20110728Staff 77-139 to IPC.pdf

DONALD L. HOWELL, II
KARL T. KLEIN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720~0074
(208) 334~0312
IDAHO BAR NOS. 3366/5156
RECEIVED
ioii JUL 28 PM 2: 15
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702~5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE IN IDAHO. )
)
)
)
CASE NO. IPC~E~11~8
FIFTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorneys of record,
Donald L. Howell, II and Karl T. Klein, Deputy Attorneys General, requests that Idaho Power
Company (Company; IPC) provide the following documents and information as soon as possible,
but no later than THURSDAY, AUGUST 18,2011.
This Production Request is to be considered as continuing, and the Company is requested to
provide, by way of supplementar responses, additional documents that it or any person acting on
its behalf may later obtain that wil augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of the
person preparng the documents. Please identify the name, job title, location and telephone number
of the record holder.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 28, 2011
In addition to the wrtten copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 77: Page 8 of Exhibit 20 (Forecast Methodology Manual prepared at
Witness Tatum's direction) states that Miscellaneous Service Revenues were "projected for 2011 to
be the same as the 12 month actual ended December 2010 Base." Please provide a 5~year historical
schedule of this account by month.
REQUEST NO. 78: Page 8 of Exhibit 20 states: "Substation equipment rentals,
transformer and distribution rentals, station and line rentals, real estate rents, dark fiber rents, joint
pole attachments, overnight park rents were forecasted to be the same as the 2010 Base." Please
provide a 5-year historical schedule of these accounts by month.
REQUEST NO. 79: Please provide a 5~year historical schedule of the cogeneration and
small power production revenues and facilities charge revenues amounts by account by month.
REQUEST NO. 80: Page 8 of Exhibit 20 states that cogeneration and small power
production revenues 2010 Base was "increased for thirteen new wind projects that have or will
come on~line in 2011."
a) Please identify each wind project and provide the actual on~line or expected on~line date
for each.
b) Please also provide workpapers showing the calculations behind the increase from the
2010 Base.
c) Please provide workpapers and explanations for how it was determined that an anual
growth rate of 4.5% should be used.
REQUEST NO. 81: Page 9 of Exhibit 20 states that facilty charge revenues are reviewed
intermittently and "IPC determined that the rate should be decreased based on the current
methodology." Please provide a copy of the most recent reviews. Was the "curent methodology"
used the same as the methodology the Company used in the last rate case?
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 28, 2011
REQUEST NO. 82: Page 9 of Exhibit 20 states that "revenues related to the photovoltaic
station service, Antelope substation, Sierra stand~by service, and miscellaneous were projected for
2011 to be the same as the 2010 Base." Please provide a 5-year historical schedule by month of
these accounts.
REQUEST NO. 83: Please provide a 5~year historical schedule of the 2011 Network
Transmission Customer revenues and the 20 11 point~to~point wheeling revenues.
REQUEST NO. 84: Page 9 of Exhibit 20 describes how the'Company calculated the 2011
Network Transmission Customer revenues.
a) Please provide all workpapers for this calculation in electronic format with formulas
intact.
b) Please provide a schedule and explanation of how the 2 MW increase for new customer
demand was determined.
REQUEST NO. 85: Page 9 of Exhibit 20 describes how the Company calculated the 201 i
point~to-point wheeling revenues were calculated. Please provide all workpapers for this
calculation.
REQUEST NO. 86: Page 9 of Exhibit 20 states that "Valmy usage is not expected to
exceed capacity; therefore no revenues from Sierra Pacific Power Usage are expected." Please
provide a 3~year historical schedule of usage for Valmy.
REQUEST NO. 87: Please provide the workpapers, and all detail necessary to verify all of
the deferred income tax items in Witness Jones' Exhibit No. 14, page 21 of23, pertaining to
Accumulated Deferred Income Taxes.
REQUEST NO. 88: Reference Exhibit 20, page 11,2011 Labor Expense of$133 Milion.
a) Please provide supporting documentation for the labor allocations.
b) Please show how this amount is allocated to all accounts and identify each account
number.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JULY 28, 2011
c) Please provide the most current update (year~to~date) of the 2011 Labor Expenses table,
including the three~year historical average percentage.
d) Identify months where there are extra pay periods (3 vs 2) in the three~year average and
2011.
e) If there are extra pay periods, what was done to insure the periods are comparable?
The following questions (Nos. 89-139) are in reference to "2011 O&M Non-Labor Expenses"
from Witness Tatum's Exhibit No. 20, page 11.
REQUEST NO. 89: Please provide any and all workpapers, emails, spreadsheets, cost
estimates, contracts and any other supporting documentation for the following items. Include in
your response all studies and assumptions used in estimating the expenses. For items not expected
to recur in 2012, or for items that are not normally recurring, please provide information about the
timing of the event, for example, if the expense is for a survey, how often is the survey expected to
be performed and how often is the survey required. In addition, please include a description of each
item, and the benefits each item provides to ratepayers.
a) Thermal O&M Increases from Operating Parners.
b) Bennett Mountain - 2011 Combustor Inspection
c) NERC Required LIDAR Sureys
d) BLM Rate increase - Land Rents
e) Idaho Fish and Game's Projected Hatchery Increases
f) Increased IT maintenance Expenses
g) Special Reliability Projects ~ Transmission
REQUEST NO. 90: Please provide a printout of all expenses charged to Accounts 920,
921,923,925,926,928,930,931 and 935 during 2009, 2010 and 2011 to date and continuing when
available. Please include amounts paid, vendor, date, and a brief explanation of the expense. This
information should be provided on CD in Excel format with all formulas intact.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JULY 28, 2011
REQUEST NO. 91: Please provide a schedule of Contributions in Aid of Construction
(CIAC) as of December 31, 2010 showing names, dates, amounts and accounts used. Please
include within your response any significant changes to CIAC occurring in, or planed for 2011.
REQUEST NO. 92: Please provide a schedule of Customer Advances for Construction for
the year ending 2010 showing names, dates, amounts and accounts used. Please include within
your response any significant changes to Advances occuring in, or planned for 2011.
REQUEST NO. 93: Please provide an analysis of the sale of land and plant for the years
2010 and 2011 to date. Please show gains, losses and supporting documentation including
accounting entries for removal of items from rate base.
REQUEST NO. 94: Please provide details of any planed sales of land and/or plant for the
remainder of 20 11. Please include within your response the estimated date of these sales and
planed treatment (including accounting entries) for them.
REQUEST NO. 95: Please provide a list of "out~of-period adjustments" and
"extraordinary items" for the years 2010 through 2011 to date and continuing when available.
REQUEST NO. 96: Please provide a list of all pending legal cases and their status
including description of the issue, estimates ofliability and possible ramifications to the Company.
REQUEST NO. 97: Please provide the amounts spent for injures and damages for the
years 2010 to date. Please include within your response the description of each item, the amount for
each item and the account charged.
REQUEST NO. 98: Please provide detail of all advertising expenses recorded above the
line including account and subaccount where posted, dates posted, vendor names, explanations, and
amounts posted during 2010. Please identify each expense that is related to safety. In addition,
please provide copies of the ads used during 2010 and correlate the ad copy with the specific detail
provided in this production request response.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 JULY 28, 2011
REQUEST NO. 99: Please provide a list of all consultants who performed services for
Idaho Power for the years 2009 to date. Please include within your response the services
performed, amounts paid, the accounts charged, the allocation factor and amount allocated to the
Idaho jurisdiction.
REQUEST NO. 100: Please provide copies of all internal audit reports for the years 2008,
2009,2010 and 2011 to date and continuing when available.
REQUEST NO. 101: Please provide a description of all audits/organizational reviews
curently in progress or planed through 2012 year~end. Please include within your response the
description of reviews that are currently underway for which no report has been issued and the
estimated report date.
REQUEST NO. 102: Please provide a copy of the policy for bad debt write-offs and
collection of past due amounts.
REQUEST NO. 103: Please provide a schedule of bad debt amounts for 2010 and 2011 to
date and continuing when available.
REQUEST NO. 104: Please provide the amounts spent for injuries and damages for the
years 2010 and 2011 to date and continuing when available. Please include within your response
the description of each item, the amount for each item and the account charged.
REQUEST NO. 105: Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division and
company. Please include within your response the dollar level at which individual capital
expenditure projects require approval by the Board of Directors.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 JULY 28, 2011
REQUEST NO. 106: Please provide a detailed listing of all entries to Account 451 -
Miscellaneous Service Revenues for the years 2010 and 2011 to date and continuing when
available.
REQUEST NO. 107: Please provide a detailed listing of all entries to Account 454 - Rent
from Electric Property years 2010 and 2011 to date and continuing when available.
REQUEST NO. 108: Please provide a detailed listing of all entries to Account 456 - Other
Electric Revenues for the years 2010 and 2011 to date and continuing when available.
REQUEST NO. 109: Please prepare a narrative showing the monthly, quarterly and annual
comparison of operating and capital budgets to actual expenditures for the years 2010 and 2011 to
date and continuing when available. Please include within your response any narative explanations
for budget variations. This should include, but not be limited to, written operating and capital
budget variance reports and explanations used by Company offcers and managers to monitor and
control budgets under their areas of responsibility.
REQUEST NO. 110: Please provide copies of the monthly, quarerly, and anual
presentations to the Company's Executive Board and Chief Executive and Operating Offcers for
2010 and 2011 to date and continuing when available. Please include within your response a paper
copy of any slides and notes used in such presentations.
REQUEST NO. 111: Please provide the Company's monthly operating and financial
reports for each month from Januar 2010 to date and continuing when available. These should be
in the most detailed format possible and should include all attached supporting schedules and
analysis received by management.
REQUEST NO. 112: Please provide a copy of each adjusting joural entry proposed by
the Company's independent auditors in the two (2) most recent audits of the Company. Please
include within your response the documentation supporting these adjustments and documentation
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 7 JULY 28, 2011
supporting any items that were "passed upon" and not reflected in the Company's financial records
and/or financial statements.
REQUEST NO. 113: Please provide a current organization chart showing names of
employees and their titles that includes all managers and executives. Please include within your
response how this organization char changed or is expected to change during 2010 and 2011.
For each offcer of the Company, please provide the following:
a) Total dollar amount of remuneration for 2010 and 2011 with the amounts separated by
salary, incentive pay, options, benefits and other.
b) The percentages of his or her total remuneration that is allocated to other subsidiaries
along with the basis for that allocation.
c) Please provide all offcers' salaries for 2008 through 2011 for each officer by month, and
please itemize by base salar, bonuses, and benefits, along with the amount included in
test year and the amount paid for by shareholders.
REQUEST NO. 114: Please provide the total number of employees and employee
expenses by account and in total for the last two (2) years as well as the budgeted amounts for 2011.
REQUEST NO. 115: Please provide both federal and state quarerly and annual payroll tax
reports for the year ending 2010.
REQUEST NO. 116: Please provide all documents supporting budgeted and actual wage
increases for all employees durng 2009 through 2011 by year. Please include within your response
the number of employees (budgeted and actual) to which these wage increases applied and their
associated salaries pre and post wage increase.
REQUEST NO. 117: Please provide the anualized O&M salary as of December 31,2009
and December 31,2010.
REQUEST NO. 118: Please provide all officers' employee numbers, names, job titles,
detailed job descriptions, responsibilties, base salaries, and other compensation by year since 2008.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 8 JULY 28, 2011
REQUEST NO. 119: Please explain the basis for all offcers' salar increases from the
2010 level to the 2011 leveL. Also, please provide all documents that are relevant to this inquiry.
REQUEST NO. 120: Please provide a copy of all Company policies and other relevant
materials provided as an "employee handbook" for the Company's employees. If the employee
handbook is only available on the Company's intranet, please provide access to the Company's
employee handbook on the company intranet.
REQUEST NO. 121: Please provide a copy of the Company's P-card policy. Please
highlight any changes to the policy that have occurred since the last general rate case.
REQUEST NO. 122: Please provide a schedule showing all P~card purchases, advances
and other charges, by FERC account for the years 2010, and 2011 to date.
REQUEST NO. 123: Please provide the total dollar amount of P~card purchases, advances
and other charges for 2008 and 2009.
REQUEST NO. 124: Please provide access to the documentation for all P~card purchases,
advances, and other charges to the P-card for the year 2010.
REQUEST NO. 125: Please provide the total amount spent on food, meals, snacks, coffee,
and bottled water for the year 2010 and 2011 to date. Please provide this information by month, by
FERC account, and by category, such as coffee, meals, bottled water, meeting snacks, etc.
REQUEST NO. 126: Please provide copies of the employee newsletters issued during
2010, and 2011 to date.
REQUEST NO. 127: Please provide a listing of all penalties and fines included in the test
year, citing the account it is located in, the payee, and the amount.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 9 JULY 28, 2011
REQUEST NO. 128: Please provide a listing of any costs included in the test year related
to sporting or entertainment events, including but not limited to season tickets or sky boxes.
Provide the accounts where these costs are booked and if above the line and not already removed in
this fiing, please include any and all explanations as to the business purose.
REQUEST NO. 129: Please provide a listing of all charitable contributions, including
names, amounts and account numbers included in the test year. Please include all accounts other
than account 930, where charitable contributions are also booked.
REQUEST NO. 130: Please provide a listing of licenses paid for by the Company, such as
PE, CPA, Legal, etc. included in the test year by FERC account and sub-account included in the test
year.
REQUEST NO. 131: Please provide the audit workpapers from the external auditors for
2010.
REQUEST NO. 132: Please provide the Board of Director minutes, including all material
distributed and/or discussed at the meetings, including but not limited to external reports, committee
reports, handouts, chars, etc. for the years 2010 and 2011 to date.
REQUEST NO. 133: Please provide a schedule showing 2009,2010, and 2011 to date
monthly balances for the materials and supplies subaccounts. Please include within your response
the descriptions of the accounts, the amounts in each account and the turover ratios for each
account.
REQUEST NO. 134: Please provide a list of all leased items in 2010 and to date in 2011.
Please separately identify those leases historically accounted for as capital leases and operating
leases. Please include within your response the dates, terms, amounts and accounts used for each
lease.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 10 JULY 28, 2011
REQUEST NO. 135: Please provide copies of the Company's most recent cost allocation
manuals.
REQUEST NO. 136: For each of the plant additions listed on Witness Noe's Exhibit No.
22 (Major Plant Additions Annualized for 2011), please provide the following information
separately for each project: invoice number, description of payment, vendor name, date posted and
amount, for inception of project to date.
REQUEST NO. 137: Please provide an updated Exhibit No. 22 using month end June
2011 information.
REQUEST NO. 138: Please identify the costs included within the filing that are associated
with any projects that have been abandoned. Please include within your response the amount and
accounts posted along with the applicable allocation factors.
REQUEST NO. 139: Please provide a list showing a sumar of all consultants and
attorneys (internal and external) who performed services for the Company or who were paid by the
Company for 2010 that are included in the test year. For all attorneys, show services performed,
amounts paid, and accounts charged. If services were performed in support of a docketed
federal/state cour or regulatory agency action, please identify the case name, case number and
jurisdiction. If studies were the result of any of these payments, please provide a copy of those
studies.
r- .1LDATED at Boise, Idaho, this ¿~ day of July 2011.
1!'lLKarl T. Kléf
Deputy Attorney General
Technical Staff: Shelby Baker177-86
Kathy Stockton/87-139
i:umisc:prodreq/ipce i i ,8dhkk prod req 5
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 11 JULY 28, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF JULY 2011,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC~E~11-08, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
DONOV AN E WALKER
JASON B WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707~0070
E~MAIL: lnordstrom(fidahopower.com
dwalker(fidahopower .com
j wiliams(fidahopower.com
CBear(fidahopower .com
myoungblood(fidahopower.com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E~MAIL: peter(frichardsonandoleary.com
greg(frichardsonandolear.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(fracinelaw.net
ARTHUR PERRY BRUDER
ATTORNEY-ADVISOR
US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E~MAIL: Arthur.bruder(fhg.doe.gov
E-MAIL ONLY:
STEVE A PORTER
US DEPT OF ENERGY
E-MAIL: steven.porter(fhg.doe.gov
GREGORY W SAID
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707~0070
E~MAIL: gsaid(fidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(fmindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyankel.net
DWIGHT ETHERIDGE
EXETER ASSOCIATES
10480 LITTLE PATUZENT PKWY
STE 300
COLUMBIA MD 21044
E-MAIL: detheridge(fexeterassociates.com
JOHN R HAMMOND JR
BATT FISHER PUSCH
& ALDERMAN LLP
PO BOX 1308
BOISE ID 83701
E~MAIL: jrhrmbattfisher.com
CERTIFICATE OF SERVICE
KURT JBOEHM
BOEHM KURTZ & LOWERY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E~MAIL: kboehm(fbkllawfirm.com
RICHARD E MALMGREN
SR ASST GENERAL COUNSEL
MICRON TECHNOLOGY INC
800 S FEDERAL WAY
BOISE ID 83716
E-MAIL: remalmgren(fmicron.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E~MAIL: bmpurdy(fhotmail.com
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E~MAIL: kmiler(fsnakeriveralliance.org
KEVIN HIGGINS
ENERGY STRATEGIES
215 S. STATE ST SUITE 200
SALT LAKE CITY UT 84111
E~ MAIL: khiggins(fenergystrat.com
MARY V YORK
THORV ALD A NELSON
FRED SCHMIDT
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIR
STE 500
GREENWOOD VILLAGE CO 80111
E-MAIL: myork(fhollandhar.com
tnelson(fhollandhart.com
fschmidt(fhollandhar.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83702
E-MAIL: bottormidahoconservation.org
Ji~r6SECRETA~ -=
CERTIFICATE OF SERVICE