20180515PAC to Monsanto 1-26.pdf

3 ROCKY MOUNTAIN
POWER
A O|V|STON Or PACTFTCORP
RECE IVED
?0lBt{AY l5 Pt{ L: l6
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116ii-i,]'.l-:fi FIJALiC
i.iT ti-!i I ES f, Oi,4M ISSION
May I5, 2018
Randall C. Budge, iSB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE & BUDGE, CHARTERED
P.O. Box l39l; 201 E. Center
Pocatello, Idaho 83204-1391
[e-mail]
[e-mail]
RE: ID GNR-U-I8-01
Monsanto lsr Set Data Request (l-26)
Please find enclosed Rocky Mountain Power's Responses to Monsanto 1't Set Data Requests Ll-
l.2l and 1.24-1.26. AlsoprovidedareAttachmentsMonsanto 1.1 {l-2),1.2,1.3,1,A{l-3),
1 .5, 1.6, | .7 *(l-2), and 1.9 * (l -4).
If you have any questions, please feel free to call me at [phone]
Sincerely,
J,Wlllu,W"/A*
J. Ted Weston
Manager, Regulation
Enclosures
C.c. Joe Terry/[PUC j.gseph.teny@.ouc.idahq.gov (C)
Terri Carlock [e-mail]. gov (W)
Donn English Donn,[e-mail]. gov (W)
Brad Iverson-Long Brad.lversorl-Lone@puc. idaho. gov (W)
Brubaker & AssociatedlMonsanto [e-mail] [e-mail]
Eric L. Olsen/IIPA [e-mail]
Anthony Yankel/tlPA tony@yankell,.net
Ronald L. Williams/Pl IC ron@will iar.n_sbradbury. com
Bradley G. Mullins/?llC [e-mail]
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request l.l
Monsanto Data Request 1.1
Please produce work papers 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.
Response to Monsanto Data Request 1.1
Please refer to Attachment Monsanto I . 1- I and Attachment Monsanto 1. 1-2.
Recordholder: James Zhang
Sponsor: TBD
GNR-U-18-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.2
Monsanto Data Request 1.2
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.
Response to Monsanto Data Request 1.2
Please refer to Attachment Monsanto L2
The Company does not waive any potential objections related to the data request
responses included in the attachments.
Going forward, Monsanto will be provided copies of all outgoing data responses.
Recordholder: KaleyMcNay
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request L3
Monsanto Data Request 1.3
At page 6 of its March 30, 2018 filing, RMP refers to its "Results of Operations"
for the l2-month ended December 31,2016, 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.
Response to Monsanto Data Request 1.3
Please refer to Attachment Monsanto 1.3, which provides the Idaho results of
operations (ROO) jurisdictional allocation model (JAM) for the l2-months ended
December 31,2016, which was filed with the Idaho Public Utilities Commission
(IPUC) on April 28,2017.
Recordholder: Nick Highsmith
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15, 2018
Monsanto Data Request 1.4
Monsanto Data Request 1.4
Please provide the detailed work papers in native format with all formulas intact,
supporting each column on pages I and2 of Attachment I to RMP's March 30,
2018 filing.
Response to Monsanto Data Request 1.4
Work papers supporting pages I and2 of Attachment I are provided and
described as follows:
Please refer to Attachment Monsanto 1 .4- I , which provides the summary of tax
impacts on a total Company and Idaho basis.
Please refer to Attachment Monsanto 1.4-2, which provides the Idaho results of
operations (ROO) jurisdictional allocation model (JAM) for the 12-months ended
December 31,2016 using a 21 percent corporate federal tax rate used to calculate
the estimated tax impact to Idaho customers. In addition, please refer to the
Company's response to Monsanto Data Request 1.3, specifically Attachment
Monsanto 1.3, which provides the Idaho ROO JAM for the l2-months ended
December 31,2016 using a 35 percent corporate federal tax rate used to calculate
the estimated tax impact to Idaho customers.
Please refer to Attachment Monsanto 1.4-3, which provides the Idaho ROO JAM
for the 12-months ended December 31,2016 using a 2l percent corporate federal
tax rate used to calculate a theoretical tax impact to all PacifiCorp customers
using Idaho specific adjustments.
Recordholder: Nick Highsmith
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.5
Monsanto Data Request 1.5
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.
Response to Monsanto Data Request 1.5
Income taxes for financial purposes are calculated in the Federal Energy
Regulatory Commission (FERC) Form I and allocated according to the 2017
Protocol approved in Case PAC-E-15-16. Please refer to Attachment Monsanto
1.5, which provides a listing of and derivation of the allocation factors.
Recordholder: Nick Highsmith
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.6
Monsanto Data Request 1.6
Please provide the following regarding the individual accumulated deferred
income tax (ADIT) 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).
Response to Monsanto Data Request 1.6
(a) Please refer to Attachment Monsanto L6, which provides the year-end
accumulated deferred income taxes (ADIT) asset and liability account
balances as of December 31, 2016, as filed with the Idaho Public Utilities
Commission (IPUC) on April 28,2017 as part of the Idaho results of
operations (ROO) under "B-19 - Defened Income Tax Balance".
(b) Please refer to Attachment Monsanto L6.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request L7
Monsanto Data Request 1.7
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 2l%o.
(b) Identify the individual portions of subpart (a) that are, based on the Internal
Revenue Code/Treasury Regulations, "protected" (subject to Average Rate
As sump tion Method/am ortization/ flow-back) and tho se 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).
Response to Monsanto Data Request 1.7
(a) Monsanto Data Request 1.6 requests information related to accumulated
deferred income taxes (ADIT) balances as of December 31, 2016. As the tax
reform did not impact the ADIT balances as of December 37,2016,
calculating excess deferred income taxes (EDIT) based on December 31,2016
balances does not present relevant data for these proceedings.
(b) Please refer to the Company's response to subpart (a) above.
(c) Please refer to Attachment Monsanto 1.7 -l . In line with the 1986 tax reform
act, section 13001 of the 2017 tax act provides the normabzation requirements
of protected items, which are the EDIT on public utility property on
temporary differences that result from different depreciation methods and
Iives.
Please refer to Attachment Monsanto 1.7-2. Notice 87-82, 1987 CB 389
discusses the normalization treatment of contributions in aid of construction
(crAC).
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request L8
Monsanto Data Request 1.8
Please reference the excess individual ADIT balances provided in response to
Request No. l-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 amortization/flow-back of
protected 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 amortizatior/flow-back of excess ADIT in rates?
Response to Monsanto Data Request 1.8
(a) The Company anticipates the amortization period for the protected property-
related excess accumulated deferred income taxes (ADIT) to be the remaining
book depreciable life ofthe assets.
(b) The Company's estimates of annual amortization for the protected and non-
protected property-related items for 2018 through 2021is presented below.
The Company estimates that the amortization for periods after 2021 will be in
a similar range, however, these amounts cannot be accurately estimated at this
time.
Protected Non-Protected Total
201 8
20t9
2020
202t
(37,2s3,431)
(48,445,393)
(41,0e9,074)
(42,160,444)
(4,84s,62e)
(t0,945,623)
415,045
(6,884,489)
(42,099,060)
(59,391,016)
(40,684,029)
(49,044,933)
Total (168,958,342)(22,260,696)( 191,219,038)
(c) The Company's installation of the PowerTax fixed assets software is designed
to use the average rate assumption method (ARAM) to reverse the excess
deferred income taxes (EDIT) on all property-related items without distinction
between a protected or unprotected property-related item. Customized
changes would be required to be made by PowerTax to enable the system to
amortize the EDIT of unprotected property-related items under an alternative
method. Therefore, the Company proposes that the unprotected property-
related excess ADIT be amortized over the same period as the protected
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.8
property-related excess ADIT. Please refer to the Company's response to
subpart (a) above.
(d) The Company is currently working to calculate the full revenue requirement
impact associated with the 2077 tax reform legislation. Once the full impact,
including the excess ADIT, is known, the Company with work with all parties
to determine the best method to amortize/flow-back the excess ADIT.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.9
Monsanto Data Request 1.9
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.
Response to Monsanto Data Request 1.9
With regards to an updated response to Monsanto Data Request 1.3 - please refer
to Attachment Monsanto I .9- l, which provides the Idaho results of operations
(ROO) jurisdictional allocation model (JAM) for the 12-months ended December
31,2017, which was filed with the Idaho Public Utilities Commission (IPUC) on
April30,20l8.
With regards to an updated response to Monsanto Data Request 1.4 - please refer
to Attachment Monsanto 1.9-2, which provides the summary of tax impacts on an
Idaho basis.
Please refer to Attachment Monsanto 1.9-3, which provides the Idaho ROO JAM
for the l2-months ended December 31,2017 using a 2l percent corporate federal
tax rate used to calculate the estimated tax impact to Idaho customers. In addition,
please refer to the Company's response to Monsanto Data Request 1.9,
specifically Attachment Monsanto 1.9-1, which provides the Idaho ROO JAM for
the l2-months ended December 31,2017 using a 35 percent corporate federal tax
rate used to calculate the estimated tax impact to Idaho customers.
With regards to an updated response to Monsanto Data Request 1.5 - please refer
to the Company's response to Monsanto Data Request 1.5 as this information
would not change.
With regards to an updated response to Monsanto Data Request 1.6 - please refer
to Attachment Monsanto L9-4.
With regards to an updated response to Monsanto Data Request 1.7 - the
requested information is not yet available at this time because it is either more
complex in nature or requires additional guidance or information. The Company
will supplement the response once it obtains additional information necessary to
fully respond to the request.
With regards to an updated response to Monsanto Data Request 1.8 - the
requested information is not yet available at this time because it is either more
complex in nature or requires additional guidance or information. The Company
will supplement the response once it obtains additional information necessary to
fully respond to the request.
GNR-U-18-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.9
Recordholder: Nick Highsmith
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request L l0
Monsanto Data Request 1.10
The2017 Berkshire Hathaway Energy Form 10-K filed with the SEC states at
page2l4, in part, as follows:
"As a result of the 2017 Tax Reform, PacifiCorp reduced deferred income tax
liabilities 52,361million. 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 $2,361
million 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
taxrate? Ifnot, 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.
Response to Monsanto Data Request 1..10
(a) Amounts on an Idaho jurisdictional basis will be provided by June I 5, 20 I 8,
consistent with the tax stipulation in this case filed with the Commission on
May l l, 2018...
(b) The entire $2,358 million is associated with federal excess deferred income
taxes (EDIT).
(c) The regulatory liability is inclusive of the EDIT associated with accumulated
deferred income tax (ADIT) liabilities which have been included in rate base
and/or the deferred income tax expense which has been included in customer
rates. The $3 million difference relates to ADIT which have not been included
in rate base and/or deferred income tax expense.
(d) The $2,358 million is composed of $1,725 million of EDIT, $561 million of
an income tax gross-up on the EDIT, and $71 million adjustment to the
GNR-U-I8-01 / Rocky Mountain Power
May 15, 2018
Monsanto Data Request l.l0
income tax gross-up on the net regulatory asset existing prior to the income
tax rate change.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request l.l I
Monsanto Data Request 1.11
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.
Response to Monsanto Data Request 1.11
The Company objects to the request on the basis that it appears to be
contradictory in that it asks for the amount of the flow-back of "protected
property-related EDIT" but then defines that as the portion of property related
excess deferred income taxes (EDIT) "not protected" under the normalization
rules. Without waiving the objection and despite the contradiction, the Company
responds as follows:
Given the fact that the PowerTax is designed to use the average rate assumption
method (ARAM) to reverse the EDIT on all property-related items without
distinction between protected and unprotected property-related items, the 2018
amortization of EDIT on a total Company basis is estimated to be $42 million. Of
this amount, the Company estimates that $37 million relates to protected property-
related items and $5 million relates to unprotected property-related items.
The Company does not have the Idaho jurisdictional amounts at this time
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request I .12
Monsanto Data Request 1.12
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.
Response to Monsanto Data Request 1.12
This response is inclusive of both protected and non-protected property-related
excess deferred income taxes (EDIT) given the fact that that the PowerTax is
designed to use the average rate assumption method (ARAM) to reverse the EDIT
on all property-related items without distinction between protected or unprotected
property-related items. Based on the foregoing explanation, the Company
responds as follows:
The Company has recorded the amortization of property-related EDIT for 2018
year-to-date by spreading the 2018 amortization of EDIT in the amount of $42
million in accordance with Accounting Standards Codification (ASC) 740-270
which requires the use of an estimated annual effective tax rate applied to year-to-
date operating results. Specifically, the ratio of year-to-date pre-tax book income
over the forecasted 2018 annual pre-tax book income is multiplied by the 2018
EDIT of $42 million to arrive at the year-to-date amount to be recorded on a
monthly basis. This amount is recorded as a debit against the income tax
regulatory liability (established as of December 2017 in connection with the
change in the tax rate) and a credit to deferred income tax expense.
Correspondingly, a debit is made to retail revenues and a credit is made to
establish a regulatory liability which defers the benefit to return to customers.
The amount of the amortization that has been recorded through March 2018 with
respect to the property related EDIT is $8 million on a total Company basis.
The above amounts are on a total Company basis. The Company does not have
the Idaho jurisdictional amounts at this time.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.13
Monsanto Data Request 1.13
Is the Company recording the amortizatron of the protected property-related EDIT
under the ARAM method as a regulatory liability to return to customers? If no,
explain why not.
Response to Monsanto Data Request 1.13
Yes, the Company is recording the amortization of the protected property-related
excess deferred income taxes (EDIT) under the average rate assumption method
(ARAM) as a regulatory liability to return to customers as explained in more
detail in the Company's response to Monsanto Data Request 1.12.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.14
Monsanto Data Request 1.14
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.
Response to Monsanto Data Request 1.14
This response is inclusive of both protected and non-protected property-related
excess deferred income taxes (EDIT) given the fact that that the PowerTax is
designed to use the average rate assumption method (ARAM) to reverse the
excess deferred income tax on all property-related items without distinction
between protected or unprotected property-related items. Based on the foregoing
explanation, the Company responds as follows:
The Company's current best estimate of the flow-back of property-related EDIT
that will be recorded under the ARAM for each year,2019 through 2021 on a
total Company basis is $59 million, $41 million, and $49 million, respectively for
2019,2020 and202l. Of these amounts, the Company estimates that $48 million,
$41 million and$,42 million relate to the amortization protected property-related
items for 2019,2020, and2027, respectively.
The amounts referenced above are on a total Company basis. The Company does
not have the Idaho jurisdictional amounts at this time.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request L l5
Monsanto Data Request 1.15
Does RMP claim a repairs dedication for tax purposes associated with items that
have been capitalized for book purposes?
Response to Monsanto Data Request 1.15
Yes, the Company claims a repairs deduction for income tax purposes associated
with certain items that have been capitahzed for book purposes.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request l.l6
Monsanto Data Request 1.16
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.
Response to Monsanto Data Request 1.16
The Company uses the safe harbor method of accounting provided for in Revenue
Procedure 20ll-43,2011-37IRB 326, to determine whether expenditures to
maintain, replace or improve electric transmission and distribution property must
by capitalized under Internal Revenue Code (IRC) Section 263(a). Specifically,
the Company currently expenses incidental costs associated with the routine
repair and maintenance of its network assets based on the unit of property safe
harbor provisions of the Revenue Procedure including the gain or loss on
associated retirements.
The Company uses the safe harbor method of accounting to use the unit of
property and major component definitions provided for in Revenue Procedure
2013-24,2013-21 IRB 1 142, to determine whether expenditures to maintain,
replace or improve steam or electrical generation property must by capitalized
under IRC $ 263(a). Specifically, the Company currently expenses costs
associated with the routine repair and maintenance of its steam and electrical
generation assets based on the unit ofproperty safe harbor provisions ofthe
Revenue Procedure including the gain or loss on associated retirements.
The repair deduction is a non-protected item as it is a basis difference not defined
in the IRC or the regulations thereto.
The estimated excess deferred income tax (EDIT) expense as of December 31,
2017 related to the repair deduction is $255 million total Company.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request l.l7
Monsanto Data Request 1.17
Does RMP claim a maintenance deduction for tax purposes associated with items
that have been capitalized for book purposes?
Response to Monsanto Data Request 1.17
Before 2008, the Company claimed an Asset Depreciation Range (ADR) repair
allowance (maintenance) deduction for income tax purposes associated with
certain items that have been capitalized for book purposes. The ADR repair
allowance deductions claimed by the Company in taxable years before 2008 were
replaced by the Company's adoption of the income tax repair deduction as part of
the Company's change in the income tax method of accounting for income tax
repairs on the 2008 federal corporate income tax return. The deferred income tax
liability on the Company's books for the remaining pre-2008 ADR repair
allowance deductions is $11 million.
Recordholder: DeannaFladstol
Sponsor: TBD
GNR-U-18-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request l.l8
Monsanto Data Request 1.18
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,
Response to Monsanto Data Request 1.18
The Asset Depreciation Range (ADR) repair allowance deductions claimed by the
Company in taxable years before 2008 were superseded by the Company's
adoption of the income tax repair deduction as part of the Company's change in
the income tax method of accounting for income tax repairs on the 2008 federal
corporate income tax refurn.
The estimated excess deferred income tax (EDIT) liability remaining as of
December 31,2017 related to this "maintenance" deduction is $4 million total
Company.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request l.l9
Monsanto Data Request 1.19
Does RMP claim as a current tax deduction for periodic manufacturer upgrades to
capital equipment?
Response to Monsanto Data Request 1.19
No, the Company does not claim as a current tax deduction for periodic
manufacturer upgrades to capital equipment.
Recordholder: Deanna Fladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.20
Monsanto Data Request 1.20
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
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.
Response to Monsanto Data Request 1.20
Please refer to the Company's response to Monsanto Data Request 1 . I 9
Recordholder: DeannaFladstol
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request l.2l
Monsanto Data Request 1.21
Please provide a copy of the December 21,2077 S&P "Ratings Direct"
publication on Pacifi Corp.
Response to Monsanto Data Request 1.21
The "Ratings Direct" publication on PacifiCorp is proprietary to S&P Global,
Inc., and Rocky Mountain Power is not permitted to distribute it to third parties. A
"Ratings Direct" account may be required to obtain requested report from the
following website: https://www.globalcreditportal.com/ratingsdirect/Login.do.
Recordholder: Kristi Olsen
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.24
Monsanto Data Request 1.24
Please provide copies of the Rating Agency Reports referenced on page 9 of the
March 30, 2018 filing.
Response to Monsanto Data Request 1.24
The "Ratings Direct" publication "U.S. Tax Reform: For Utilities' Credit Quality,
Challenges Abound" dated January 24,2018, is proprietary to S&P Global, Inc.,
and Rocky Mountain Power is not permitted to distribute it to third parties. A
"Ratings Direct" account may be required to obtain requested report from the
following website: https://www.globalcreditportal.com/ratingsdirect/Login.do.
The Moody's Investor Service publication "Tax reform is credit negative for
sector, but impact varies by company" dated 24lantary 2018, is proprietary to
Moody's Investors Service., and Rocky Mountain Power is not permitted to
distribute it to third parties. A Moody's account may be required to obtain
requested report from the following website: www.moodys.com.
The Fitch publication "Tax Reform Impact on the U.S. Utilities, Power & Gas
Sector" dated January 24,2018 is proprietary to Fitch Ratings, and Rocky
Mountain Power is not permitted to distribute it to third parties. A Fitch Ratings
account may be required to obtain requested report from the following website:
www.fi coln.
Recordholder: Kristi Olsen
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.25
Monsanto Data Request 1.25
Please provide a copy of the Moody's report mentioned in the last paragraph on
page 9 of the March 30,2018 filing.
Response to Monsanto Data Request 1.25
The Moody's Investor Service publication "Tax reform is credit negative for
sector, but impact varies by company" dated 24 Jantary 2018, is proprietary to
Moody's Investors Service., and Rocky Mountain Power is not permitted to
distribute it to third parties. A Moody's account may be required to obtain
requested report from the following website: www.moodys.com.
Recordholder: Kristi Olsen
Sponsor: TBD
GNR-U-I8-01 / Rocky Mountain Power
May 15,2018
Monsanto Data Request 1.26
Monsanto Data Request 1.26
Please provide a copy of the three most recent reports on PacifiCorp issued by
each of the Rating Agencies.
Response to Monsanto Data Request 1.26
The "Ratings Direct" publications are proprietary to S&P Global, Inc., and Rocky
Mountain Power is not permitted to distribute it to third parties. A "Ratings
Direct" account may be required to obtain requested report from the following
website : https ://www. globalcreditportal.com/ratin gsdirect/Lo ein.do.
The Moody's Investor Service publications are proprietary to Moody's Investors
Service., and Rocky Mountain Power is not permitted to distribute it to third
parties. A Moody's account may be required to obtain requested report from the
following website: www.moodys.com.
The Fitch publications are proprietary to Fitch Ratings, and Rocky Mountain
Power is not permitted to dishibute it to third parties. A Fitch Ratings account
may be required to obtain requested report from the following website:
www.fitchratings.com.
Recordholder: Kristi Olsen
Sponsor: TBD