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Home My WebLink About20100913PIIC 86-101 to PAC.pdf..r- f' r-i\k"jL Melinda J. Davison, OSB No. 930572 Davison Van Cleve, P.C. 333 SW Taylor, Suite 300 Portland, OR 97204 (503) 241-7242 (503) 241-8160 (Fax) mjd~dvc1aw.com 20m SEl l 3 PM 2: 42 Ronald L. Wiliams, ISB No. 3034 Wiliams Bradbur, P.C. 1015 W. Hays St. Boise ID, 83702 (208) 344-6633 (208) 344-0077 (Fax) ron~willamsbradbur.com Attorneys for PacifiCorp Idaho.Industral Customers 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 SET OF DATA REQUESTS ) TO ROCKY MOUNTAIN POWER ) OF THE PACIFICORP IDAHO ) INDUSTRIAL CUSTOMERS ) ) PacifiCorp Idaho Industrial Customers("PIlC"), 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 Thursday, September 30, 2010. For the definitions and instructions that apply to these data requests, please refer to PIlC's First Set of Data Requests dated August 12,2010. PAGE 1 - PILC'S TENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER Please provide the responses to these Data Requests by Thursday, September 30, 2010, to: Melinda Davison Davison Van Cleve, P.C. 333 S.W. Taylor St., Ste. 400 Portland, Oregon 97204 (503) 241-7242 mai1~dvclaw.com Greg Meyer Brubaker & Associates, Inc. P. O. Box 412000 St. Louis, Missouri 63141-2000 gmeyer~consultbai.com III. DATA REQUESTS 86. Please refer to PILC Data Request 64. Please identify Idaho O&M expense by year and FERC USA, and separately identify all labor O&M. 87. Please identify by year, the last 5 years ofIdaho (please separately identify allocations) injuries and damages expenses and claims paid. Please identify amount included in rate case. Is amount included in rate case based on historical expense, historical claims paid, or budgeted expense level? 88. Please identify the amount ofIdaho bad debts included in the rate case. 89. Please identify by year, the last 5 years ofIdaho power plant maintenance. For each year, identify the costs as materials, outside labor (Non-PacifiCorp employees), and internal labor (including allocated labor). Please identify amount included in rate case. Please separate amount included in rate case by as materials, outside labor (Non-PacifiCorp employees), and internal labor (including allocated labor). 90. . Please provide a 10-year history level of scheduled power plant maintenance outages. 91. Please identify by year, the last 5 years ofIdaho storm restoration expense. For each year, identify the costs as materials, outside labor (Non-PacifiCorp employees), and internal labor (including allocated labor). Please identify amount included in rate case. Please separate amount included in rate case by as materials, outside labor (Non- PacifiCorp employees), and internal labor (including allocated labor). 92. Please identify by year, the last 5 years ofIdaho program vegetation management (tree- trimming) expense. For each year, identify the costs as materials, outside labor (Non- PacifiCorp employees), and internal labor (including allocated labor). Please identify amount included in rate case. Please separate amount included in rate case by as materials, outside labor (Non-PacifiCorp employees), and internal labor (including allocated labor). PAGE 2 - PIlC'S TENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER 93. Please identify by year and by FERC USOA, the next 5 years of Idaho capital and O&M expense budgets reflecting all allocated costs. 94. Please provide copies of all incentive plan documents for the test year and any subsequent revisions. 95. Please identify by year for the last 5 years, Idaho amount of allocated costs separated by entity allocating costs. 96. Has PacifiCorp, Rocky Mountain Power, and/or the Idaho operations of Rocky Mountain Power sold any SOi Emission Allowances in the past 5 years? If so, please identify by year for the last 5 years the SOi Emission Allowance revenues. 97. Please provide a breakdown of Idaho miscellaneous revenues by type and by year for the last 5 years. 98. Please provide a sumar sheet detailing the percentage of the service company costs allocated to each operating jurisdiction for each of the last 5 years. 99. Please identify by year for the last 5 years, Idaho level of outside services expense. 100. Please list all adjustments proposed (and value of adjustment) that extend the costs beyond the test year. 101. Please provide the following: a. The Company policy which describes all steps that are taen in the process of wrting off an account as uncollectible from beginnng to end. b. Are there a specific number of days before an account is wrtten off? If yes, are those days calculated as calendar days or business days? c. Please explain the point at which the Company stars calculating a wrte-off period. Is it different than the first biling of the last unpaid bil? If yes, please identify the difference or lapse of time that occurs. PAGE 3 - PIlC'S TENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served the foregoing Tenth Set of Data Requests to Rocky Mountain Power on behalf of the PacifiCorp Idaho Industrial Customers upon the parties, on the offcial service list shown below for PAC-E-1O-07, via electronic maiL. Dated at Portland, Oregon, this 9tJday of September, 2010. s~~ Ted Weston PacifiCorp/dba Rocky Mountain Power 201 S. Main Street, Suite 2300 Salt Lake City, UT 84111 ted.weston(gpacificorp.com Paul J. Hickey Hickey & Evans, LLP 1800 Carey Ave., Suite 700 PO Box 467 Cheyenne, WY 82003 phickey(ghickeyevans.com Mark C. Moench Daniel Solander PacifiCorp/dba Rocky Mountain Power 201 S. Main Street, Suite 2300 Salt Lake City, UT 84111 mark.moench(gpacificorp.com daniel. so lander(gpacificorp.com (ELECTRONIC COPIES ONLY) Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 datarequest(gpacificorp.com Scott Woodbury Deputy Attorney General Idaho Public Utilties Commission 427 W. Washington (83702) PO Box 83720 Boise, ID 83720-0074 scott.woodbury(gpuc.idaho.gov Randall C. Budge Monsanto Company Racine Olson Nye Budge & Bailey 201 E. Center PO Box 1391 Pocatello, ID 83204-1391 rcb(gracinelaw.net Katie Iverson Monsanto Company Brubaker & Associates 17244 W. Cordova Court Surprise, AZ 85387 kiverson(gconsultbai.com James R. Smith Monsanto Company PO Box 816 Soda Springs, ID 83276 jim.r.smith(gmonsanto.com (ELECTRONIC COPIES ONLY) PAGE 4 - PILC'S TENTH 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(gracinelaw.net Benjamin J. Otto Idaho Conservation League 710 N. 6th Street POBox 844 Boise, ID 83702 botto(gidahoconservation.org Brad M. Purdy Community Action Partnership Association of Idaho Attorney at law 2019 N. 17th Street Boise, ID 83702 bmpurdy(ghotmail.com Anthony Yankel Idaho Irrigation Pumpers Association, Inc. 29814 Lake Road Bay Vilage, OH 44140 tony(gyankel.net Tim Buller Jason Harris Agrium, Inc. 3010 Conda Road Soda Springs, ID 83276 tbuller(gagrium.com jahars(gagrium.com Ronald L. WiIliams PacifiCorp Idaho Industrial Customers Wiliams Bradbury, P.C. 1015 W. Hays St. Boise, ID 83702 ron(gwiliamsbradbury .com PAGE 5 - PILC'S TENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER