20220510PAC to PIIC 3-23.pdf

ROCKY MOUNTAIN
PO\AIER
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
May 10,2022
Ronald L. Williams, ISB No. 3034
Jonathan D. Wheatley, ISB No. I1537
Hawley Troxell Ennis & Hawley LLP
877 West Main Street
Boise ID, 83701
rwilliams@hawleytroxe ll.com (C)
iwheatlev@hawlytroxel l.com (C)
RE: ID PAC-E-22-05
PIIC Set I (l-24)
Please find enclosed Rocky Mountain Power's Responses to PIIC I't Set Data Requests 34, 6,
l5-18, 20-21, and23-24. The remaining responses will be provided separately. Also provided
via e-mail are the non-confidential Attachments. Confidential Attachments are provided via
BOX. Confidential information is provided subject to protection under IDAPA 3 I .0 I .0 1.067 and
31.01.01.233, the Idaho Public Utilities Commission's Rules ofProcedureNo.6T -lnformation
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,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Jan Noriyuki /IPUC [e-mail] (C)
Joseph Terry/IPUC i oseph. terr.v@puc. idaho. eov ( C )
Donn English/IPUC donn.en glish@puc. idaho. gov
Bradley Mullins/PIIC brm u I I ins@mwanalyti cs. com (C)
Val Steiner/ltafo s Conda, LLC Val. Ste i [e-mail] rr
Kyle Williams/BYU Idaho [e-mail]
Thomas J. Budge/Bayer [e-mail] (C)
Brian C. Collins/Bayer [e-mail] (C)
Greg Meyer lBay er [e-mail] (C)
PAC-E-22-05 / Rocky Mountain Power
May 10,2022
PIIC Data Request 3
PIIC Data Request 3
Please provide PacifiCorp's actual net power costs over the period 2017 through
2021. Please provide allwork papers 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.
Response to PIIC Data Request 3
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 2021 (January 1,2021
through December 31,2021). Notwithstanding the foregoing objection, the
Company responds as follows:
Please refer to Attachment PIIC 3-l which provides actual net power costs (NPC)
reports for 2017 through 2021. Please refer to Confidential Attachment PIIC 3-2
which provides the actual NPC database entries, along with their mapping and
fuel supply cost calculations for 201 7 through 2021 .
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-22-05 / Rocky Mountain Power
May 10,2022
PIIC Data Request 4
PIIC Data Request 4
Please provide PacifiCorp's actual net power cost, in the manner identified in
PIIC Data Request 3 (the prior request), but for calendar year 2022 through the
latest month available.
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 adjustment mechanism (ECAM) deferral
period relevant in this proceeding, namely calendar year 2021 (January 1,2021
through December 31,2021). Notwithstanding the foregoing objection, the
Company responds as follows:
Please refer to Confidential Attachment PIIC 4 which provides the actual net
power costs (NPC) report for 2022 to-date (January 2022). Note: PacifiCorp's
actual NPC are confidential until the Federal Energy Regulatory Commission
(FERC) Form I for calendar year2022 has been filed with FERC (April 2023).
Please also refer to Confidential Attachment PIIC 4 which provides the actual
NPC database entries, along with their mapping and fuel supply cost calculations
for 2022 to-date (January 2022).
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 - 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-22-05 / Rocky Mountain Power
May 10,2022
PIIC Data Request 6
PIIC Data Request 6
Please provide transaction level detail supporting each and every gas purchase
and sale transaction, including furancial transactions, with deliveries or
settlements in the 2021 deferral Period. For each transaction, please provide all
available fields in PacifiCorp's energy hading system, including but not limited to
deal tracking number, instrument type, trade date, trade type, commodity type,
hading 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 defenal period.
Response to PtrC Data Request 6
Please refer to Confidential Attachment PIIC 6 which provides natural gas
physical transactions and natural gas financial transactions that were settled
during calendar year 2021.
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 any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Ray Zacharia
To Be DeterminedSponsor:
PAC-E-22-05 / Rocky Mountain Power
May 10,2022
PIIC DataRequest 15
PtrC Data Request 15
Please provide hourly power market prices at each market hub where PacifiCorp
transacts for the 2021 defenal period.
Response to PIIC Data Request 15
Please refer to Attachment PIIC 15 wtrich provides historical elecficity prices
(montlrly average) for calendar year 2021. Note: actual hourly electricity / market
prices constitute third party proprietary information for which the Company is
prohibited from providing to other ttrird parties in accordance with the Company's
subscription services agreements.
Recordholder:Lori Oathes / Geoffiey Brooks
To Be DeterminedSponsor:
PAC-E-22-05 / Rocky Mountain Power
May 10,2022
PIIC DataRequest 16
PIIC Data Request 16
Please provide hourly (or sub-hourly if available) generation logs for each of
PacifiCorp generation resources, including wind resources, for the 2021deferral
period.
Response to PIIC Data Request 16
Please refer to Confidential Attachment PIIC 16 which provides PacifiCorp's
hourly generation logs for PacifiCorp's owned hydro, thermal and wind resources
for calendar year 2021.
Confidential information is provided subject to protection under TDAPA
31.01.01.067 and 31.01 .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:Mary Kelly lCato Wagner,III
To Be DeterminedSponsor:
PAC-E-22-05 / Rocky Mountain Power
May 10,2022
PIIC DataRequest 17
PIIC Data Request 17
Please provide a log of outages for all thermal, wind, and hydro resources for the
deferral period.
Response to PtrC Data Request 17
Please refer to Confidential Attachment PIIC l7 which provides PacifiCorp's
outage logs for PacifiCorp's owned hydro, thermal and wind resources for
calendar year 2021.
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:Devin Hutchinson / Tom Hickey I Gavn Mangelson
To Be DeterminedSponsor:
P AC-E-22-05 / Rocky Mountain Power
May 10,2022
PtrC DataRequest l8
PIIC Data Request 18
For each NPC account, please provide a reconciliation between PacifiCorp's
financial accounting and FERC accounting.
Response to PIIC Data Request 18
Please refer to Attachment PIIC l8 which provides a reconeiliation as of
December 31,2021between PacifiCorp's financial accounting (as reported in
PacifiCorp's Securities and Exchange Commission (SEC) Form l0-K filing) and
PacifiCorp's Fede,ml Energy Regulatory Commission (FERC) Form l) fornet
power costs (NPC) accounts.
Recordholder: Catherine Dooekal
Sponsor:Jack Painter
PAC-E-22-05 / Rocky Mountain Power
May 10,2022
PIIC Data Request 20
PtrC Data Request 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 DocketNo PAC-E-21-09.
Response to PIIC Data Request 20
The approved final energy cost adjusfrnent mechanism (ECAM) revenue was
$l1,969,000 in CaseNo. PAC-E-21-09 (the202l ECAM for calendar year2020).
The difference between $12,144,000 and $l1,969,000 is due to the change in test
periods and billing determinants. The test period in Case No. PAC-E-21-09 was
the l2-months ended December 2014.The test period in this 20228C1+Mfor
calendar year 2021 is updated to be the adjusted l2-months ended December 2020
from the Company's last general rate case (GRC), Case No. PAC-E-21-07.
Recordholder: James Zhang
Sponsor:Robert Meredith
PAC-E-22-05 / Rooky Mountain Power
NIay 10,2022
PtrC DataRequest2l
PtrC Data Request 21
Please provide MWH sales by rate schedule over the2U2l Deferral period.
Response toPIIC Data Request2l
Please refer to Attaohment PIIC 2l which provides sales by rate schedule for
calendar yeat202l (in megawafi-hours (MWh)).
Recorrdholder:Mike McCoy
To Be DeterminedSponsor:
P AC-E-22-05 / Rocky Mountain Power
NIay 10,2022
PIIC Data Request 23
PIIC DataRequest23
Please provide PacifiCorp's unbilled revenues and MWH sales by month for each
rate schedule rn2021.
Response to PIIC Data Request 2.3
Please refer to Attachment PtrC 23 u,tioh provides the Company's unbilled
revenues and kilowaff-hour (klVh) sales by monflr for each revenue class in 2021.
Note: the Company does not have the unbilled revenues and kWh sales by month
for each rate schedule m2021.
Recordholder:Jarres Zhang
Robert MeredithSponsor:
PAC-E-22-05 / Rocky Mountain Power
Iv'f.ay 10,2022
PIIC Data Request 24
PtrC Data Request 24
Please explain how unbilled revenues were considered in the calculation of the
ECAM deferral.
Response to PIIC Data Requqt24
Unbilled retail revenue estimates are included in determination of Idaho retail
sales which are used in the Idaho energy cost adjustment mechanism @CAM)
calculation. PacifiCorp does not have the ability to read all Idaho retail customer
meters on the last day of each month so unbilled estimates are necessary to get
calendar month retail sales.
Recordholder:Doug Young
To Be DeterminedSponsor: