20100730Staff 167-201 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
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
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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
FIFTH 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, AUGUST 20, 2010.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 30, 2010
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil 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 preparng 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. 167: Company workpaper page 4.1.1 indicates the amounts of
Miscellaneous General Expense removed from the 2009 Results of Operations. Please provide
an itemized schedule of each expenditure that was removed that reconciles with page 4.1.1.
Please include the date, vendor, amount ofthe expense, and the Idaho allocation.
REQUEST NO. 168: Please provide in Excel format with all formulas intact pages 4.3
through 4.3.14 of the Company's workpapers.
REQUEST NO. 169: Please provide the Company's policies on overtime pay and
overtime meals.
REQUEST NO. 170: Please provide a schedule of the listings in Account 500250
(Overtime Meals) comparing expenses for calendar years 2005-2009 and year-to-date 2010.
REQUEST NO. 171: Please provide a narrative of Account 500700 (Severance/
Redundancy) and a complete listing of all charges made to that account during 2009.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 30, 2010
REQUEST NO. 172: Please provide a narrative of Account 500850 (Other
Salar/Labor Costs) and a complete listing of all charges made to that account during 2009.
Please include date, vender, a brief explanation of the charge, and the Idaho allocation.
REQUEST NO. 173: Please provide the Company's policies on Education Assistace.
REQUEST NO. 174: In Portland (August 16 thru 20,2010 audit), please have available
all information supporting the 2010 budgeted amounts listed in Column D of work paper page
4.3.9.
REQUEST NO. 175: Please provide a complete itemized listing of "Settlement Fees"
that were removed from the 2009 Results of Operations (see workpaper page 4.7.1). Please
include the date, vendor, FERC account, amount and the Idaho Allocation.
REQUEST NO. 176: Please provide a listing of all restitutions paid under the Avian
Settlement and to which accounts the restitution payments are booked.
REQUEST NO. 177: Please provide the details of the Company's lease for the offce
space located within the One Utah Center. Please provide the Company's short-term,
intermediate, and long-term plans for that office space. Please provide justification for the
Company maintaining the lease.
REQUEST NO. 178: Does the Company sublet any of its office space within the One
Utah Center to other businesses? Is so, please provide the details of the sub-lease.
REQUEST NO. 179: Please provide the lease agreements for the real property used for
the wind generation projects known as Seven Mile Hil, Seven Mile Hil II, High Plains and
McFadden Ridge.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 30, 2010
REQUEST NO. 180: Please provide the Purchase Agreement for the real property used
for the wind generation project known as Dunlap (Dunlap property).
REQUEST NO. 181: Please provide documentation of real property taxes for the
Dunlap property for 2009 and 2010.
REQUEST NO. 182: Please provide a description of any personal property that was
purchased as par of the Dunlap property purchase, the value assigned to such personal property,
and the current use of such property.
REQUEST NO. 183: Please provide a description of any improvements to the real
property that were included in the purchase price of the property, the value of such
improvements and the current use of the improvements.
REQUEST NO. 184: Please provide any/all leases with any third pary that relates to
the operation of the Dunlap property as a wind generation project. This would include any lease
for the grazing rights, mineral rights, or any other ancilar property right associated with the
property.
REQUEST NO. 185: Please provide any planing projection for the placement of any
future use of the Dunlap property. This would include any generation, transmission or
distribution use.
REQUEST NO. 186: Company workpaper 4.17 (Avian Settlement) states "This
adjustment removes the April 2009 reversal ofa December 2008 entry." Please provide all
entries related to this adjustment with dates and accounts; please provide this data in excel
format.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JUL Y 30, 2010
REQUEST NO. 187: Regarding mine stripping costs at Bridger Coal Mine:
(1) Please provide the total estimated stripping costs per year beginning with FY2009 and
continuing until 95% of overburden is removed; please provide documentation
supporting this estimate.
(2) Please provide the estimated total tons of coal contained in the new vein that will be
uncovered; please provide documentation supporting this estimate.
(3) Please provide the estimated tons of coal expected to be removed per year until the
vein is 95% depleted; please provide documentation supporting this estimate.
(4) What is the impact of stripping costs on the inventory valuation of the coal stockpile
inventory at Bridger.
REQUEST NO. 188: Please provide a bil frequency analysis for Schedule 1 customers
from January 2009 through the most curent month. Please use 100 kWh bins for 0-1,200 kWh,
200kWh bins for 1,201-2,000 kWh, and 500kWh bins for 2,001+.
REQUEST NO. 189: Please provide a bil frequency analysis for Schedule 36
customers from January 2009 through the most current month. Please use 100 kWh bins for
0-1,200 kWh, 200kWh bins for 1,201-2,000 kWh, and 500kWh bins for 2,001+.
REQUEST NO. 190: Please identify the costs associated with meter reading and biling
for Schedules 1 and 36 customers within the Company's COS modeL.
REQUEST NO. 191: With regards to residential Schedules 1 and 36 customers, has the
Company recently conducted any end-use studies? If not, does it plan to? If not, why?
REQUEST NO. 192: What percentage of Schedule 1 and 36 customers rely on electric
space heating in the winter?
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 30, 2010
REQUEST NO. 193: In light of the Company's proposal to implement tiered rates in
non-summer months, what rate mitigation or assistance options has the Company considered to
assist low income customers, specifically those using electric heat in the winter?
REQUEST NO. 194: Does the Company plan to install AMR devices or an AMI system
within its system? Please explain why or why not, and the proposed timing if so.
REQUEST NO. 195: Has the Company attempted to quantify the benefits, both to the
system and the Idaho jurisdiction, of its time-of-use rates offered in Idaho? If so, please provide
the results. If not, explain why not.
REQUEST NO. 196: Please provide actual energy sales by Idaho customer class for all
available months for 2010.
REQUEST NO. 197: Please provide weather normalized energy sales by Idaho
customer class for all available months for 2010.
REQUEST NO. 198: Please list all curent or closed general rate case proceedings that
involved a 2010 test year by jurisdiction.
REQUEST NO. 199: For any proceedings listed in the Company's response to
Production Request No. 11, did the Company adjust Idaho jurisdictional load as it has in this
proceeding, resulting in adjusted jurisdictional allocation factors? If so, please explain.
REQUEST NO. 200: Please provide all instances over the past three years where the
Company has performed a load normalization to customer classes in all jurisdictions in general
rate case proceedings similar to what the Company has down with irrigation and industrial
customers in Idaho.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JULY 30, 2010
REQUEST NO. 201: Please provide the energy savings for 2009 attributed to the
following Company programs:
a. Irrigation Energy Services
b. FinAnswer Express
c. Home Energy Savings
DATED at Boise, Idaho, this~ay of July 2010.
~f)¿~
Scott Woodbury
Deputy Attorney General
-~
Technical Staff: Donn English/167-178
Joe Leckie/179-185
Cecily Vaughn186-187
Bryan Lanspery/188-201
i:umisc:prodreq/paceI O.7swdejlcvbl prod req5
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JULY 30, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30TH OF JULY 2010, SERVED THE
FOREGOING FIFTH 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
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moench§pacificorp.com
daniel.solander§pacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb§racinelaw.net
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith§monsanto.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony§yanel.net
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
E-MAIL: phickey§hickeyevans.com
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
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 NUNEZ
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: mcc§givenspursley.com
kelseynunez§givenspursley.com
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbuller§agrium.com
jaharis§agrium.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
PO BOX 844
BOISE ID 83702
E-MAIL: bottoriidahoconservation.org
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E-MAIL: mjd§dvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: ronriwiliamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy§hotmail.com
Jo~SECRETA -~--
CERTIFICATE OF SERVICE