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Home My WebLink About20100819Staff 223-251 to PAC.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 ISB NO. 1895 REeE ; l 20in AUG l 9 PH 3= 37 NEIL PRICE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 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 SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER The Staff of the Idaho Public Utilties 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 MONDAY, AUGUST 30, 2010. SEVENTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 1 AUGUST 19,2010 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 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 files on CD with formulas activated. REQUEST NO. 223: For Bridger Coal Company (BCC), 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 turnover ratios for each account. REQUEST NO. 224: For BCC, 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 chart changed or is expected to change during 2009 and 2010. REQUEST NO. 225: For each officer ofBCC, please provide the total dollar amount of remuneration for 2007 through 2010 to date and proformed through December 31, 2010. Please separate the amounts into salary, incentive pay, options, benefits and other. Please provide this information for each officer by month. For each officer, please also provide the percentages of his or her total remuneration that is allocated to underground and surface operations along with the basis for that allocation, and please itemize by base salary, bonuses, and benefits. SEVENTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 2 AUGUST 19,2010 REQUEST NO. 226: For BCC, please provide the total number of employees and employee expenses by month by account and in total for 2007 through 2010 to date. In addition, please provide the budgeted amounts for 2010. REQUEST NO. 227: For BCC, please provide a copy of the most recent employee handbook. REQUEST NO. 228: For BCC, please provide a copy of all agreements with union employees effective during 2007, 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. 229: For BCC, 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 and describe any changes to the incentive!bonus plans that are anticipated or under consideration. REQUEST NO. 230: For BCC, please provide the account numbers and amounts posted that the Company used to book incentive payments for 2009. REQUEST NO. 231: For BCC, please provide all documents supporting budgeted and actual wage increases (if any) for non-union and exempt employees during 2009 though 2010. 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. 232: For BCC, please provide a written narative that explains how the Company sets employee salaries, incentive payments and other employee benefits. Please provide a copy of the salary sureys or other documentation used to set employee salaries. SEVENTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 3 AUGUST 19,2010 REQUEST NO. 233: For BCC, please provide copies of the employee newsletters issued during the period 2007 to date. REQUEST NO. 234~ For BCC, please provide all officers' employee numbers, names, job titles, detailed job descriptions, responsibilties, base salaries, and other compensation by year since 2007. REQUEST NO. 235: For BCC, please provide details of all bonus plans included in the test period and the criteria and goals used to grant employees bonuses. REQUEST NO. 236: For BCC, please explain the basis for all officers' salary increases from the 2009 level to the 2010 leveL. Also, please provide all documents that are relevant to this inquiry. REQUEST NO. 237: Please provide the average cost and tonnage of coal delivered from Bridger Coal Company and Black Butte for each year 2005 to date. a. For the years 2007 through 2010 to date, please provide costs and tons delivered per month per year from both Bridger Coal Company and Black Butte. b. Does PacifiCorp have any reason to expect coal costs to increase during the remainder of 2010 and durng 2011. If these costs are expected to increase, please provide supporting data. REQUEST NO. 238: Please provide the coal inventory by location and by month for the period 2007 to date. Please provide both tonnage and cost for each data point. Please provide this data in excel format. REQUEST NO. 239: For the information provided in the above question, please explain any significant change in either volume (tonnage) or cost for each coal pile during this period. SEVENTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 4 AUGUST 19,2010 The next three questions relate to Bridger: REQUEST NO. 240: How is coal quality measured? What are the metrics (specifications), instruentation used, and frequency? REQUEST NO. 241: Where in the coal supply pipeline is quality measured? (i.e. upon delivery from each of the three sources, prior to blending, after blending, upon delivery to the generation plant?) REQUEST NO. 242: Please provide all coal quality measurement data for the period 2007 through 2010 to date. Please provide this data in excel format. The next four questions relate to the External Auditor workpapers review: REQUEST NO. 243: Please provide a list of all Berkshire Hathaway affliate companies. Please provide this in excel format similar to the data found in external auditor workpapers at http://idoc.pacificorp.us/File/File64231.xls REQUEST NO. 244: How many Pcards are issued to PacifiCorp employees? REQUEST NO. 245: What is the status of the non-public investigation by the FERC into the power outage of September 2008? REQUEST NO. 246: Has there been any buyback of unused personal time from senior management included in the test year? SEVENTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 5 AUGUST 19,2010 REQUEST NO. 247: In 2009, how many service connections were performed in Idaho during regular office hours? REQUEST NO. 248: In 2009, how many service connections were performed in Idaho between the hours of 4:00pm and 5:00pm, Monday through Friday, excluding holidays? REQUEST NO. 249: In 2009, how many service connections were performed in Idaho between the hours of 5:00pm and 7:00pm Monday through Friday, excluding holidays? REQUEST NO. 250: In 2009, how many service connections were performed in Idaho after 7:00pm and before regular office hours began the following morning? REQUEST NO. 251: In 2009, how many service connections were performed in Idaho on weekends and holidays? DATED at Boise, Idaho, this l't ~ay of August 2010. MJ~ ~í Scott Woodbury Deputy Attorney General Technical Staff: Cecily Vaughn223-246 Marilyn Parker/247-251 i:umisc:prodreq/pace i o. 7swcvmp prod req7 SEVENTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 6 AUGUST 19,2010 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF AUGUST 2010, SERVED THE FOREGOING SEVENTH 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(fpacificorp.com E-MAIL: ONLY MARK C MOENCH DANIEL E SOLANDER ROCKY MOUNTAIN POWER E-MAIL: mark.moench(fpacificorp.com daniel.solander(fpacificorp.com RANDALL C BUDGE RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: rcb(fracinelaw.net E-MAIL: ONLY JAMES R SMITH MONSANTO COMPANY E-MAIL: jim.r.smith(fmonsanto.com ANTHONY Y ANKEL 29814 LAK ROAD BAY VILLAGE OH 44140 E-MAIL: tony(fyanel.net PAUL J HICKEY HICKEY & EVANS LLP 1800 CAREY AVE., SUITE 700 PO BOX 467 CHEYENNE WY 82003 E-MAIL: phickey(fhickeyevans.com E-MAIL: ONLY DATA REQUEST RESPONSE CENTER PACIFICORP E-MAIL: datarequest(fpacificorp.com KATIE IVERSON BRUBAKER & ASSOCIATES 17244 W CORDOVA CT SURPRISE AZ 85387 E-MAIL: kiverson(fconsultbai.com ERIC L OLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: elo(fracinelaw.net CERTIFICATE OF SERVICE TIM BULLER JASON HARRS AGRIUMINC 3010 CONDA RD SODA SPRINGS ID 83276 E-MAIL: tbuller(fagrium.com jaharris(fagrium.com BENJAMIN J OTTO IDAHO CONSERVATION LEAGUE 710 N 6TH STREET PO BOX 844 BOISE ID 83702 E-MAIL: botto(fidahoconservation.org MELINDA J DAVISON DAVISON VAN CLEVE, P.C. 333 SW TAYLOR, SUITE 400 PORTLAND, OR 97204 E-MAIL: mjd(fdvclaw.com RONALD L WILLIAMS WILLIAMS BRADBURY, P.C. 1015 WHAYS STREET BOISE ID 83702 E-MAIL: ron(fwiliamsbradbury.com BRAD M PURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 E-MAIL: bmpurdy(fhotmail.com ,b~SECRETAR - CERTIFICATE OF SERVICE