20100908PAC to PIIC 2-49 partial.pdf

~~l~UNTAIN
RECE!\/
tum SEP -8 ArU I: 03 201 South Main, Suite 2300
Salt Lake City, Utah 84111
September 7, 2010
Melinda Davison
Davison Van Cleve, P.C.
333 S.W. Taylor St., Ste. 400
Portand, Oregon 97204
Randal J. Falenberg
RFI Consulting, Inc.
PMB362
8343 Roswell Road
Sandy Springs, GA 30350
RE: il PAC-E-1O-07
PILC Data Request (2-49)
Pleae fid enclosed Rocky Mounta Power's responses to PILC Data Request 2-49, excludig
PIlC 9, 11-14, 17,32,34,40,43, and 47-48. These responses wil be provided separately.
Provided on the enclosed CD are Attchments PIlC 2 -1, 3 -1,4 -(a-b), 5, 6, 21, 28, 30, 39, and
49. Provided on the enclosed Confdential CD are Confdential Atthments PILC 2 -2, 3 -2, 15,
33,35,37,41,44, and 45. The Confdential Attchments are Confdential and are provided to
paries tht have signed a protective order in ths docket.
If you have any questions, pleae feel free to call me at [phone].
Sincerely, JJ:rd/(~/~
J. Ted Weston
Manager, Reguation
Enclosue:
cc: Jean Jewel1PUC (C)/ 3 copies
Eric OlsenIPA (C)
Ben Otto/ICL (C)
Radall Budge/Monsto (C)
James R. Smithonsto (C)
Richad Anderson/onsanto (C)
Gerge C. Carer, IIIonsto (C)
Denns Peseau/onsto (C)
Gar R. Kajander/Monsanto (C)
Maunce Brubaker/Monsto (C)
Brian Collionsanto (C)
Michal Gormanonsanto (C)
Ka Iversn/onsanto (C)
Ma Widmer/Monsto (C)
PAC-E-10-07/Rocky Mountan Power
September 7, 2010
PILC Data Request 2
PUC Data Request 2
Pleae provide copies of Rocky Mounta Power's responses to Sta Production
Requests 1-59,97-98, 111, 121-123, 158-164, 167-187, 194-201,208-209, and
214-222.
Response to PIIC Data Request 2
Please refer to Attchment PIlC 2 -1 for the requested responses and atchments
and to Confdential Attchment PILC 2 -2 for confidential attchments.
Confdential information is provided subject to the terms and conditions of the
protective agreement in ths proceedig.
Recordholder: N/ A
Sponsor: N/ A
P AC-E-1 0-07/Rocky Mountan Power
September 7, 2010
PILC Dat Request 3
PIIC Data Request 3
Pleas provide copies of Rocky Mounta Power's responses to Idao Irgation
Pumpers Association Production Requests 1-24, 27-30, and 36-45.
Response to PUC Data Request 3
Please refer to Attchment PUC 3 -1 for the requested responses and atthments
and to Confdential Atthment PUC 3 -2 for confdential atthments.
Confdential inormtion is provided subject to the terms and conditions of the
protective agrement in ths proceedng.
Recordholder: N/ A
Sponsor: N/A
PAC-E-1O-07/Rocky Mountan Power
September 7, 2010
PILC Data Request 4
PUC Data Request 4
For each Company distrbution substation in the stte ofIdao, provide a schedule
in an EXCEL file indicating the nae of the substation, the instled trsformer
capacity, the winter and sumer pe rating used by the Company for the
substation, the peak load for each month (including the date and time when each
peak occured), and the peak load for each distrbution feeder (including the date
and time when each peak occured) for 2009.
Response to PUC Data Request 4
Attched is an Excel fie (Attchment PUC 4a) that lists each PacifiCorp
distrbution substation in the state of Idao, curent trformer capacity, and
monthy peak loads for 2009. Also atthed is an Excel file (Atthment PILC 4b)
tht lists the 2009 monthy peak loads for each PacifiCorp distrbution feeder in
the state ofIdaho.Most of the distrbution substations and feeders in Idao have
drag had meterig that is only read once a month by field personneL. Since the
meterig is only read monthly, date and time stps are not available for most of
the data.
Recordholder:
Sponsor:
Joshua Jones
To Be Determined
PAC-E-IO-07/Rocky Mounta Power
September 7,2010
PUC Data Request 5
PUC Data Request 5
Please provide a complete copy of the Company's distrbution engineer design
manual.
Response to PUC Data Request 5
Plea see Attchment PUC 5.
Recordholder:
. Sponsor:
Doug Bennon
To Be Determed
PAC-E-1O-07/Rocky Mountain Power
September 7, 2010
PILC Data Request 6
PUC Data Request 6
Plea provide a complete copy of the Company's transmission engieer design
manual.
Response to PUC Data Request 6
Pleas Atthment PUC 6.
Recordholder:
Sponsor:
Doug Bennon
To Be Determined
PAC-E-I0-07/Rocky Mounta Power
September 7, 2010
PUC Data Request 7
PUC Data Request 7
Provide the calculation of the labor costs such tht it shows the amount the
Company is proposing to include in rates.
Response to PUC Data Request 7
Tota Company
Non-Utility / Capita Labor Portion
Utility Labor Porton (Accts 500 to 935)
Idaho Allocation (5.537%)
$733,743,074
$210,344,679
$523,398,394
$28,980,569
Please also refer to Exhbit No.2, page 4.3.4, colum "Proforma"
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
P AC-E-l 0-07/Rocky Mounta Power
September 7, 2010
PILC Data Request 8
PUC Data Request 8
Provide the followig inormation for each of the calenda yea 2004 though
2009:
a. Bas pay
b. Incentive compensation
c. Pension and benefit costs
Response to PUC Data Request 8
The Company objects to ths request to the extnt that it requests inormation
related to time periods not relevant to ths proceeding. Notwthtadi ths
objection, the Company responds as follows:
Please see below for the requested data from fiscal year 2006 though calendar
year 2009.
. Reg~larPii ..
OIrtme and Premium
Other Bare Labor
Incent.. Compeation
Penios & Bents
Payrol Taxes
12 Mas Ended
.. ..Mar-Q§
. . . 4t,~6,332
_ 55,033,635 .
29,204,747
5(,72,948
l60,~:L~3l
36,328,631
.. 732,33,67~ ....
. ... ..6,~l4~?3~ .....
192,735,64
533,38,30
NonlliUiYL:iir ..
capiizedL:ti
O&M Porio
CY200gy 2()!._~Y~0~8~V.20~
~~8,i79,Cl? ~,9~!9~ ..,5!771,165.i18,~!378
..6~S23'047 . 63,503,118 ...... 64,7.,818 ... 57!~l4~46
g2SS!793 13,52~é54 ..... .. 6Æ~,317 _ M12()'23
33,879,482 .. .. 29,8',~ 32,67,~ 30,776,233
.173,615,927 ......172,641,410 146!.~15!051 l5'~'138
36,613,260 35,60,79 37,42,m 38,397,33
~?,~,575 . .70~IQn,§6 . ~~'~19,I\.703'95,78
6,226'54..~,~4,l~.~71,?ll. (S7~'~??)
187,99,247 19,543,029 199,46,977 202,67,999
56,874,784 50,905,501 492,121,797 502,146,763
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-I 0-07/Rocky Mountain Power
September 7, 2010
PILC Data Request 10
PUC Data Request 10
Provide the actu bonuses and incentive compenson for each calenda that
would be added to "bare labor expenss" to arve at tota wages and salares that
are comparble to the Company's proposed rate case total wages and salares.
Response to.PllC Data Request 10
Please see below for the requested data from fiscal year 2006 though calenda
year 2009.
Twelve Month Ended Marh 2006
Bare Labor
Bonuses and Incentive Compensation
Calenda Year 2006
Bare Labor
Bonuses and Incentive Compensation
$484,864,713
50,728,948
$535,593,661
$512,990,907
33,879.482
$546,870,389
Calenda Year 2007
Bare Labor
Bonuses and Incentive Compensation
Calenda Year 2009
Bare Labor
Bonuses and Incentive Compensation
$463,954,508
29,875,948
$ 493,830,456
$477,398,300
32,677,359
$510,075,659
$483,834,081
30,776,233
$514,610,314
Calendar Year 2008
Bar Labor
Bonuss and Incentive Compensation
Recordholder:
Sponsor:
Steven.R. McDougal
Steven R. McDougal
P AC-E-I 0-07/Rocky Mountain Power
September 7, 2010
PUC Data Request 15
PUC Data Request 15
Provide the anua base salar, bonuses, stock options, and all other compensation
included in Rocky Mountain Power's proposed revenue requiement for the rate
period test year for each of Rocky Mountan Power's and PacifiCorp's executive
offcers including all individuas with the title of Vice President or higher in the
organzation.
Response to PUC Data Request 15
Please refer to Confdential Atthment PUC 15. Ths inormtion is confdential
and is provided subject to the terms and conditions of the protective agrement in '
this proceeding.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-07/Rocky Mounta Power
September 7, 2010
PILC Data Request 16
PUC Data Request 16
If wages and salaries and the costs of related employee benefits and payroll taes
included in the test period, and include any costs allocate or assigned from an
afliate, please provide the base wage, overte, benefits, taes, and other
amounts for each employee. Include a description of the seices provided and
the basis for the allocation/assignent of these amounts to Rocky Mountan
Power.
Response to PUC Data Request 16
There are no affiated wages (includig wage and benefit adjustment) except for
those chaged in the Affliated Management Fee. For the 12 month endig
12/31/2009, both labor and non-labor charges totaled $11,568,011.05 of which
only $8,353,029.34 was booked above the line. This was fuer reduced to
$7,300,000 as shown in Adjustment 4.8 in Exhbit No.2.
Recordholder: Henr E. Lay 1 Steven R. McDougal
Sponsor: Steven R. McDougal
PAC-E-10-07/Rocky Mountan Power
September 7,2010
PII C Data Request 18
PUC Data Request 18
Provide a list of all testimony, schedules, and workpapers in the company's filing
that impact wages and salares, employee benefits, and payroll taes.
Response to PUC Data Request 18
Wages and salares, employee benefits, and payroll taes are addressed in:
Dirt Testiony of Steven R. McDougal
Exhbit No.2, Adjustment 4.2 and 4.3
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-IO-07/Rocky Mounta Power
September 7, 20 I 0
PUC Data Request 19
PUC Data Request 19
Provide the following information for Rocky Mounta Power Idaho for each of
the calendar years 2010, 2009, 2008, 2007, 2006, 2005, and 2004:
a. Total wages and salares
b. Tota wages and salares charged to accounts 500 thoug 932
c. Tota wages and salares chaged to capita or other balance sheet accounts
d. Tota regular wages and saares
e. Tota overtme wages and salares.
Response to PUC Data Request 19
The Company objects to ths request to the extent tht it requests inormtion
related to tie periods not relevant to this proceeding. Notwthtading ths
objection, the Company responds as follows:
Wages and salares are added to benefits to arve at tota labor before being
alocated to accounts and jursdictions. For ths reason junsdictional allocation
can only be provided for tota labor. Attchment PILC 21 provides the tota labor
allocated to Idaho for accounts 500 though 935 and to capita accounts for fisca
year 2006, calendar year 2006 though 2009. Calendar year 2010 is not yet
available. The pro forma calenda year 2010 test period is provided in PILC 7.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
P AC-E- 1O-07/Rocky Mounta Power
September 7, 20 I 0
PUC Data Request 20
PUC Data Request 20
Provide the followig inormation for Rocky Mounta Power Idao by month for
2009:
a. Tota wages and salares
b. Tota wages and salares charged to acunts 500 through 932
c. Tota wages and salares chaged to capital or other balance sheet accounts
d. Tota regular wages and salares
e. Tota overtime wages and salares.
Response to PUC Data Request 20
The anua amount of tota wages and salares allocated to Idao ar provided in
the Company's response to PILC 21. Ths inormtion is not prepared on a
monthly basis.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-IO-07/Rocky Mountain Power
September 7, 2010
PILC Data Request 21
PUC Data Request 21
Provide the followig inormaton for PacifiCorp for each of the calenda years
2010,2009,2008,2007,2006,2005, and 2004:
a. Tota wages and salares
b. Tota wages and salares charged to accounts 500 though 932
c. Total wages and salares chaged to capital or other balance sheet accounts
d. Tota reguar wages and salares
e. Tota overtme wages and salares.
Response to PUC Data Request 21
The Company objects to ths request to the extent tht it requests inormation
related to tie periods not relevant to ths proceedig. Notwthstading ths
objection, the Company responds as follows:
Pleae refer to the Company's response to PUC 8 for (a) tota wages and salares,
(d) tota reguar wages and salares, and (e) tota overte wages and salares.
Attchment PILC 21 provides (b) tota labor for accounts 500 though 935 in total
and (c) capita and other balance sheet accounts for fisca year 2006 thugh
calendar year 2009. Actual calendar year 2010 is not yet available. The pro forma
calenda year 2010 test period is provided in Exhbit No.2, page 4.3.4 and in data
response PILC 7.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-1O-07/Rocky Mountain Power
September 7,2010
PILC Data Request 22
PUC Data Request 22
Explai in detal how Rocky Mountan Power's Idao waes and salares are
determned.
Response to PUC Data Request 22
Al PacifiCorp wages and salares are allocated to Idaho under the Revised
Protocol Allocation methodology. For example, the costs of a distrbution
lineman in Idaho are situ assigned to Idao. Simarly, the costs of a distbution
lineman in Uta are situ assigned to Utah. The costs related to generation,
trsmission, and genera across the system ar allocated to Idaho based on the
applicable Revised Protocol allocation factors. Pleas refer to Case No. P AC-E-
02-3 for detals regarding Revised Protocol methodology cost allocations.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
P AC-E-l 0-07/Rocky Mounta Power
September 7,2010
PILC Data Request 23
PUC Data Request 23
Are Rocky Mounta Power's Idaho wages and salares included in the total
wages and salares ofPacifiCorp?
Response to PUC Data Request 23
Yes. Please refer to the Company's response to PUC 22.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-I0-07/Rocky Mountan Power
September 7, 2010
PILC Data Request 24
PUC Data Request 24
Provide al workpapers, calcultions, assumptions, and source documentation
necessa to replicate all of the Company's proposed adjustments for wages and
salares though the end of the test year. Provide as much inormation as possible
in working electronic format (unocked and includig all formulas).
Response to PUC Data Request 24
Please refer to the attachment previously provided in data response Monsanto 1.5,
specifically the fie named "4.2 & 4.3 WEBA - il GRC Dec09.xls"
Please also refer to the atthment previously provided in data response IPUC
168.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-I0-07/RockyMountain Power
September 7, 2010
PIIC Data Request 25
PUC Data Request 25
Provide all wages and salares schedules and workpapers included in the
company's application in workig electronic format (unocked and including
formulas).
Response to PLLC Data Request 25
Please refer to the attachment previously provided in data response Monsanto 1.5,
specifically the fie naed "'4.2 & 4.3 WEBA - ID GRC Dec09.x1s" The
"Escalation" and "Labor Increases" tabs of the atthment provide the derivation
of wages and salares.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-1O-07/Rocky Mountan Power
September 7,2010
PILC Data Request 26
PUC Data Request 26
Provide all employee benefits schedules and workpapers included in the
company's application in workig electronic format (unocked and includig
formulas).
Response to PUC Data Request 26
Please refer to the atthment previously provided in data response Monsanto 1.5,
specifically the file named "4.2 & 4.3 WEBA - ID GRC Dec09.xls" The "Penion
& Benefits" tab of the attchment provides the derivation of employee benefits.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
P AC-E-I0-07 /Rocky Mountain Power
September 7, 2010
PILC Data Request 27
PUC Data Request 27
Provide all payroll ta schedules and workpapers included in the company's
application in workig electronic formt (unocked and includg formulas).
Response to PUC Data Request 27
Please refer to the attchment previously provided in data response Monsanto 1.5,
specifically the fie naed "4.2 & 4.3 WEBA - ID GRC Dec09.x1s" The "Payroll
Tax" tab of the attchment provides the derivation of payroll taes.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
P AC-E-I 0-07/Rocky Mountain Power
September 7, 2010
PILC Data Request 28
PUC Data Request 28
Provide the amount of incentive compensation included in the actu results of
operations for the twelve month of the test period by FERC account.
Response to PUC Data Request 28
Please refer to Attchment PILC 28.
Recordholder:
Sponsor:
HenrE. Lay
Steven R. McDougal
P AC-E-1 0-07/Rocky Mounta Power
September 7, 2010
PILC Data Request 29
PUC Data Request 29
Provide the number of employees included in Idaho operations by month for the
twelve month test period.
Response to PUC Data Request 29
PacifiCorp does not trck employees for Idaho operations or by any other state
operations.
Recordholder:
Sponsor:
Erich D. Wilson
To Be Deteed
PAC-E-IO-07/Rocky Mountai Power
September 7, 2010
PUC Data Request 30
PUC Data Request 30
Regarding PacifCorp's legal deparent, please provide the number of
employees for each position for 2000-2010.
Response to PUC Data Request 30
The Company objects to ths request to the extent tht it requests inormation
related to time periods not relevant to ths proceedng. Notwithstading ths
objection, the Company responds as follows: .
Pleae refer to Attchment PILC 30 for the requested information from fiscal yea
2006 though calenda year 2010.
Recordholder:
Sponsor:
HenrE. Lay
To Be Determned
PAC-E-I 0-07/Rocky Mounta Power
September 7, 2010
PIlC Data Request 31
PUC Data Request 31
Regarding PacifiCorp's legal deparent, please provide the expected number of
employees for each position for 2010-2015.
Response to PllC Data Request 31
The Company objects to ths request to the extent that it requests informtion
related to time periods not relevant to ths proceeding. Notwthstading ths
objection, the Company responds as follows:
Please refer to Attchment PIle 30 for the budgeted number of employees in
PacifiCorp's legal deparent in calenda year 2010. The Company has not yet
budgeted at this level of grularty beyond 2010.
Recordholder:
Sponsor:
HenrE. Lay
To Be Detered
P AC-E-1 0-07/Rocky Mountain Power
September 7, 2010
PILC Data Request 33
PUC Data Request 33
Please identify whether the Company's proposed revenue requiement includes
the costs associated with the Company's genera rate proceedings. If so, please
identify the tota costs, a categorical breakdown of the costs, the Idao allocated
costs, and an explanation of the Idao allocation.
Response to PllC Data Request 33
The Company's proposed revenue requirement includes the costs associated with
the Company's general rate proceedgs. Please refer to Confdential Atthment
PILC 33 for details. Ths inormation is confdential and is provided subject to the
term and conditions of the protective agreement in ths proceeding.
The costs associated with the Company's genera rate proceedigs include both
labor and non-labor components. The non-labor costs were $ 1,255,586 on a tota
Company basis. Idaho's porton of these costs is $ 36,656, which was calculated
using the interjunsdctional allocation factors. The labor expense associated with
the Compay's general rate proceedigs were $966,051 on a tota Company basis.
Labor expenses are generaly combined with all other labor and benefits before
being allocated to jursdictions. As a result, the labor expenses are not directly
available on an Idao allocate basis. However, the Idao allocated porton of the
labor expenses can be derived using an Idaho allocation of tota utility labor of
5.537%.
Recordholder:
Sponsor:
Henr E. Lay I Steven R. McDougal
Steven R. McDougal
P AC-E-1 0-07/Rocky Mountan Power
September 7, 2010
PIIC Data Request 35
PUC Data Request 35
Plea identify the tota legal deparent costs for 2000-2010, and expected legal
deparent costs for 2010-2015. Please provide a categorical breakdown and
description of PacifCorp' s legal departent costs.
Response to PUC Data Request 35
The Company objects to ths request to the extent tht it requests inormation
related to time periods not relevant to ths proceedg. Notwthtading this
objection, the Company responds as follows:
Please refer to Confdential Atthment PIle 35 for the legal deparent costs
and tota legal costs for 2005-2009. The budgeted inormation for 2010 is also
provided. This information is confdential and is provided subject to the terms
and conditions of the protective agreement in ths proceeding.
The Company ha not yet budgeted at the same level of granularty beyond 2010.
The legal deparent costs for 2011-2015 are expected to escalate due to ination
. and will fluctute based on the number of matters processed.
Recordh01der:
Sponsor:
Henr Lay
To Be Determined
PAC-E-10-07/Rocky Mountain Power
September 7, 2010
PUC Data Request 36
PUC Data Request 36
Please identify PacifCorp's total legal costs for 2000-2010, and expcted legal
costs for 2010-2015. Please provide a categorical breakdown and description of
PacifCorp's legal costs.
Response to PUC Data Request 36
The Company objects to ths request to the extent tht it requests inormtion
related to tie periods not relevant to ths proceedg. Notwthstadig ths
objection, the Company responds as follows:
Please refer to the Company's response to PILC Data Request 35.
Recordholder:
Sponsor:
HenrE. Lay
To Be Detrmned
PAC-E-IO-07/Rocky Mounta Power
September 7, 2010
PIlC Data Request 37
PUC Data Request 37
Please identify the number of in-hous attorneys, saares per each titles, and their
tota salares and other compensation.
Response to PUC Data Request 37
Please refer to Confdential Atthment PIlC 37. Confdential inormation is
provided subject to the terms and conditions of the protective agrment in this
proceeding.
Recordholder:
Sponsor:
HenrE. Lay
To Be Determed
P AC-E-l 0-07/Rocky Mountai Power
September 7, 2010
PILC Data Request 38
PUC Data Request 38
Regarding outside legal expenses, ha PacifiCorp taen any action to reduce
outside legal expenses through negotiating lower biling rates? If the anwer is
yes, please quatify the impact of the lower billig rates on the test year outside
legal expenses assumg all other assumptions regardig the determtion of
outside legal expenss rema constat.
Response to PUC Data Request 38
Yes. PacifiCorp follows its practice of negotiating lower billng rates, discounted
biling rates or alternative biling argements (e.g. flat fee or capped fee
services) for cert outside legal services. For matters that were expected to
incur significant legal fees, PacifiCorp solicited bids from law firms for providi
PacifiCorp legal servces. Whle ths ensured the company paid the lowest
reasonable cost for servces received, it did not necessarly result in an absolute
reduction in legal costs or biling rates compared to prior years. It did reduce
legal costs compared to what they otherwse would have been. Because it ha
been PacifiCorp's past practice to attempt to control outside legal expenses in ths
maner, and assuming all other assumptions regarding the detertion of
outside legal expense remais constat, PacifiCorp does not expect test year
outside legal fee expenses to be materially impacted by the contiuation of this
practice.
Recordholder:
Sponsor:
Henr Lay
To Be Determned
P AC-E-l 0-07/Rocky Mountain Power
September 7,2010
PUC Data Request 39
PUC Data Request 39
Please provide the actu or estimted biling rates for PacifiCorp's in house and
outside legal experts forFY 2003 though FY 2010.
Response to PUC Data Request 39
Please see AttchmentPUC 39.
Recordholder:
Sponsor:
HenrE. Lay
To Be Determed
PAC-E-1O-07/Rocky Mountan Power
September 7,2010
PUC Data Request 41
PUC Data Request 41
Regarding PacifCorp's outside legal expenses included in the test period. Please
provide a detailed explantion for the tys 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 attbutale to each case
or matter. In addition, please explain the differences between cert groups of
costs that have the sae "FERC Description."
Response to PUC Data Request 41
Please refer to Confdential Attchment PUC 41 for the outside legal expenses
included in the test year by FERC account and matter. Outside legal expenses are
recrded to the varous FERC accounts accordig to the natue of the costs in
accordance with the Code of Federal Reguations (CFR). "FERC Description" is
the name of the corresponding FERC account.
Confdential inormtion is provided subject to the terms and conditions of the
protective ageement in this proceedig.
Recordholder:
Sponsor:
HenrE. Lay
To Be Deted
PAC-E-l 0-07/Rocky Mounta Power
September 7, 2010
PILC Data Request 42
PUC Data Request 42
Regarding outside legal expenses included in the test period. For each "FERC
Description," please provide a detaled explantion for why each "il Factor" was
selected.
Response to PllC Data Request 42
The FERC account and relate FERC description to which Outside Legal
Expenses ar booked is derived from the underlying legal mattr being processed
for each of the Company's business unts. As such, legal expenses are spread
across a range of Operations and Maitenace FERC accounts. With test year
results, each FERC account is categorized by FERC fuction. Based on the
Revised Protocol allocation methodology, "ID factors" are assigned based on the
speific Function, FERC account and location of each tranaction posted.
Plea refer to Confdential Attchment PUC 41 for outside legal expenses
included in the test period. Confdential inormation is provided subject to the
terms and conditions of the protective agement in ths proceeing.
Recordholder: Donald R. Barsel / R. Bryce Dalley
Sponsor: To Be Determned
PAC-E-10-07/Rocky Mounta Power
September 7, 2010
PILC Data Request 44
PUC Data Request 44
Plea provide an explantion and all supportg information regardig 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 tht are
expected to differ.
Response to PUC Data Request 44
Pleae refer to Confdential Attchment PIlC 44 for the outside legal expenses for
the periods requested. Confdential inormation is provided subject to the terms
and conditions of the protective agreement in ths procedig.
Calenda year 2008 included envionmenta litigation expenses associated with
McConnell v PacifiCorp tht did not continue in 2009. If the costs of this
proceedng are taen out of CY 2008, total outside legal costs for CY 2008 are
comparable to CY 2009, which is comparable to the CY 2010 budget.
Recordholder: Natae Hocken / Dean Brokban 1 Mar Moech
Sponsor: To Be Determined
P AC-E-l 0-07/Rocky Mounta Power
September 7, 2010
PIlC Data Request 45
PUC Data Request 45
Please provide PacifiCorp's outside legal fee budgets for each calendar year from
2000-2010.
Response to PUC Data Request 45
Pleas refer to Confdential Atthment PUC 45 for the outside legal fee budgets
for the calenda years 2000-2010. Confdential inormation is provided subject to
the terms and conditions of the protective agreement in ths procedg.
Recordholder:
Sponsor:
HenrE. Lay
To Be Determned
P AC:E-I 0-07/Rocky Mounta Power
September 7,2010
PILC Data Request 46
PUC Data Request 46
Please identify the amount of outside legal fees tht were included in rates for
each general rate case in Oregon, Uta Californa, Washin, Idaho and
Wyomig since 2000. If the specific amount is unown because ofa settement
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.
Response to PUC Data Request 46
The Company objects to ths request to the extent that it requests information
related to time perods not relevant to ths proceedg. Notwthstdig th
objection, the Company responds as follows:
The Company ha not performed the requested analysis. However, in
Confdential Attchment PILC 35 the Company has provided extern legal costs
for 2005 -2009. These figues serve as the basis for general rae case filings made
durg ths period. Because of rate case settlements, it is not possible to
determe the exact amount of legal fees included in rates. However, these
amounts serve as the Company's best estiate of legal costs included in rates.
Recordholder:
Sponsor:
HenrE. Lay
To Be Determined
P AC-E-1 0-07/Rocky Mounta Power
September 7, 2010
PILC Data Request 49
PUC Data Request 49
Please provide a copy of distbution and trsmission facilties maps for each of
the Company's six servce terrtories.
Response to PUC Data Request 49
Please see Attchment PILC 49.
Recordholder:
Sponsor:
Doug Bennon
To Be Determed