20180424Monsanto 1-26 to PAC.pdf

Randall C. Budge,ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, }.ITE & BUDGE, CHARTERED
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1 39 I
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
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IN THE MATTER OF THE
APPLICATION REQUESTING
AUTHORITY TO REDUCE RETAIL
RATES BY $2.8 MILLION TO PASS A
PORTION OF THE 2017 FEDERAL TAX
REFORM ACT COST SAVINGS ONTO
CUSTOMERS
CASE NO. GNR.U.18.O1
MONSANTO COMPANY'S FIRST
SET OF DATA REQUESTS TO
ROCKY MOUNTAIN POWER
MONSANTO COMPANY, by and through their attorneys, hereby submits this First Data
Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utility Commission=s
Rules of Procedure,IDAPA 31.01.01, as follows:
Request No. 1: Please produce workpapers supporting your proposed plan to provide
customers the appropriate benefits of the Tax Cut and Jobs Act of 2017, and the development of
any tariffs. Please provide executable versions of the responsive documents in native format
with all formulas intact.
Request No. 2: Please provide copies of responses to all data requests (whether formal or
informal) that have been supplied to date and continue to do so when additional information is
supplied to other parties. To the extent applicable, please provide executable versions in native
format with all formula intact and include workpapers.
Request No.3: At page 6 of its March 30, 2018 filing, RMP refers to its "Results of
Operations" for the l2-month ended December 31,2076, that was filed with the Commission on
April 30, 2017. Please provide, in native format with all formulas intact, the total PacifiCorp
results and the detail of the allocation of each item to RMP-Idaho.
MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY
MOUNTAIN POWER - 1
Request No.4: Please provide the detailed workpapers in native format with all formulas
intact, supporting each column on pages I and2 of Attachment I to RMP's March 30,2018
filing.
Request No. 5: Please explain and provide details of how RMP-Idaho income taxes are
calculated and/or allocated from PacifiCorp's total financial reports. Please provide a narrative
description and the detail of the derivation of all allocation factors and all tax calculations.
Request No.6: Please provide the following regarding the individual accumulated
deferred income tax ("AD[T") asset and liability account balances, for total PacifiCorp and for
Idaho in working Excel format, including all supporting documentation:
a. The individual account and subaccount numbers, descriptive account and subaccount
number titles and account balances at December 31,2016, separated by federal and
state income taxes.
b. As explanation of the tax events/transactions that gave rise to each of the balances
provided in response to subpart (a).
Request No. 7: Please reference the individual ADIT balances provided in response to
Request No. l-6 and provide the following, in working Excel format, including all supporting
documentation:
a. Identify the portion of each ADIT account and subaccount that is an excess balance,
based on the new federal income tax rate of 2lo/o.
b. Identify the individual portions of subpart (a) that are, based on the Internal Revenue
Code/Treasury Regulations, "protected" (subject to Average Rate Assumption
Method/amortization/fl ow-back) and those that are "unprotected;" and
c. Provide specific cites to Treasury Regulations and other authoritative text that support
the categorization of the ADIT balance as protected and unprotected in subpart (b).
Request No. 8: Please reference the excess individual ADIT balances provided in
response to Request No. 1-7 and provide the following in working Excel format, including all
supporting documentation:
a. Over what period of time does the Company anticipate amortization/flow-back will
occur for the protected excess ADIT?
b. What are the anticipated amounts of annual amortrzation/flow-back of protected
MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY
MOUNTAIN POWER. 2
excess ADIT, for 2018 and forward annually?
c. Over what period of time does the Company propose amortization/flowing back the
unprotected excess ADIT?
d. What is the Company's plan for reflecting the revenue requirement impacts of the
amortization/flow-back of excess ADIT in rates?
Request No.9: Please update your response to Requests Number 3 through 8 in
connection with future "Results of Operations" filings with the Idaho PUC, including for 2017.
Request No. l0: The 2017 Berkshire Hathaway Energy Form l0-K filed with the SEC
states at page 274, in part, as follows:
"As a result of the 2017 Tax Reform, PacifiCorp reduced deferred income tax liabilities $2,361
million. As it is probably the change in deferred taxes will be passed back to customers through
regulatory mechanisms, PacifiCorp increased net regulatory liabilities by $2,358 million."
a. Please provide the $2,358 million on an Idaho jurisdictional basis.
b. Please provide a breakdown of the $2,358 million between amounts associated with
federal excess deferred income taxes and state excess deferred income taxes (if any
state EDIT exists). Provide these amounts on a total PacifiCorp and on an Idaho
jurisdictional basis. If the combined amount of the state and federal excess deferred
income taxes do not equal either $2,361million or $2,358 million, explain in detail
why not.
c. Please explain why the net regulatory liability is $3 million less than the reduction in
the deferred income tax liabilities.
d. Is either the $2,361 million or the $2,358 million equal to the amount of excess
deferred income taxes resulting from the change in the federal income tax rate? If
not, please reconcile the difference between the excess deferred income taxes and
both the reduction in the deferred income tax liabilities and the increase in net
regulatory liabilities.
Request No. 11: Please provide the amount of flow-back of the protected property-
related EDIT (i.e., portion of property-related EDIT not protected under the normalization rules)
that will be recorded during 2018 under the ARAM on a total PacifiCorp and on an Idaho
jurisdictional basis. Please provide this by month, if available by month.
MONSANTO COMPANY'S FIRST SET OF DATA REQUESTS TO ROCKY
MOUNTAIN POWER. 3
Request No. 12: Please explain, in detail how the Company has been recording the
amortization of the protected property-related EDIT (i.e., portion of property-related EDIT
protected under the normalization rules) for 2018 year to date (i.e., recorded in a regulatory
liability account, etc.). Additionally, please provide the amount of amortization of the protected
property-related EDIT under the ARAM that has been recorded to date on a total PacifiCorp and
on an Idaho jurisdictional basis.
Request No. 13: Is the Company recording the amortization of the protected property-
related EDIT under the ARAM method as a regulatory liability to return to customers? If no,
explain why not.
Request No. 14: Please provide the Company's current best estimate of the flow-back of
the protected property-related EDIT (i.e., portion of property-related EDIT protected under the
normalization rules) that will be recorded under the ARAM for each year,2019 through 2021 .
Provide the amounts on a total PacifiCorp and on an Idaho jurisdictional basis.
Request No. 15: Does RMP claim a repairs dedication for tax purposes associated with
items that have been capitalized for book purposes?
Request No. 16: If RMP claims repairs as a deduction for tax purposes, please provide a
copy of the policy or practice describing the accounting guidelines used to claim these tax
deductions; explain whether RMP contends these amounts are unprotected or protected; explain
why RMP so contends, providing all supporting documentation and references; and give an
estimate of the value of this amount.
Request No. 17: Does RMP claim a maintenance deduction for tax purposes associated
with items that have been capitalized for book purposes?
Request No. 18: If RMP claims a maintenance deduction for tax purposes, please
provide a copy of the policy or practice describing the accounting guidelines used to claim these
tax deductions; explain whether RMP contends these amounts are unprotected or protected;
explain why RMP so contends, providing all supporting documentation and references; and give
an estimate of the value of this amount.
Request No. 19: Does RMP claim as a current tax deduction for periodic manufacturer
upgrades to capital equipment?
Request No.20: If RMP claims as a current tax deduction, periodic manufacturer
upgrades to capital equipment, please provide a copy of the policy or practice describing the
MONSANTO COMPANY'S FIRST SET OF DATA R-EQUESTS TO ROCKY
MOUNTAIN POWER - 4
accounting guidelines used to claim these tax deductions; explain whether RMP contends these
amounts are unprotected or protected, explain why RMP so contends, providing all supporting
documentation and references; and give an estimate of the value of this amount.
Request No.21: Please provide a copy of the December 21,2017 S&P "Ratings Direct"
publication on PacifiCorp.
Request No. 22: Please provide projections for 2018, 2019 and 2020 of FFO/Total Debt,
Debt/EBITDA and FFO cash interest coverage, all calculated consistent with the calculations in
the S&P report referenced in Monsanto's Request No. 21, above, assuming:
a. No rate changes;
b. A S10.35 million rate reduction;
c. A $10.35 million rate reduction and a retum to customers of an ARAM compliant
share of protected excess ADIT; and
d. Same as (c) plus a return to customers over five years of the unprotected excess
ADIT.
Request No. 23: Please update your response to Request No. 22based on2017 Results
of Operations.
Request No.24: Please provide copies of the Rating Agency Reports referenced on page
9 of the March 30,2018 filing.
Request No.25: Please provide a copy of the Moody's report mentioned in the last
paragraph on page 9 of the March 30, 2018 filing.
Request No.26: Please provide a copy of the three most recent reports on PacifiCorp
issued by each of the Rating Agencies.
DATED this 24th day of April,20l8.
RACINE, OLSON,IVYE
& BUDGE, CHARTERED
D,futl c.e/*
RANDALL C. BUDGE
MONSAI{TO COMPAIYY',S FIRST SET OF DATA REQUESTS TO ROCKY
MOUNTAIN POWER. 5
By:
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 24th day of April,2Ol8,I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Diane Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: diane.holt@ouc. idaho. eov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
salt l^ake city, utah 84116
Telephone: [phone]
Email: ted.weston@pacifi corp.com
Yvonne R. Hogle,
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt [^ake city, utah 84116
Telephone: [phone]
Email: yvonne.hogle@pacifi corp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
datarequest@pacifi corp. com
Brubaker & Associates
16690 Swingley Ridge Rd #140
Chesterfield, MO 63017
[e-mail]
kiverson@consultbai. com
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RANDALL C. BUDGE
MONSAI\TO COMPAM'S FIRST SET OF DATA REQUESTS TO ROCKY
MOUNTAIN POWER - 6