20100625Staff 1-76 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
RE
iOiUJUN 25 PM I: 26
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES. )
)
)
)
)
CASE NO. PAC-E-I0-07
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information on or before
FRIDAY, JULY 16,2010.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 1 JUE 25, 2010
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementa responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: For calendar years 2007, 2008, 2009 and 2010, please provide the
trial balances, by month, by FERC account and by FERC sub-account in an excel spreadsheet
with all formulas intact.
REQUEST NO.2: Please provide a copy of the Company's most recent char of
accounts and all cost allocation manuals.
REQUEST NO.3: Please provide a schedule of Property Held for Futue Use (PHFU)
for December 31, 2009. Please list each item individually. Please include within your response
any significant changes to PHFU occuring in, or planed for 2010.
REQUEST NO.4: Please provide a schedule of Contributions in Aid of Construction
(CIAC) as of December 31, 2009 showing names, dates, amounts and accounts used. Please
include within your response any significant changes to CIAC occuring in, or planed for 2010.
REQUEST NO.5: Please provide a schedule of Customer Advances for Constrction
for the year ending 2009 showing names, dates, amounts and accounts used. Please include
within your response any significant changes to Advances occuring in, or planed for 2010.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 2 JUE 25, 2010
REQUEST NO.6: Please provide an analysis of the sale ofland and plant for the years
2008, 2009 and 2010 to date. Please show gains, losses and supporting documentation including
accounting entries for removal of items from rate base.
REQUEST NO.7: Please provide details of any planed sales of land and/or plant for
the remainder of2010. Please include within your response the estimated date of these sales and
planed treatment (including accounting entries) of them.
REQUEST NO.8: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2007 through 2010 to date.
REQUEST NO.9: Please provide a list of all pending legal cases and their status
including description of the issue, estimates of liabilty and possible ramifications to the
Company.
REQUEST NO. 10: Please provide the amounts spent for injuries and damages for the
years 2007 to date. Please include within your response the description of each item, the amount
for each item and the account charged.
REQUEST NO. 11: For the following accounts, please provide, in an excel spreadsheet
with formulas intact, the detail of all transactions in each account at the sub-account level,
including date posted, vendor names, explanations, voucher or invoice number, expenditue type,
transaction description, and amounts posted, by month, for 2009 and 2010 to date. Please
provide the allocation factor and amount allocated to the Idaho jurisdiction.
FERC Account Nos.
901 910 929
902 920 930
903 921 931
904 922 935
905 923
907 924
908 925
909 928
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 3 JUE 25, 2010
REQUEST NO. 12: 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 2009. Please identify each expense that is related to safety.
REQUEST NO. 13: Please provide copies of the ads used during 2009 and correlate the
ad copy with the specific detail provided in the preceding audit request response.
REQUEST NO. 14: Please provide a list of all consultants who performed services for
Rocky Mountain Power and PacifiCorp for the years 2007 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. 15: Please provide copies of all internal audit reports for the years 2007
to date.
REQUEST NO. 16: Please provide a description of all audits/organizational reviews
currently in progress or planed through 2011 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. 17: Please provide a copy of the policy for bad debt write-offs and
collection of past due amounts.
REQUEST NO. 18: Please provide a schedule of bad debt amounts for 2008,2009 and
2010 to date.
REQUEST NO. 19: Please provide copies of all biling inserts for the years 2008 and
2009. Indicate the states where they were sent. Please provide a schedule showing the amount
and account numbers charged for all costs to produce, print, and distribute inserts.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 4 JUE 25, 2010
REQUEST NO. 20: Please provide a biling summar showing monthly breakdown of
revenue by class for the years 2007 through 2010 to date for Idaho. Please include within your
response the amounts, KWhs, and number of customers biled.
REQUEST NO. 21: Please provide an itemization by state of regulatory expenses for
the years 2007 through 2010 to date.
REQUEST NO. 22: Please provide schedules itemizing all changes to rate base by
account from 2008 to 2009. Please include within your response any significant changes to rate
base (by account) occuring in, or planed for 2010.
REQUEST NO. 23: 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.
REQUEST NO. 24: Please provide a copy of the cost!enefit analysis or similar
analysis study performed for each PacifiCorp and/or Rocky Mountain Power major capital
project rate based in the last three (3) years. Please provide a copy of the cost!enefit analysis or
similar analysis study performed for each PacifiCorp and/or Rocky Mountain Power major
capital project that is included in this rate case filing.
REQUEST NO. 25: Please provide any and all documents used by PacifiCorp and/or
Rocky Mountain Power to demonstrate the benefits realized for each major capital project that
has been rate based in the last three (3) years.
REQUEST NO. 26: Please provide a detailed listing of all entries to Account 456 -
Other Électric Revenues for 2007 to date.
REQUEST NO. 27: Please provide copies of the narative monthly, quaerly and
anual comparison of operating and capital budgets to actual expenditures for 2007 to date.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 5 JUNE 25, 2010
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 officers and managers to monitor and control budgets under their
areas of responsibilty.
REQUEST NO. 28: Please provide copies of the monthly, quaerly, and annual
presentations to the Company's Executive Board and Chief Executive and Operating Officers for
2007 to date. Please include within your response a paper copy of any slides and notes used in
such presentations.
REQUEST NO. 29: Please provide the Company's monthly operating and financial
reports for each month from January 2007 to date. These should be in the most detaled format
possible and should include all attached supporting schedules and analysis received by
management.
REQUEST NO. 30: 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
supporting any items that were "passed upon" and not reflected in the Company's financial
records and/or financial statements.
REQUEST NO. 31: Please provide a list of all leased items in 2009 and to date in 2010.
Please separate capital leases from operating leases and show the dates, terms, amounts and
accounts used for each lease.
REQUEST NO. 32: Please provide a list of all professional, social and organizational
membership dues paid and/or allocated to the Company in 2008 and 2009. These memberships
could include dues such as these: Chamber of Commerce, country clubs, organizations which
include lobbying as par or all of their goals, professional organzations for employees, and the
Edison Electric Institute. For each organization, show the amount paid, account posted, amount
allocated to Idaho and the service or benefit PacifiCorp received.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 6 JUNE 25, 2010
REQUEST NO. 33: Please provide a narative explaining how the Company accounts
for its relicensing costs. Please include within your response the accounts posted and ratemaking
implications, including how the revenue requirements for the state jurisdictions are impacted.
REQUEST NO. 34: Please provide a detailed list with explanation of all cost-cutting
measures undertaken by the Company during 2009 and 2010. Please also provide the annual
quantifiable results of those measures.
REQUEST NO. 35: Please provide a schedule of prepaid items for 2009 showing
amounts posted, vendor names, explanations and accounts posted. Please include within your
response any significant changes to prepaid items (by account) occurring in, or planed for 2010.
REQUEST NO. 36: Please provide a schedule showing 2007 through 2010 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. 37: Please provide a current organization char 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 2009 and 2010.
REQUEST NO. 38: For each officer of the Company, please provide the total dollar
amount of remuneration for 2009 and the amounts separated by salar, incentive pay, options,
benefits and other. For each officer, please also provide the percentages of his or her total
remuneration that is allocated to other subsidiaries along with the basis for that allocation. Please
provide all officers' salaries for 2007 through 2009 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.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 7 JUNE 25, 2010
REQUEST NO. 39: 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
2010.
REQUEST NO. 40: Please provide a copy of the most recent employee handbook.
REQUEST NO. 41: Please provide acopy of all agreements with union employees
effective during 2008,2009 and 2010. Please include within your response a synopsis of the
major compensation changes in these agreements from year to year.
REQUEST NO. 42: Please provide both federal and state quarterly and anual payroll
tax reports for the years ending 2008 and 2009.
REQUEST NO. 43: Please provide a'description of all incentive/bonus plans in effect
during fiscal years 2008, 2009 and 2010. Please include within your response the employees or
group of employees eligible under each of the plans and the costs attributable to each of these
plans. Indicate whether there are any changes and describe any changes to the incentive/bonus
plans that are anticipated or under consideration.
REQUEST NO. 44: Please provide the account numbers and amounts posted that the
Company used to book incentive payments for 2009.
REQUEST NO. 45: Please provide all documents supporting budgeted and actual wage
increases (if any) for non-union and exempt employees during 2008 through 2010. Please
include within your response the number of employees (budgeted and actual) to which these
wage increases applied and their associated salares pre and post wage increase.
REQUEST NO. 46: Please provide a written narrative that explains how the Company
sets employee salaries, incentive payments and other employee benefits. Please provide a copy
of the salar surveys or other documentation used to set employee salaries.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 8 JUE 25, 2010
REQUEST NO. 47: Please provide copies of the employee newsletters issued durng
the period 2008 to date.
REQUEST NO. 48: Please provide all officers' employee numbers, names, job titles,
detailed job descriptions, responsibilties, base salaries, and other compensation by year since
2007.
REQUEST NO. 49: Please provide details of all bonus plans included in the test period
and the criteria and goals used to grant employees bonuses.
REQUEST NO. 50: Please explain the basis for all officers' salar increases from the
2009 level to the 2010 leveL. Also, please provide all documents that are relevant to this inquiry.
REQUEST NO. 51: Please provide a copy ofthe following PacifiCorp documents:
2009 Annual Report to Stockholders; 2009 Statistical Supplement to Annual Report; 2009 Form
10-K; Most recent prospectus for sale of common stock; Most recent prospectus for sale of long-
term debt.
REQUEST NO. 52: Please provide an organizational char for PacifiCorp and Rocky
Mountain Power that shows each of its subsidiaries, and the parent company(s). In addition,
please provide a description of each company location and the fuctions performed at each
location.
REQUEST NO. 53: 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.
REQUEST NO. 54: 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 booked and if above the line, please include any explanation as to
the business purose.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 9 JUE 25, 2010
REQUEST NO. 55: Please provide a listing of all charitable contributions, including
names, amounts and account numbers included in the test year.
REQUEST NO. 56: 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. 57: Please provide the audit workpapers from the external auditors for
the years 2008 and 2009.
REQUEST NO. 58: 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 2008, 2009, and 2010 to date.
REQUEST NO. 59: Please provide the minutes for the other director committees, such
as the audit committee, compensation committee, etc. as well as all material distributed and/or
discussed at the meetings, including but not limited to external reports, committee reports,
handouts, chars, etc. for the years 2008, 2009 and 2010 to date.
REQUEST NO. 60: Please provide a copy of all contracts related to the Dave Johnston
FGD Retrofit Project (DJP) made between PacifiCorp and other vendors and suppliers. Please
provide a complete copy of the contract with supporting documents and specifications made
between PacifiCorp and Dave Johnston Power Parners (DJPP).
REQUEST NO. 61: Please provide a list of all major subcontractors employed by DJPP
in the DJP project.
REQUEST NO. 62: Please indicate ifPacifiCorp or any affliate ofPacifiCorp has an
equitable or beneficial interest in the constrction business DJPP which is the general contractor
on the DJP. Also, please indicate ifPacifiCorp or any affliate ofPacifiCorp has an equitable or
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 10 JUE 25, 2010
beneficial interest in any sub-contractor of DJPP that performed services on the construction of
the DJP. If so, please indicate what that interest is, and a description of the nature of the interest.
REQUEST NO. 63: Please provide a listing of contractor total payments made to all
vendors and monthly invoices for DJP. Please provide this information in electronic format
readable by Excel 2007.
REQUEST NO. 64: Please provide a copy of all environmental reports completed in
relation to the DJP.
REQUEST NO. 65: Please provide a schedule of AFUDC accumulated on the DJP.
Please include the amount booked and the AFUDC percent utilized in the calculation by month
since the beginning of the project
REQUEST NO. 66: Please explain how the DJP wil benefit Idaho customers.
REQUEST NO. 67: In addition to DJPP, what other constrction firms bid the DJP?
What factors drove PacifiCorp's decision to select DJPP as the contractor?
REQUEST NO. 68: Please provide a copy of all contracts related to the Populus-
Terminal Transmission Line (P2T) project made between PacifiCorp and other paries that were
executed in addition to the contract with Populus Terminal Transmission Parners (PTTP).
REQUEST NO. 69: Please provide a list of all major subcontractors employed by PTTP
in the P2T project.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 11 JUE 25, 2010
REQUEST NO. 70: Please provide invoices and any other supporting documentation
for the following contractors/suppliers for the P2T project:
21,171.38
69,199.50
341,350.74
1,555,277.00
17,999.00
26,142.92
41,651.55
2,300.00
21,363.00
42,325.92
Name of offsetting account
ANTHONY G HIATT
CRAIG W CHRISTENSEN
CHARTERED
DASELLLC
FABIAN & CLENDENIN
F AITHFUL+GOULD INC
FORTIS GROUP LLC
GILLESPIE PRUDHON & ASSOC INC
HALLOCK MODEY INC
HANSEN & ASSOCIATES INC
I/C Moving/Reloc Srv
I/Co Al - MEHC
JBR ENVIRONMENTAL
CONSUL T ANTS INC
LECGLLC
MOSTAFA JAFARNIA
MidA Mgmt Fee-930.2
Mov/Relo Serv-Emp
Other Emp Rel Exp
Other SalarylLabor C
PAUL R RUSSMAN
RIESTER MOUNTAIN LLC
ROGER TEW
STANLEY CONSULTANTS
STANLEY CONSULTANTS INC
STANTEC CONSULTING INC
STOEL RIVES LLP
Temp Services-Other
UTAH MAIDS LLC
V AN COTT BAGLEY CORNWALL &
MCCARTHY
Veh-Heatlen & AlC S
WALL ST TRANSPORTATION INC
WRGHT TREE SERVICE INC
Amount Paid
3,310.00
322,956.43
6,000.00
101,644.08
57,163.09
23,965.00
692.72
10,271.00
8,645.50
231,521.38
8,525.00
2,458,877.42
2,355,854.71
32,120.00
58,090.72
6,422.88
975
167,174.42
3,723,860.32
873
746,858.93
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 12 JUE 25, 2010
REQUEST NO. 71: Please provide a complete copy of any reports prepared by EPG Inc
related to the P2T project.
REQUEST NO. 72: Please provide a schedule of AFUDC accumulated on the P2T
project. Please include the amount booked and the AFUDC percent utilzed in the calculation by
month since the beginning of the project.
REQUEST NO. 73: Please provide a schedule of AFUDC accumulated on the P2T
project. Please include the amount booked and the AFUDC percent utilized in the calculation by
month since the beginning of the project.
REQUEST NO. 74: Please describe the derivation of any surcharge booked to a capital
project including all factors included in the surcharge. How often is the surcharge updated?
REQUEST NO. 75: Please explain how construction of the P2T line wil benefit Idaho
customers.
REQUEST NO. 76: In addition to PTTP, what other construction firms bid the P2T
line? What factors drove PacifiCorp's decision to select PTTP as the contractor?
DATED at Boise, Idaho, this :iS~ay of June 2010.
Scö Woodbury
Deputy Attorney General
Technical Staff: Joe Leckie
Cecily Vaughn
i :umisc:prodreq/pace i o. 7swjlcv prod req i
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 13 JUE 25, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH OF JUNE 2010, SERVED THE
FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO
PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-I0-07, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston~pacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datarequest~pacificorp.com
KATIE IVERSON
BRUBAKER & ASSOCIATES
17244 W CORDOVA CT
SURPRISE AZ 85387
E-MAIL: kiverson~consultbai.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo~racinelaw.net
MICHAEL C CREAMER
KELSEY J NUEZ
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: mcc~givenspursley.com
kelseynunez~givenspursley.com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solander~pacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb~racinelaw.net
JAMES R SMITH
E-MAIL: ONLY
i im.r.smith(imonsanto .com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony~yanel.net
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbuller~agrium.com
iaharis~agrium.com
I~J: __SECRETAR ~
CERTIFICATE OF SERVICE