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Home My WebLink About20100826Staff 252-270 to PAC.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 ISB NO. 1895 RECE.î\/EiJ Lura AUG 26 Pr1 3:40 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 EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNT AIN POWER The Staff of the Idaho Public Utilties Commission, by and through its attorney of record, Scott Woodbur, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power (Company; Rocky Mountain) provide the following documents and information on or before TUESDAY, SEPTEMBER 7, 2010. EIGHTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 1 AUGUST 26, 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 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. 252: Please provide copies of the Actuarial Reports for the Company's pension plans for 2007-2009. REQUEST NO. 253: Please provide copies of any correspondence between the Company and its actuaries, specifically any correspondence regarding future fuding levels or changes in assumptions for 2009 and 2010. REQUEST NO. 254: Please provide a table comparing the anual target incentive amounts to the amounts actually paid for the years 2007-2009. REQUEST NO. 255: Please describe in detail the nature of all affliate relationships between PacifiCorp or its parent companies and any company under contract to transport coal to any of the PacifiCorp coal-fired plants. REQUEST NO. 256: Please describe in detail any hiring constraints affecting the abilty of the Bridger Coal Company (BCC) to attract qualified employees. If these constraints are material to mine operation, what is the estimated financial impact of these constraints? Please EIGHTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 2 AUGUST 26, 2010 include any spreadsheets or other workpapers used in the analysis of financial impact due to hiring constraints at BCC. What steps has BCC taken to address this issue? REQUEST NO. 257: Please describe the method of determining cost of coal for the BCC. Please provide all backup documentation and spreadsheets with formulas intact used in this determination. How does this cost of coal compare to the cost of coal agreed to in the most recent IERCO- Idaho Power coal contract? REQUEST NO. 258: What is the all-in cost of coal per ton for the BCC coal? This all- in cost should identify both the detailed coal cost and the detailed return component. Please provide all backup documentation including spreadsheets with formulas intact used for this analysis. REQUEST NO. 259: Please provide all studies/cost-benefit analyses since 2000 pedormed by PacifiCorp or under its direction related to obtaining all or par of the coal used by the Bridger coal plant from any source other than BCC? REQUEST NO. 260: Please provide the same information as the above request for comparsons at all other coal plants. REQUEST NO. 261: What retrofitting would the Bridger coal plant need in order to economically bum a lower Btu/igher ash coal than that supplied by Black Butte/BCC? What are the estimated costs for this retrofit? REQUEST NO. 262: For the Naughton-Chevron Mining coal contract, please provide a schedule showing the dollar amount of the coal costs in 2010 when the contract effective date is changed from January 1,2010 to July 1,2010. In your response, please include all supporting documentation and spreadsheets with formulas intact that were used in this analysis. Please show the line item detail to identify the difference between this schedule and the Company's PAC-E-I0-07 general rate case (RA/JAM) amounts. EIGHTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 3 AUGUST 26,2010 REQUEST NO. 263: What is the composition ofthe suspended solids in the water pumped from the Bridger Underground Mine? What is the BCC plan for reclamation of this water? REQUEST NO. 264: In response to Staff Production Request No. 126, Rocky Mountain Power stated that in 2009 there were 15,158 customers on Schedule 36 (Time of Use pricing). It also reported that in 2008 there were 16,723 on Schedule 36. That is 1,565 fewer paricipants in 2009 than in 2008. Has Rocky Mountain Power done a sureyor an internal review of those customers that are no longer paricipating in the time-of-use pricing to determine why those customers chose to be dropped from Schedule 36? If so, what were the findings? REQUEST NO. 265: In response to Production Request No. 137, Rocky Mountain Power stated that the threshold at which it would go out and physically disconnect a meter if no one had signed up for the premises was 1,000 kwhs. In response to the same question in Case PAC-E-05-01 (Staff Production Request No. 50), Rocky Mountain stated that its threshold was 400 kwhs. Why did the Company raise the threshold from 400 kwhs to 1000 kwhs? If a cost analysis was completed, please provide that analysis. REQUEST NO. 266: Regarding those accounts that met the 1,000 kwh threshold, how many of those 835 customer accounts were physically disconnected: a) within 3 days, b) within 4-5 days, or, c) after 5 days? REQUEST NO. 267: Regarding Rocky Mountain Power's response to Staff Production Request #132, the answer was not responsive. To fuher clarify the question, for all the customer-requested account closures in 2009, by rate class, how many of those accounts that were closed, were reconnected to a new customer: a) within 3 calendar days, b) within 4-5 days, or c) went longer than 5 days before a new customer signed up for service? EIGHTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 4 AUGUST 26,2010 REQUEST NO. 268: In response to Staff Production Request No. 135, Rocky Mountain states that if a customer-requested account close/open date is 5 days before or 5 days after a scheduled monthly meter reading date that the close or open reading wil be computer estimated based upon the per day usage. So in the remaining 2/3 of the days in a month, in 2009, what was the length of time it took the Company to obtain an actual reading (i.e., by rate class, how many were obtained within 3 days, 4-5 days, or took more than 5 days)? REQUEST NO. 269: Regarding RMP's response to the above question, in all the scenarios above, whether it took 3 days to obtain an actual reading or more than 5 days, would an estimate always be done to take the reading back to the actual date requested by the customer to close or open the account? REQUEST NO. 270: Regarding RMP's Landlord Agreement program, is it possible for a landlord at any time to obtain a real time copy of the property listing showing the properties covered by the agreement and whether the account is tumed on or tumed off at the time of the request? If yes, can this listing mailed or faxed to the customer, or is it available on line? DATED at Boise, Idaho, this ôilfy of August 2010. Scott Woodbury Deputy Attorney General Technical Staff: Donn English/252-254 Cecily Vaughn255-263 Marilyn Parker/264-270 i:umisc:prodreqlpacelO.7swdecvmp prod req8 EIGHTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 5 AUGUST 26,2010 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF AUGUST 2010, SERVED THE FOREGOING EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-1O-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.westonaYpacificorp.com E-MAIL: ONLY MARK C MOENCH DANIEL E SOLANDER ROCKY MOUNTAIN POWER E-MAIL: mark.moenchaYpacificorp.com daniel.solanderaYpacificorp.com RANDALL C BUDGE RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: rcbaYracinelaw.net E-MAIL: ONLY JAMES R SMITH MONSANTO COMPANY E-MAIL: jim.r.smithaYmonsanto.com ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 E-MAIL: tonyaYyankeL.net PAUL J HICKEY HICKEY & EVANS LLP 1800 CAREY AVE., SUITE 700 PO BOX 467 CHEYENNE WY 82003 E-MAIL: phickeyaYhickeyevans.com E-MAIL: ONLY DATA REQUEST RESPONSE CENTER PACIFICORP E-MAIL: datarequestaYpacificorp.com KATIE IVERSON BRUBAKER & ASSOCIATES 17244 W CORDOVA CT SURPRISE AZ 85387 E-MAIL: kiversonaYconsultbai.com ERIC LOLSEN RACINE OLSON NYE ET AL PO BOX 1391 POCATELLO ID 83204-1391 E-MAIL: eloaYracinelaw.net CERTIFICATE OF SERVICE TIM BULLER JASON HARRS AGRIUMINC 3010 CONDA RD SODA SPRINGS ID 83276 E-MAIL: tbulleraYagrium.com jaharrisaYagrium.com BENJAMIN J OTTO IDAHO CONSERVATION LEAGUE 710 N 6TH STREET POBOX 844 BOISE ID 83702 E-MAIL: bottoaYidahoconservation.org MELINDA J DAVISON DAVISON VAN CLEVE, P.C. 333 SW TAYLOR, SUITE 400 PORTLAND, OR 97204 E-MAIL: mjdaYdvclaw.com RONALD L WILLIAMS WILLIAMS BRADBURY, P.C. 1015 WHAYS STREET BOISE ID 83702 E-MAIL: ronaYwillamsbradbury.com BRAD M PURDY ATTORNEY AT LAW 2019N 17TH STREET BOISE ID 83702 E-MAIL: bmpurdyaYhotmaiLcom J?~ SECRETAR7 CERTIFICATE OF SERVICE