20100819PIIC 2-49 to PAC.pdf

Melinda J. Davison, OSB No. 930572
Davison Van Cleve, P.C.
333 SW Taylor, Suite 300
Portland, OR 97204
[phone]
[phone] (Fax)
mjd~dvc1aw.com
RECEIV '1
zoin AUG l 9 AM 8: 01
Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
[phone]
[phone] (Fax)
ron~wiliamsbradbury.com
Attorneys for PacifiCorp Idaho Industral Customers
BEFORE THE IDAHO PUBLIC UTILITIES. COMMISSION
IN THE MATTER OF THE APPLICA nON OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES.
)
) CASE NO. PAC-E-1O-07
)
) SECOND SET OF DATA
) REQUESTS TO ROCKY
) MOUNTAIN POWER OF THE
) PACIFICORP IDAHO
) INDUSTRIAL CUSTOMERS
)
PacifiCorp Idaho Industral Customers ("PIIC"), by and through its attorney of
record, Melinda Davison, requests that PacifiCorp, d//a Rocky Mountain Power (the
"Company"), provide the following documents and information on or before Wednesday,
September 8,2010. For the definitions and instructions that apply to these data requests, please
refer to PIIC's First Set of Data Requests dated August 12,2010.
PAGE 1 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
Please provide the responses to these Data Requests by Wednesday, September 8,
2010, to:
Melinda Davison
Davison Van Cleve, P.C.
333 S.W. Taylor St., Ste. 400
Portland, Oregon 97204
[phone]
mail~dvclaw.com
Randall J. Falkenberg
RFI Consulting, Inc.
PMB 362
8343 Roswell Road
Sandy Springs, GA 30350
[phone]
consultr~aol.com
III. DATA REQUESTS
2. Please provide copies of Rocky Mountain Power's responses to Staff Production
Requests 1-59,97-98, 111, 121-123, 158-164, 167-187, 194-201,208-209, and 214-222.
3. Please provide copies of Rocky Mountain Power's responses to Idaho Irrgation Pumpers
Association Production Requests 1-24,27-30, and 36-45.
4. For each Company distribution substation in the state of Idaho, provide a schedule in an
EXCEL file indicating the name of the substation, the installed transformer capacity, the
winter and summer peak rating used by the Company for the substation, the peak load for
each month (including the date and time when each peak occurred), and the peak load for
each distribution feeder (including the date and time when each peak occurred) for 2009.
5. Please provide a complete copy of the Company's distrbution engineer design manuaL.
6. Please provide a complete copy of the Company's transmission engineer design manuaL.
7. Provide the calculation of the labor costs such that it shows the amount the Company is
proposing to include in rates.
8. Provide the following information for each of the calendar years 2004 through 2009:
a. Base pay
b. Incentive compensation
c. Pension and benefit costs
9. Please identify the total number and percentage of employees that earn: 1) less than their
targ~t amount of "at risk" compensation; 2) their target amount of "at risk"
compensation; and 3) more than their target amount of "at risk" compensation.
PAGE 2 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
10. Provide the actual bonuses and incentive compensation for each calendar that would be
added to "bare labor expenses" to arrve at total wages and salaries that are comparable to
the Company's proposed rate case total wages and salaries.
11. Provide a current employee organization chart for PacifiCorp for all employees of
Director level and higher.
12. Provide a current employee organization chart for PacifiCorp Energy for all employees of
Director level and higher.
13. Provide a current employee organization chart for Rocky Mountain Power for all
employees of Director level and higher.
14. Provide a current corporate organization chart for PacifiCorp showing PacifiCorp's
ownership and affiliate companies. Please provide a response which includes the
ownership of Mid American Energy Holdings Company and all affiiated companies.
15. Provide the annual base salary, bonuses, stock options, and all other compensation
included in Rocky Mountain Power's proposed revenue requirement for the rate period
test year for each of Rocky Mountain Power's and PacifiCorp's executive offcers
including all individuals with the title of Vice President or higher in the organization.
16. If wages and salaries and the costs of related employee benefits and payroll taxes
included in the test period, and include any costs allocated or assigned from an affiliate,
please provide the base wage, overtime, benefits, taxes, and other amounts for each
employee. Include a description of the services provided and the basis for the
allocation/assignent of these amounts to Rocky Mountain Power.
17. Regarding PacifiCorp's legal expense:
a. Please provide the legal expenses that are included in the revenue requirement for
the test period.
b. Please provide the legal expenses that are included in the forecast test period
revenue requirement on a total Company basis and a jurisdictional basis.
c. Please provide the level of outside legal expense that is included in its test period,
along with any costs for outside legal activities that it excluded.
d. Please provide its actual FY and budgeted 2008-2010 outside legal expense that
compares with the amounts provided above.
18. Provide a list of all testimony, schedules, and workpapers in the company's filing that
impact wages and salaries, employee benefits, and payroll taxes.
19. Provide the following information for Rocky Mountain Power Idaho for each of the
calendar years 2010, 2009, 2008, 2007, 2006, 2005, and 2004:
a. Total wages and salaries
PAGE 3 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
b. Total wages and salaries charged to accounts 500 through 932
c. Total wages and salaries charged to capital or other balance sheet accounts
d. Total regular wages and salaries
e. Total overtime wages and salaries.
20. Provide the following information for Rocky Mountain Power Idaho by month for 2009:
a. Total wages and salaries
b. Total wages and salaries charged to accounts 500 through 932
c. Total wages and salaries charged to capital or other balance sheet accounts
d. Total regular wages and salaries
e. Total overtime wages and salaries.
21. Provide the following information for PacifiCorp for each of the calendar years 2010,
2009,2008,2007,2006,2005, and 2004:
a. Total wages and salaries
b. Total wages and salaries charged to accounts 500 through 932
c. Total wages and salaries charged to capital or other balance sheet accounts
d. Total regular wages and salaries
e. Total overtime wages and salaries.
22. Explain in detail how Rocky Mountain Power's Idaho wages and salaries are determined.
23. Are Rocky Mountain Power's Idaho wages and salaries included in the total wages and
salaries ofPacifiCorp?
24. Provide all workpapers, calculations, assumptions, and source documentation necessary
to replicate all of the Company's proposed adjustments for wages and salaries through
the end of the test year. Provide as much information as possible in working electronic
format (unlocked and including all formulas).
25. Provide all wages and salaries schedules and workpapers included in the company's
application in working electronic format (unlocked and including formulas).
26. Provide all employee benefits schedules and workpapers included in the company's
application in working electronic format (unlocked and including formulas).
27. Provide all payroll tax schedules and workpapers included in the company's application
in working electronic format (unlocked and including formulas).
28. Provide the amount of incentive compensation included in the actual results of operations
for the twelve months of the test period by FERC account.
29. Provide the number of employees included in Idaho operations by month for the twelve
month test period.
PAGE 4 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
30. Regarding PacifiCorp's legal departent, please provide the number of employees for
each position for 2000-2010.
31. Regarding PacifiCorp' s legal departent, please provide the expected number of
employees for each position for 2010-2015.
32. Please provide the legal expense associated with Rocky Mountain Power's last five Idaho
general rate proceedings.
33. Please identify whether the Company's proposed revenue requirement includes the costs
associated with the Company's general rate proceedings. If so, please identify the total
costs, a categorical breakdown of the costs, the Idaho allocated costs, and an explanation
of the Idaho allocation.
34. Please provide a total and detailed fuctional breakdown of all rate case expense that is
included in the test period. Please include the specific amounts for internal and outside
legal expense, internal and external witness expense by witness, and all other functions
and categories.
35. Please identify the total legal departent costs for 2000-2010, and expected legal
departent costs for 2010-2015. Please provide a categorical breakdown and description
ofPacifiCorp's legal departent costs.
36. Please identify PacifiCorp's total legal costs for 2000-2010, and expected legal costs for
2010-2015. Please provide a categorical breakdown and description ofPacifiCorp's legal
costs.
37. Please identify the number of in-house attorneys, salaries per each titles, and their total
salaries and other compensation.
38. Regarding outside legal expenses, has PacifiCorp taken any action to reduce outside legal
expenses through negotiating lower biling rates? If the answer is yes, please quantify the
impact of the lower biling rates on the test year outside legal expenses assuming all other
assumptions regarding the determination of outside legal expenses remain constant.
39. Please provide the actual or estimated biling rates for PacifiCorp's in house and outside
legal experts for FY 2003 through FY 2010.
40. For PacifiCorp's legal expense included in the test year, please provide the legal expense
associated with PacifiCorp's last five general rate proceedings.
41. Regarding PacifiCorp's outside legal expenses included in the test period. Please provide
a detailed explanation for the types of cases included in each group of costs included in
each "FERC Description," a list of cases or matters included in each "FERC
Description," and a breakdown of the costs attributable to each case or matter. In
PAGE 5 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
addition, please explain the differences between certain groups of costs that have the
same "FERC Description."
42. Regarding outside legal expenses included in the test period. For each "FERC
Description," please provide a detailed explanation for why each "ID Factor" was
selected.
43. Regarding outside legal expenses included in the test period. For each cost allocated to
Idaho, please provide a general description of each legal case or matter, each case's costs,
the amount at issue, and the biling rates charged to PacifiCorp. IfPacifiCorp is unable to
unwiling to answer this question, please provide the information to ascertain the each
legal case or matter, each case's total costs, and the biling rates for each case.
44. Please provide an explanation and all supporting information regarding the difference
between the amount of outside legal expenses included in the test period, and the
calendar year outside legal expense for 2008, 2009 and 2010. For example, please
identify specific cost categories, cases or matters that are expected to differ.
45. Please provide PacifiCorp's outside legal fee budgets for each calendar year from 2000-
2010.
46. Please identify the amount of outside legal fees that were included in rates for each
general rate case in Oregon, Utah, California, Washington, Idaho and Wyoming since
2000. If the specific amount is unown because of a settlement or other reason, please
identify the amount of outside legal fees proposed by the Company to be included in rates
and the Company's best estimate of the amount oflegal fees included in rates.
47. For PacifiCorp's outside legal fees, please identify whether these amounts are offset by
legal claims paid to PacifiCorp. Please identify the amount oflegal claims paid to
PacifiCorp for the past five calendar years and for the current test period. Please identify
the total company and Idaho amounts, appropriate Idaho allocation factors, descriptions
of the cases and matters, and an identification of how much was paid for each case or
matter number.
48. Please provide copies of the Company's compensation and bonus payment plan and
guidelines, and an explanation of each component of the compensation and bonus
payment plan.
49. Please provide a copy of distribution and transmission facilities maps for each of the
Company's six service terrtories.
PAGE 6 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing Second Set of
Data Requests to Rocky Mountain Power on behalf of the Pacifi Corp Idaho Industral Customers
upon the parties, on the offcial service list shown below for PAC-E-I0-07, via electronic maiL.
Dated at Portland, Oregon, this 17th day of August, 2010.
~
Ted Weston
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
ted.westonCÐpacificorp.com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Ave., Suite 700
PO Box 467
Cheyenne, WY 82003
phickeYCÐhickeyevans.com
Mark C. Moench
Daniel Solander
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
mark.moenchCÐpacificorp.com
daniel.solanderCÐpacificorp.com
(ELECTRONIC COPIES ONLY)
Data Request Response Center
PacifCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
datarequestCÐpacificorp.com
Scott Woodbury
Deputy Attorney General
Idaho Public Utilties Commission
427 W. Washington (83702)
PO Box 83720
Boise, il 83720-0074
scott. woodburyCÐpuc.idaho.gov
Randall C. Budge
Monsanto Company
Racine Olson Nye Budge & Bailey
201 E. Center
PO Box 1391
Pocatello, il 83204-1391
rcbCÐracinelaw.net
Katie Iverson
Monsanto Company
Brubaker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
kiversonCÐconsultbai.com
James R. Smith
Monsanto Company
PO Box 816
Soda Springs, il 83276
jim.r.smithCÐmonsanto.com
(ELECTRONIC COPIES ONLY)
PAGE 7 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
Eric L. Olson
Idaho Irrigation Pumpers Association, Inc.
Racine Olson Nye Budge & Bailey
201 E. Center
PO Box 1391
Pocatello, il 83204-1391
eloCÐracinelaw.net
Michael C. Creamer
Kelsey J. Nunez
Agrium, Inc.
Givens Pursley LLP
601 W.Bannock St. (83702)
Boise, il 83701-2720
mccCÐgivenspursley.com
ke1seynunezCÐgivenspursley.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
POBox 844
Boise, il 83702
bottoCÐidahoconservation.org
Brad M. Purdy
Community Action Partnership Association of
Idaho
Attorney at law
2019 N. 17th Street
Boise, il 83702
bmpurdYCÐhotmail.com
Anthony Yankel
Idaho Irrgation Pumpers Association, Inc.
29814 Lake Road
Bay Vilage, OH 44140
tonYCÐyankel.net
Tim Buller
Jason Harris
Agrium, Inc.
3010 Conda Road
Soda Springs, il 83276
tbullerCÐagrum.com
jaharrsCÐagrium.com
Ronald L. Williams
PacifiCorp Idaho Industral Customers
Wiliams Bradbury, P.e.
1015 W. Hays St.
Boise, il 83702
ronCÐwiliamsbradbury .com
PAGE 8 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER