Power's filing in this case.
Response to PIIC Data Request 1
Please refer to Attachment PIIC l-l and Confidential Attachment PIIC l-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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Not Applicable
Not ApplicableSponsor:
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 2
PIIC Data Request 2
Please provide PacifiCorp's actual net power costs over the period 2016 through
2020. Please provide all workpapers used to calculate actual net power costs,
including the underlying monthly fuel reports and FERC reporting database
(formerly TORIS). If a map is necessary to assign database entries or fuel items to
the lines in the actual net power cost report, please provide a copy of the
spreadsheet used to map the data. (See e.g. PCA Data Request l4 in Washington
Docket No. UE-I91024).
Response to PIIC Data Request 2
The Company objects to this data request as overly broad and not reasonably
calculated to lead to the discovery of admissible evidence. This data request seeks
information outside of the energy cost adjustment mechanism (ECAM) defenal
period relevant in this proceeding, namely calendar year 2020 (January 1,2020
through December 31,2020). Notwithstanding the foregoing objection, the
Company responds as follows:
Please refer to Attachment PIIC 2-l which provides actual net power costs (NPC)
reports for 2016 through 2020. Please refer to Confidential AttachmentPllC 2-2
which provides the actual NPC database enties, along with their mapping and
fuel supply cost calculations for 2016 through2020.
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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Jack Painter
Sponsor:Jack Painter
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 3
PIIC Data Request 3
Please provide PacifiCorp's actual net power cost, in the manner identified in
PIIC Data Request 01, but for calendar year 2021 through the latest month
available. This is an ongoing request.
Response to PIIC Data Request 3
The Company assumes that the reference to "PIIC Data Request 0l" is intended
to be a reference to PIIC Data Request 2. Based on the foregoing assumption, the
Company responds as follows:
The Company objects to this data request as overly broad and not reasonably
calculated to lead to the discovery of admissible evidence. This data request seeks
information outside of the energy cost adjustnent mechanism (ECAM) deferral
period relevant in this proceeding, namely calendar year 2020 (January 1,2020
through December 31,2020). Notwithstanding the foregoing objection, the
Company responds as follows:
Please refer to Confidential Attachment PIIC 3 which provides the actual net
power costs (NPC) report for 2021(January 2021and February 2021). Note:
PacifiCorp's actual NPC are confidential until the Federal Energy Regulatory
Commission (FERC) Form I for calendar year 2021has been filed with FERC
(April 2022). Please also refer to Confidential Attachment PIIC 3 which provides
the actual NPC database entries, along with their mapping and fuel supply cost
calculations for 2021 (January 202I andFebruary 2021).
The Company will supplement the response to this data request as additional
information becomes available.
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 - lnformation Exempt from Public Review, and further subject
to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Jack Painter
Sponsor:Jack Painter
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 4
PIIC Data Request 4
Please provide an outage log for calendar years 2019,2020, and202l (to date) in
a format substantially similar to the information typically provided as an exhibit
to Rocky Mountain Power's Wyoming ECAM filings, (see e.g Wy.PSC docket
20000-582-EM-20, Exhibit RMP_(DGW-8) CONF).
Response to PIIC Data Request 4
The Company objects to this data request as overly broad and not reasonably
calculated to lead to the discovery of admissible evidence. This data request seeks
information outside of the energy cost adjustnent mechanism (ECAM) deferral
period relevant in this proceeding, namely calendar year 2020 (January 1,2020
through December 31,2020). Notwithstanding the foregoing objection, the
Company responds as follows:
Please refer to Confidential Attachment PIIC 4 which provides the Company's
thermal outage information for calendar years 2019 and2020. At this time,
thermal outage information for calendar year 2021(to-date) is not available. The
Company will supplement this data request response when the information
becomes available.
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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Gavin Mangelson
Jack PainterSponsor
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 5
PIIC Data Request 5
Please provide a description of each adjustnent applied to actual net power costs
when calculating the ECAM defenal.
Response to PIIC Data Request 5
Net Power Costs (NPC) Adiustments - The Company increased actual NPC
$769,008 to account for the following adjustments: (l) prior period adjustments,
(2) coal cost adjustnents, (3) removal of special contract curtailment buy-through,
(4) Leaning Juniper revenue, (5) Black Cap Solar allocation, (6) Old Mill Solar
power purchase agreement (PPA) allocation, (7) Pavant Solar III PPA, (8) Oregon
Solar Incentive Plan (OSP) resources allocation, (9) Utah Transition Program for
Customer Generators (Transition Program), ( I 0) Mead-Phoenix amortization,
(11) Amor IX -University of Utah PPA, (12) Cove Mountain Solar 2 -Facebook
PPA, (13) Reasonable Energy Price Quali$ing Facility (QF) Adjustnents, and
(14) Reclassification of Wholesale Sales due to the Federal Energy Regulatory
Commission (FERC) Price Cap.
l. Prior Period Adjustments
Prior period adjustrnents represent accounting tansactions booked during the
energy cost adjusftnent mechanism (ECAM) defenal period of calendar year
2020 (January 2020 through December 2020), but that are related to operating
periods prior to the inception of the ECAM in July 1,2009. Prior period
adjustnent accounting entries were zero in this 2021ECAM defenal period.
2. Coal Cost Adjustments
Coal cost adjustments increased actual NPC by $5,518,271. These
adjustments are necessary to include 2020 liquidated damages accrued in
2019, and legal fees related to fines and citations. In addition, adjustnents are
made to coal inventory to reflect coal costs in the correct period. Please refer
to the Company's response to PIIC Data Request 6, specifically Confidential
Attachment PIIC 6, file "Adjustnents_ID ECAM CONF", tabs "Prior Period
Coal Adjusfrnents", "Aerial Survey Adjustments", "Choll a LD",'Naughton
LD", and "Wyodak LD".
3. Removal of Special Contract Curtailment Buy-Through
The removal of special contract curtailment buy-through reduced actual NPC
by $2,1 14,572. This adjusfrnent is required to remove the effects of special
contract customer elections to purchase market energy during curtailment
events. Buy-through energy costs are a direct pass-through cost to special
contract customers and is not included in NPC. Please refer to the Company's
response to PIIC Data Request 6, specifically Confidential Auachment PIIC 6,
file "AdjustnentsJD ECAM CONF", tab "Buy-Through".
PAC-E-21-09 / Rocky Mountain Power
Apil29,202l
PIIC Data Request 5
4. Leaning Juniper Revenue
In October 2013, the Company reached an agreement resulting in additional
revenue for energy, renewable energy credits EEC), and production tax
credits (PTC) related to the Leaning Juniper wind project. Actual revenue is
booked in FERC Account 456. An adjustment is made to include $69,459 in
revenue related to Leaning Juniper energy output for purposes of the ECAM.
Please refer to the Company's response to PIIC Data Request 6, specifically
Confidential Attachment PIIC 6, file "AdjustrnentsJD ECAM CONF", tab
"Leaning Juniper".
5. Black Cap Solar Allocation
Black Cap Solar was procured to satisfu Oregon Revised Statute (ORS)
757 .370 solar capacity standard. Therefore, the zero cost energy benefit of
Black Cap Solar generation is situs assigned to Oregon. For the purposes of
the ECAM, the Black Cap Solar adjusftnent increases NPC $78,600. Please
refer to the Company's response to PIIC Data Request 6, specifically
Confidential Attachment PIIC 6, file "Black Cap_JAN-DEC}0 CONF".
6. Old Mill Solar Power Purchase Agreement (PPA) Allocation
Old Mill Solar PPA was procured to satisfr ORS 757.370 solar capacity
standard. Therefore, the above market cost or benefit of Oregon Mill Solar
generation is situs assigned to Oregon. For the purposes of the ECAM, the
Old Mill Solar adjustnent decreases NPC $622,947.Ptease refer to the
Company's response to PIIC Data Request 6, specifically Confidential
Attachment PIIC 6, file "Old MiII-JAN-DEC2O CONF".
7. Pavant Solar III Power Purchase Agreement (PPA)
Pavant Solar III PPA was procured to satisff the Utah "Subscriber Solar
Program Rider - Optional" Tariff Schedule 73, which created a limited pilot
progrurm to enable Utah customers who choose to participate to purchase
electricity from a specific solar resource. Therefore, the above market cost or
benefit of Pavant Solar III generation is situs assigned to Utah. For purposes
of the ECAM, the Pavant Solar III adjustrnent decreases NPC $392,594.
Please refer to the Company's response to PIIC Data Request 6, specifically
Confidential Attachment PIIC 6, file'oPavant III JAN-DEC20 CONF".
8. Oregon Solar Incentive Plan (OSIP) Resources Allocation
OSIP is a solar pilot project in Oregon which enables Oregon customers to
own solar panels and sell any excess energy to the Company at an agreed
upon rate. Therefore, the above market cost or benefit of OSIP generation is
situs assigned to Oregon. For the purposes of the ECAM, the OSIP adjusfinent
decreases NPC $31,896. Please refer to the Company's response to PIIC Data
Request 6, specifically Confidential Attachment PIIC 6, file "Adjustments_ID
ECAM CONF", tab "OSIP Resources".
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 5
9. Utah Transition Program for Customer Generators (Transition Program)
The Utah Transition Program for Customer Generators under the Transition
Program Tariff Schedule 136 measures the difference between the electicity
supplied by the Company and the electricity generated by an eligible
customer-generator and fed back to the electric grid. The progftrm enables
eligible customers to offset part or all of their own electrical requirements
with self-generation and receive export credits for energy fed back to the
electric grid. Therefore, the above market cost or benefit of the Transition
Program is situs assigned to Utah. For purposes of the ECAM, the Transition
Program adjustnent decreases NPC by $3,090,398. Please refer to PIIC Data
Request 6, specifically Confidential Attachment PIIC 6, file "Adjusfrnents_ID
ECAM CONF", tab "Transition Program".
I 0. Mead-Phoenix Amortization
The amortization of Mead-Phoenix wheeling expense was updated to reflect
the Cholla Unit 4 Oregon depreciation schedule. Therefore, the incremental
variance in amortization expense associated with Mead-Phoenix is situs
assigned to Oregon and added to NPC for the purposes of the ECAM. The
Mead-Phoenix adjustrnent increases NPC $80,096. Please refer to the
Company's response to PIIC Data Request 6, specifically Confidential
Attachment PIIC 6, file "AdjusfrnentsJD ECAM CONF", tab "Mead-
Phoenix".
I l. Amor IX - University of Utah PPA
The Amor IX -University of Utah PPA was procured to satisff the Utah
Schedule 32 tariff . This schedule is a unique retail service option that allows
customers to direct the Company to serve all or part of its electricity from a
renewable energy facility. Therefore, the above market cost or benefit of the
Amox IX - University of Utah generation is situs assigned to Utah. For
purposes of the ECAI\4 the Amor IX - University of Utah adjustnent reduces
NPC by $3,136,295. Please refer to the Company's response to PIIC Data
Request 6, specifically Confidential Attachment PIIC 6, file "Amor JAN-
DEC2O CONF''.
12. Cove Mountain Solar 2 - Facebook PPA
The Cove Mountain Solar 2 - Facebook PPA was procured to satisfu the Utah
Schedule 34 tariff. This schedule is a unique retail service option that allows
customers to direct the Company to serve all or part of its electicity from a
renewable energy facility. Therefore, the above market cost or benefit of the
Cove Mountain Solar 2 - Facebook generation is situs assigned to Utah. For
purposes of the ECAM, the Cove Mountain Solar 2 - Facebook adjustnent
increases NPC by $l,278,39L Please refer to the Company's response to PIIC
Data Request 6, specifically Confidential Attachment PIIC 6, file
"Facebook JAN-DEC2O CONF".
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 5
13. Reasonable Energy Price QF Adjustments
An adjustment increasing NPC $31,892 due to the situs assignment of costs
associated with the reasonable energy price (REP) allocated to the state of
origin in the Multi-State Process (MSP) 2020 Protocol. Please refer to the
Company's response to PIIC Data Request 6, specifically Confidential
Attachment PIIC 6, file "Adjustrnents_ID ECAM CONF", tab "Reasonable
Energy Price".
14. Reclassilication of Wholesale Sales due to FERC Price Cap
An adjustment increasing NPC $3,239,918 for reclassification of wholesale
sales revenue above the FERC price cap. Sales pending refund are accounted
for in FERC Account 449, anon-regulatory NPC account instead of FERC
Account 447. Because this tansaction is recorded in a non-NPC account and
the wholesale sales revenue is recorded in FERC Account 447, the adjustnent
should be included in the 2021 ECAM to align the pending refund with the
matching sales revenue in accordance with generally accepted accounting
principles (GAAP). Please refer to the Company's response to PIIC Data
Request 6, specifically Confidential Attachment PIIC 6, file "AdjusftnentllD
ECAM CONF", tab "FERC Reclassification".
Recordholder:Jack Painter
Sponsor:Jack Painter
PAC-E-21-09 / Rocky Mountain Power
Apnl29,202l
PIIC Data Request 6
PIIC Data Request 6
Please provide supporting work papers for each adjustnent applied to actual net
power costs when calculating the ECAM defenal.
Response to PIIC Data Request 6
Please refer to Confidential Attachment PIIC 6.
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 any subsequentNon-Disclosure Agreement (NDA) executed in this proceeding
Recordholder:Jack Painter
Sponsor:Jack Painter
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 7
PIIC Data Request 7
Please provide work papers used to support the fuel supply costs for PacifiCorp's
gas and coal plants over the period 2016 through the most recent month available.
Response to PIIC Data Request 7
The Company objects to this data request as overly broad and not reasonably
calculated to lead to the discovery of admissible evidence. This data request seeks
information outside of the energy cost adjustnent mechanism (ECAM) defenal
period relevant in this proceeding, namely calendar year 2020 (January 1,2020
through December 31,2020). Notwithstanding the foregoing objection, the
Company responds as follows:
Please refer to the Company's response to PIIC Data Request 2, specifically
Confidential Attachment PIIC 2-2wlnchprovides the actual net power costs
(NPC) database entries, along with their mapping and fuel supply cost
calculations for 2016 through 2020.
Please refer to the Company's response to PIIC Data Request 3, specifically
Confidential Attachment PIIC 3 which provides the available actual NPC
database entries, along with their mapping and fuel supply cost calculations for
calendar year 2021 (January 2021 through February 2021).
Recordholder:Jack Painter
Sponsor:Jack Painter
PAC-E-21-09 / Rocky Mountain Power
April29,202l
PIIC Data Request 8
PIIC Data Request 8
Reference McDougal Exhibit 4: Please provide work papers used to calculate the
pretax rate of return applicable to the EV 2020 and repowering projects.
Response to PIIC Data Request 8
Please refer to Attachment PIIC 8 for pre-tax rate of retum (ROR) calculations
applicable to the Energy Vision 2020 (EV 2A2q and repowering projects.
Recordholder:Justin Waterman
Sponsor:Steve McDougal
PAC-E-21-09 / Rocky Mountain Power
Aptil29,202l
PIIC Data Request 9
PIIC Data Request 9
Reference McDougal Exhibit 4: Please explain why the rate of return is different
for the repowering resources compared to the EY 2020 resources.
Response to PIIC Data Request 9
The difference of the rate of return (ROR) between repowering resources and
Energy Vision 2020 (EV 2020) resources was agreed upon during settlement
negotiations and those agreements are confidential. ROR agreements are provided
in Case No. PAC-E-17-06, Order 33954, updated for the new federal tax rate
change, and Case No. PAC-E-17-07, Order 34104.
Recordholder: Justin Waterman
Sponsor:Steve McDougal
PAC-E.21-09 / Rocky Morurtain Power
April29,202l
PtrC DataRequest l0
PtrC Data Request 10
Please provide the actual jurisdictional SE and SG allocation factors for all
jurisdietions for calendar yerrr 2020, including the load wor* papers supporting
the allocation faotor calculations.
Response to PIIC Deta Request 10
Please refer to Attachment PIIC 10 for weather normalized actual loads for
calendar yex2020.
Recordholder: Justin Waterman
Sponsor:Steve McDougal