20110314ICIP 16 to IPC.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (lSB # 7454)
Richardson & O'Lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter($richardsonandoleary.com
greg($richardsonandolear .com
Idaho PU~/ic Utilties .
Office of the s Commission
R E Cl: I v~fltary
MAR 1 + 2011
Boise, Idaho
Attorneys for the Industral Customers of Idaho Power
BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S REQUEST FOR
ACCEPTANCE OF ITS 2011
RETIREMENT BENEFITS PACKAGE
)
) CASE NO. IPC-E-1O-25
)
) SECOND PRODUCTION REQUEST
) OF THE INDUSTRIAL CUSTOMERS
) OF IDAHO POWER
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industral Customers of Idaho Power ("ICIP") hereby requests that
Idaho Power Company ("Idaho Power") provide responses to the following with supporting
documents, where applicable. Please follow the instrctions set fort in ICIP's First Production
Request in ths docket.
Page 1 ~ SECOND PRODUCTION REQUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER-IPC-E-IO-25
REQUEST FOR PRODUCTION NO. 16
In Idaho Public Utilties Commission Order 31003, Case No. IPC-E-09-29, the Commssion said,
"We authorize the clarified treatment of defined pension expense as detailed above in our
summar of the Company s reply. We find this approach satisfies the SFAS 71 requirements.
Furthermore, we adopt the four points of clarification requested by the Company in its reply
comments, as set forth above." (p. 11.)
And, as set forth above;
"While the Company continues to believe that its proposed tracking mechanism better matcnes
recovery of pension costs with the Company's cash outlays to fund the pension, the Company is
not opposed to the recommendations included in Staff's comments as clarfied in the Company's
reply. Further, the Company is satisfied that Staffs proposed methodology would meet the
deferral requirements of SF AS 71. Should the Commission choose to adopt Staff s
recommendations, the Company requests that the Commission provide the following
clarifications:
1. The regulatory asset account previously authorized for the deferrl of cash
contributions wil be considered a balancing account for the purpose of tracking the
difference between cumulative cah contributions to the pension plan and amounts
recovered in rates; and
2. The timing of the amortiztion of the deferred cash contributions as well as the
amounts wil be matched to the collection of those costs in rates; and
3. The amounts contrbuted in excess of the ERISA minimum, while potentially subject
to longer amortization, wil not be disallowed solely because they are made sooner than
they are legally required to be paid; and
4. The unamortized balance of deferred cash contrbutions wil ear a caring charge at
the Commission-approved interest rate for deposit. (p. 10.)
Please provide, for the next 20 years a forecast for each year of the 20 year period, the dollar
amount of the regulatory asset balancing account under the assumption of, A) the Company's
proposed pension plan set forth in its Application in IPC-E-I0-25, and B) beginning in 2012 all
new employees pensions will be based on a defined contribution plan rather than defined
benefits. For each of these two scenaos please assume a retu on the regulatory asset balancing
account equal to the "Best Case" and "Worst Case" for 5 Years as shown in Char 4 "Projected
Investment Retus Over Time vs. Actual Assumption Based on Curent IPCO Target
Allocation" found on page 6 of 11 of the Company's "Supplemental Report: Retirement Benefits
Risk Analysis" file in this Docket on Febru 20,2010.
Please provide this analysis in electronic format and state the assumptions of retu, pension
payments to retirees, and the Company expected contributions to the balancing account, under
both the A and B scenarios listed above.
Page 2 - SECOND PRODUCTION REQUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER-IPC-E-IO-25
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ths 14rd day of March, 2011, I caused a tre and
correct copy of the foregoing SECOND PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER to be served by the method indicated below, and
addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street (83702)
Post Offce Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(x) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Lisa Nordstrom
Donovan Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnght Mail
( ) Facsimile
(x) Electronic Mail
Gregory W. Said
Tim Tatum
Idaho Power Company
POBox 70
Boise, ID 83707
(x) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
QL
M. Adams
Page 4 - SECOND PRODUCTION REQUEST OF THE INUSTRIL
CUSTOMERS OF IDAHO POWER -IPC-E-I 0-25
Than you for your prompt attention to ths Second Request for Production.
~
Gre ory M. Adams
RICHARDSON & O'LEARY, PLLC
Page 3 - SECOND PRODUCTION REQUEST OF TH INDUSTRIL
CUSTOMERS OF IDAHO POWER-IPC-E.IO..25