20100910PIIC 64-85 to PAC.pdf

RECE r~;
Melinda J. Davison, OSB No. 930572
Davison Van Cleve, P.C.
333 SW Taylor, Suite 300
Portland, OR 97204
[phone]
[phone] (Fax)
mjd~dvclaw.com
20lUSEP lOAM 8: 10
lDi\HO
UTILITIES
Ronald L. Willams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays S1.
Boise ID, 83702
[phone]
[phone] (Fax)
ron~wiliamsbradbury.com
Attorneys for PacifiCorp Idaho Industrial 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-10-07
)
) NINTH 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 29,2010. 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 NINTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
Please provide the responses to these Data Requests by Wednesday, September
29,2010, 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]
consultrf~aoi.com
III. DATA REQUESTS
64. Please provide the last five years of O&M expense applicable to Idaho operations.
65. Please provide a copy of distribution and transmission facilties maps for each of the
Company's six service territories.
66. Please explain how Rocky Mountain Power recovers the costs of interconnection in its
Idaho retail rates.
67. Please refer to PIIC DR 2.13. Please ensure that the response includes the ownership of
Mid American Energy Holdings Company and all affliated companies.
68. Please provide the legal expense associated with Rocky Mountain Power's last five Idaho
general rate proceedings.
69. 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.
70. 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 fuctions
and categories.
71. Has Rocky Mountain Power included cost associated with the Independent Market
Monitor, Potomac Economics, in its calculation ofIdaho revenue requirement? If so,
please provide the accounts charged and amounts charged to each account.
72. Please provide the Idaho level of write-offs of doubtful accounts (bad debts) and
recoveries of previously wrtten-off accounts by month from Januar 2005 to present.
PAGE 2 - PIIC'S NINTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
73. Please provide the Idaho residential and commercial revenues by month and by rate class
from Januar 2005 to present.
74. Please provide the Idaho level of accruals for injures and damages expense and the Idaho
level of cash payouts for injures and damages claims, by year from 2005 through 2009.
75. Please provide the Idaho level of expense for outside contractors and consultats by year
from 2005 through 2009.
76. For each year from 2007 through 2009 please provide a breakdown, by FERC Uniform
System of Accounts, of Idaho allocated and Idaho direct non-labor costs.
77. For the 2010 test year please provide a breakdown by FERC USoA ofIdhao allocated
and Idaho direct non-labor costs.
78. For the 2010 test year please provide a breakdown by FERC USoA of Idaho allocated
and Idaho direct labor costs.
79. Please provide a detailed description/explanation/justification for each expense included
in the Idaho revenue requirement whose projected 2010 test year level is greater than or
equal to 10% over the calendar 2009 Idaho level of expense.
80. Please provide all analysis used in calculating the weather normalization adjustment.
Please provide all weather data utilzed and please identify all weather station(s) from
which the data utilzed was collected.
81. Please provide the basis/justification for any inflation rate that the company has utilzed
in estimating the calendar year 2010 cost levels.
82. Please provide the company's latest actuarial reports for both pensions and OPEBs.
83. Please provide all plan documents that describe incentive compensation programs
available to Rocky Mountain Power employees who either directly assign labor cost to
Idaho or allocate labor cost to Idaho. For each plan offered, please indicate the Idaho
level of expense calculated for the years 2006 though 2009 and for the test year.
84. Please provide a copy of the most recent consultant report used to assist the Company in
setting and adjusting compensation for its executives.
85. Are there any costs associated with the following projects in the company's Idaho
revenue requirement:
1. PAC Energy IT Projects
2. Hydro Dam Safety System
PAGE 3 - PIIC'S NINTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
3. Hydro Dashboard
If so, please identify each account impacted and the Idaho-related amount of cost charged
to each account identified. Also please provide the curently anticipated in-service date
for each of the above projects.
PAGE 4 - PIIC'S NINTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing Ninth Set of Data
Requests to Rocky Mountain Power on behalf of the PacifiCorp Idaho Industrial Customers upon
the paries, on the offcial service list shown below for PAC-E-10-07, via electronic maiL.
Dated at Portland, Oregon, this 8th day of September, 2010.~L~
Ted Weston
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
ted.weston~pacificorp.com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Ave., Suite 700
PO Box 467
Cheyenne, WY 82003
phickey~hickeyevans.com
Mark C. Moench
Daniel Solander
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
mark.moench~pacificorp.com
daniel.solander~pacificorp.com
(ELECTRONIC COPIES ONLY)
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
datarequest~pacificorp.com
Scott Woodbury
Deputy Attorney General
Idaho Public Utilties Commission
427 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
scott.woodbury~puc.idaho.gov
Randall C. Budge
Monsanto Company
Racine Olson Nye Budge & Bailey
201 E. Center
PO Box 1391
Pocatello,ID 83204-1391
rcb~racinelaw .net
Katie Iverson
Monsanto Company
Brubaker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
kiverson~consultbai.com
James R. Smith
Monsanto Company
PO Box 816
Soda Springs, ID 83276
jim.r.smith~monsanto.com
(ELECTRONIC COPIES ONLY)
PAGE 5 - PIIC'S NINTH 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, ID 83204-1391
elo~racinelaw .net
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
POBox 844
Boise, ID 83702
botto~idahoconservation.org
Brad M. Purdy
Community Action Partnership Association of
Idaho
Attorney at law
2019 N. 17th Street
Boise, ID 83702
bmpurdy~hotmail.com
Anthony Yankel
Idaho Irrigation Pumpers Association, Inc.
29814 Lake Road
Bay Vilage, OH 44140
tony~yankei.net
Tim Buller
Jason Harris
Agrium, Inc.
3010 Conda Road
Soda Springs, ID 83276
tbuller~agrium.com
jaharis~agrium.com
Ronald L. Williams
PacifiCorp Idaho Industrial Customers
Wiliams Bradbury, P.C.
1015 W. Hays St.
Boise,ID 83702
ron~wiliamsbradbury .com
PAGE 6 - PIIC'S NINTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER