20100910Staff 287-301 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
l".toLC "''4I ~
lOiû SE? l 0 AM to: 24
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-10-07
TENTH 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, SEPTEMBER 20, 2010.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER i SEPTEMBER 10, 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
IDAP A 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. 287: Please explain the process used to separate residential customer
sales and demand into Schedule i and Schedule 36 in moving from forecasted residential data to
schedule-specific data used in the cost of service study. Please provide any supporting
documentation.
REQUEST NO. 288: Please provide the ratios of Schedule 36 customers to all
residential customers for the last five years.
REQUEST NO. 289: Why does the Company believe Schedule 36 wil shrink in 2010
relative to 2009? Please provide any supporting documentation used to justify the response.
REQUEST NO. 290: How did the Company divide energy into on-peak and off-peak
periods in determining 2009 sales for Schedule 36? Is the same relation used for 2010 sales?
Please explain why or why not.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 10, 2010
REQUEST NO. 291: Please provide a comparison of the forecasted normalized sales
used in this case to actual weather normalized sales for all available months in 2010 for
residential customers, separated by schedule.
REQUEST NO. 292: Please provide a comparison of the forecasted customers used in
this case to actual customers for all available months in 2010 for residential customers, separated
by schedule.
REQUEST NO. 293: Please provide the actual capital structure for PacifiCorp as of
June 30, 2010.
REQUEST NO. 294: Please provide schedules showing the embedded cost of debt and
preferred stock for PacifiCorp as of June 30, 2010.
REQUEST NO. 295: Please provide revised schedules showing the capital structure,
cost of debt and cost of preferred stock for PacifiCorp estimated as of December 31, 2010.
REQUEST NO. 296: Please provide a schedule showing the amount of AFUDC
included in the Bridger coal stripping costs. Please provide this information in excel format by
month for the period 2009 - 2010 to date.
REQUEST NO. 297: Please provide the amounts received from successful real estate
tax appeals for the period from 2005-2009 and 2010 to date.
REQUEST NO. 298: Please provide a narrative of all Company safety measures
undertaken during 2008 and 2009.
REQUEST NO. 299: Please provide a narrative of all cost saving measures undertaken
by the Company from 2008-current.
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 10, 2010
REQUEST NO. 300: Does Rocky Mountain Power require a certain level of expertise
to connect or disconnect a meter? In other words, can a collector or a meter reader connect or
disconnect a meter? Please provide the title and hourly wage for those employees who are
authorized to perform meter connects and disconnects.
REQUEST NO. 301: On average, on a regular work day, Monday through Friday, in
Idaho, how many transfers of account responsibilty occur? This should also include not only
transfers of responsibility for existing residences and small businesses but customers moving into
newly constructed homes and businesses.
DATED at Boise, Idaho, this /o7Jay of September 2010.
~~
Scott Woodbury
Deputy Attorn~
Technical Staff: Bryan Lanspery/287-292
Terri Carlock/293-295
Cecily Vaughn296
Donn English/297-299
Marilyn Parker/300-301
i:umisc:prodreqlpace i o. 7swbltccvdemp prod reqlO
TENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 10, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF SEPTEMBER 2010,
SERVED THE FOREGOING TENTH 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.westonCipacificorp.com
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moenchiipacificorp.com
daniel.solanderiipacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbiiracinelaw.net
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithiimonsanto.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tonyiiyankel.net
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
E-MAIL: phickeyCihickeyevans.com
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
E-MAIL: datarequestiipacificorp.com
KATIE IVERSON
BRUBAKER & ASSOCIATES
17244 W CORDOVA CT
SURPRISE AZ 85387
E-MAIL: kiversoniiconsultbai.com
ERICLOLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloiiracinelaw.net
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbullerCiagrium.com
jaharisCiagrium.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: bottoiiidahoconservation.org
MELINDA J DA VISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E-MAIL: mjdCidvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 W HAYS STREET
BOISE ID83702
E-MAIL: roniiwillamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyCihotmail.com
Jo~rySECRET AR --
CERTIFICATE OF SERVICE