20220428PIIC 1-24 to PAC.pdf

Ronald L. Williams, ISB No. 3034
Jonathan D. Wheatley, ISB No. I1537
Hawley Troxell Ennis & Hawley LLP
877 West Main Street
Boise ID, 83701
Telephone: [phone]
rwilliams(@hawleytroxell. com
i wheatley@hawlytroxell. com
Attorneys for PIIC
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTTNG APPROVAL OF $28.4
MILLION ECAM DEFERRAL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
CaseNo. PAC-E-22-05
FIRST PRODUCTION REQIIEST OF
PACIFICORP IDAHO II\TDUSTRIAL
CUSTOMERS TO ROCKY
MOUNTAIN POWER
PacifiCorp Idaho Industrial Customers ("PIIC"), by and through its
attorneys of record and pursuant to the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission"), hereby requests that Rocky Mountain Power ("RMP")
provide the following documents and information no later than 5PM. MDT on May 19.
2022.
Please provide answers to each question and supporting work papers that provide
detail or are the source of information used in calculations. ln addition to the written
copies provided as response to the questions, please provide all Excel and electronic files
on CD with formulas activated. Please provide a copy of all responses electronically to
PIIC consultant, Brad Mullins, via his email as shown on the attached service list. This
Production Request is continuing, and RMP is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf
may later obtain that will augment the documents produced.
Page I
s9s0 1.000r . l 47 1 67 88.1
PIIC l't Set of Production Requests to RMP, Case No. IPUC-E-2I-09
Request No 1: Please provide all questions and answers to all prior data requests
between RMP and Commission Stafl and all other parties in this case, including
questions and answers that contain confidential information.
Request No 2: Please provide electonic versions of all exhibits and workpapers,
with all formulas and links intact, supporting Rocky Mountain Power's filing in this case.
Request No 3: Please provide PacifiCorp's actual net power costs over the period
2017 through 2021. 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.
Request No 4: Please provide PacifiCorp's actual net power cost, in the manner
identified in PtrC Data Request 3 (the prior request), but for calendar year 2022 through
the latest month available.
Request No 5: Please provide workpapers used to support the fuel supply costs for
PacifiCorp's gas, coal and geothermal power plants over the period 2017 through the
most recent month available. Please also provide any workpapers used to map the
associated data to the net power cost report.
Request No 6: Please provide transaction level detail supporting each and every
gas purchase and sale transaction, including financial transactions, with deliveries or
settlements in the 2021 defenal Period. For each transaction, please provide all available
fields in PacifiCorp's energy trading system, including but not limited to deal tracking
number, instrument type, trade date, trade type, commodity t1pe, trading category
counterparty, buy/sell, FERC account, delivery start date, delivery end date, point of
receipt, point of delivery, product, daily delivery rate, fixed price, floating price, market
spread, index paid or received, location name, and any other information necessary to
derive the total fuel supply costs associated with gas sales and purchase transactions in
the deferral period.
Page2
59501.0001.1471 6788.1
PIIC I't Set of Production Requests to RMP, Case No.IPUC-E-21-09
Request No 7: Please provide detail of all pipeline charges and fees accrued in the
2021 deferral period, including detail of each contract, the counterparty, the tariffrates,
the capacity, and the cost.
Request No 8: Please explain and provide details as to whether PacifiCorp
incurred any overun or undemrn entitlement charges on any pipeline in the 2021 defenal
period?
Request No 9: Please provide workpapers supporting the calculation and
allocation of fuel supplies costs to each of PacifiCorp's natural gas power plants in the
2021 defenal period.
Request No l0: Please provide the GAAP trial balance from the Bridger Coal
Company for the 2021 defenal period.
Request No 11: Please provide the GAAP financial statements, including a
Balance Sheet, lncome Statement and Statement of Cashflows, from the Bridger Coal
Company for the 2021 deferral period.
Request No 12: Please provide the operating results from the Bridger Coal
Company used to derive the cost of coal consumed at the Jim Bridger Power Plant in the
2021 defenal period.
Request No 13: Please provide transaction level accounting data for 2021 using a
format identical to PacifiCorp's response to Staff Data Request 57 in Docket UE 399
before the Oregon Public Service Commission, including detail of the Idaho allocated
amounts. Please provide the transaction level accounting detail for FERC accounts 447,
456,419,557, 501, 503, 547, 555, 557, 565, 566. Note that while some of these are not
NPC accounts, PIIC is reviewing them to evaluate whether revenues and costs were
appropriately attributed to NPC accounts.
Request No 14: Please provide a copy of PacifiCorp's FERC Form I for 2021,
including all supporting schedules and workpapers.
Page 3
59501.000r. r47 l 6788. l
PIIC l't Set of Production Requests to RMP, CaseNo.IPUC-E-21-09
Request No l5: Please provide hourly power market prices at each market hub
where PacifiCorp transacts for the 2021 deferral period.
Request No l6: Please provide hourly (or sub-hourly if available) generation logs
for each of PacifiCorp generation resources, including wind resources, for the202l
deferral period.
Request No 17: Please provide a log of outages for all thermal, wind, and hydro
resources for the deferral period.
Request No l8: For each NPC account, please provide a reconciliation between
PacifiCorp's financial accounting and FERC accounting.
Request No 19: To the extent not already provided, please provide all of the
minimum and additional filing requirements submitted in the Utah Energy Balancing
Account ("EBA"), Ut.PSC Docket No. 22-035-01 for the 2021 deferral period, except
those filing requirements specifically related to the calculation of the EBA. At a
minimum, please provide the responses to EBA FR I (substituting Idaho for Utah), EBA
FR 6, and AFRs | -20 (i.e. all AFR responses).
Request No 20: Reference Meredith Exhibit 2: Please explain why the current
ECAM revenues in the reference exhibit of $12,144,000 are materially less than the
$16,147,000 of revenues that were approved in Docket No PAC-E-21-09.
Request No 21: Please provide MWH sales by rate schedule over the 202I Deferral
period.
Request No 22: Please provide PacifiCorp's forecast MWH sales on a monthly
basis by rate schedule over the period May 2022 through July 2023.
Request No 23: Please provide PacifiCorp's unbilled revenues and MWH sales by
month for each rate schedule n2021.
Request No 24: Please explain how unbilled revenues were considered in the
calculation of the ECAM deferral.
Page 4
59501.0001. 147 16788.1
PIIC I't Set of Production Requests to RMP, Case No. IPUC-E-21-09
Darpd this 28th day ofApril 2022.
Reepreftlty submitto4
fr^t^Lil;
Rooatdl,. Willians
Hawley Trorell Fnais & Hawley LLP
Attorneys forPIIC
Page 5
59501.0001.147 | €t E8.t
PtrC ls Sst of Production Requests to RMP, CssGNo. DUC'E-21-09