20100922PAC to PIIC 64-79, 81-85.pdf

~~.£OUNTAIN Di:r-l'\.L.\..
zoroSE? 22 AM 9= 26 201 South Main, Suite 2300
Salt Lake Cit, Utah 84111
September 21, 2010
Melinda Davison
Davison Van Cleve, P.C.
333 S.W. Taylor St., Ste. 400
Portand, Oregon 97204
Randal J. Falenberg
RFI Consultig, Inc.
PMB362
8343 Roswell Road
Sandy Sprigs, GA 30350
RE: ID PAC-E-1O-07
PIIC Data Request (65-84)
Please fid enclosed Rocky Mounta Power's responses to PILC Dat Requests 65-84,
excludig PIlC 80. This response will be provided separately. Provided on the enclosed CD are
Attchments PILC 64, 67, 71, 72, 73, 74, 76, 78, 79, 82 -(1-2),83, and 85.
If you have any questions, please feel free to call me at [phone].
Sinceely,
J. T.d Ú/~ /4A
J. Ted Weston
Maner, Regulation
Enclosure:
cc:' Jean Jewell/UC (C)/ 3 copies
Enc OlsenlPA (C)
Ben OtIICL (C)
Radal Budge/Monsanto (C)
James R. Smithonsanto (C)
Richad AndersonIonsanto (C)
Gerge C. Carer, IIonsanto (C)
Des PeseuIonsato (C)
Ga R. Kajander/Monsto (C)
Maurce Brubaker/Monsanto (C)
Bna Collinonsto (C)
Michal Goimanonsto (C)
Ka Iveron/onsanto (C)
Ma Widmer/Monsanto (C)
P AC-E- 10-07 /Rocky Mountain Power
September 21, 2010
PILC Data Request 64
PIIC Data Request 64
Please provide the last five years of O&M expense applicable to Idaho operations.
Response to PIIC Data Request 64
Please refer to Attachment PILC 64.
As discussed in the direct testimony of Company witness Steven R. McDougal,
the test period in this case is the twelve-months ended December 3 i, 2009, with
limited known and measurable adjustments through December 3 I, 2010.
Idaho allocated amounts for year 2006 - 2008 are calculated using historical
factors as filed in the yearly Results of Operations reports for each respective
period. Idaho allocated amounts for 2009 actual and 2009 test year are calculated
using factors as filed in tab 10 of Steven R. McDougal's Exhibit NO.2.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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P AC-E-l 0-07/Rocky Mountain Power
September 21, 2010
PILC Data Request 65
PIIC Data Request 65
Please provide a copy of distribution and transmission facilities maps for each of
the Company's šix service territories. .
Response to PIIC Data Request 65
Please refer to the Company's response to PIIC Data Request 49.
Recordholder:
Sponsor:
Doug Bennion
To Be Determined
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PAC-E-10-07/Rocky Mountain Power
September 21, 2010
PIIC Data Request 66
PIIC Data Request 66
Please explain how Rocky Mountain Power recovers the costs of interconnection
in its Idaho retail rates.
Response to PIIC Data Request 66
Direct assigned costs are paid by the interconnection customers. The direct
assigned costs for non,;utility customers are not collected in retail rates since those
costs are not incured by the utility. Direct assigned costs and network upgrade
costs attributable to utilty generators are reflected in the utility's rate base and
ear the allowed rate of return. Network upgrade costs attibutable to other
interconnection customers are initially paid by the interconnection customer and
thus are initially deducted from transmission rate base. The rate base deduction is
gradually extinguished as the interconnection customer's payment is refuded
over time. The interconnection costs are then recovered via transmission rates
charged to users of the transmission system.
Recordholder:
Sponsor:
Denns Desmarais
To Be Determined
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P AC-E- 1 0-07/Rocky Mountain Power
September 21, 2010
PIlC Data Request 67
PIIC Data Request 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.
Response to PIIC Data Request 67
Please refer to Attachment PIIC 67.
Recordholder:
Sponsor:
Christy Chaney
To Be Determined
P AC-E-'l 0-07/Rocky Mountain Power
September 21,2010
PIIC Data Request 68
PIIC Data Request 68
Please provide the legal expense associated with Rocky Mountain Power's last
five Idaho general rate proceedings.
Response to PH C Data Request 68
Please refer to the Company's response to PIIC Data Request 32.
Recordholder:
Sponsor:
Gar Tawwater
To Be Determined
PAC-E- I 0-07/Rocky Mountain Power
September 21, 2010
PILC Data Request 69
PHC Data Request 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.
Response toPHC Data Request 69
Please refer to the Company's response to PUC Data Request 33.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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PAC-E-lO-07/Rocky Mountain Power
September 2 i, 20 i 0
PILC Data Request 70
PUC Data Request 70
Please provide a total and detailed functional 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 functions and categories,
Response to PIIC Data Request 70
Please refer to the Company's response to PUC Data Request 34.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-07/Rocky Mountain Power
September 2 i, 2010
PILC Data Request 71
PIIC Data Request 71
Has Rocky Mountain Power included cost associated with the Independent
Market Monitor, Potomac Economics, in its calculation of Idaho revenue
requirement? If so, please provide the accounts charged and amounts charged to
each account.
Response to PIIC Data Request 71
Yes. Please refer to Attachment PILC 71 for the amounts included in the Idaho
revenue requirement.
Recordholder: Steven R. McDougal
Sponsor: Steven R. McDougal
PAC-E-l 0-07/Rocky Mountain Power
September 21, 2010
PILC Data Request 72
PIIC Data Request 72
Please provide the Idaho level of wrte-offs of doubtful accounts (bad debts) and
recoveries of previously written-off accounts by month from Janua 2005 to
present.
Response to PIIC Data Request 72
Please refer to Attachment PIlC 72.
Recordholder:
Sponsor:
BenHo
Henr Lay
PAC-E- 1 0-07/Rocky Mountain Power
September 21,2010
PILC Data Request 73
Please provide the Idaho residential and commercial revenues by month and by
rate class from Januar 2005 to present.
PIIC Data Request 73
Response to PIIC Data Request 73
The Company objects to this request to the extent that it request information from
time periods not relevant to this proceeding. Notwithstanding this objection, the
Company responds as follows:
Please refer to Attachment PILC 73. The information provided excludes the BPA
credit in accordance with how revenue information is reported in the SEC i O-K
and 10-Q reports.
Recordholder:
Sponsor:
Romita Biswas
To Be Determined
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PIIC Data Request 74
PAC-E-IO-07/Rocky Mountain Power
September 21,2010
PILC Data Request 74
Please provide the Idaho level of accruals for injuries and damages expense and
the Idaho level of cash payouts for injuries and damages claims, by year from
2005 though 2009.
Response to PIIC Data Request 74
The Company objects to this request to the extent that it request information from
time periods not relevant to this proceedíng. Notwithstading this objection, the
Company responds as follows:
Please refer to Attchment PUC 74. Factor allocation percentages and method
reflected in this attchment reflect those filed in the anual results of operations
reports for each respective year.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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PAC-E-10-07/Rocky Mountain Power
September 21, 2010
PIlC Data Request 75
PUC Data Request 75
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Please provide the Idaho level of expense for outside contractors and consultats
by year from 2005 though 2009.
Response to PIIC Data Request 75
The Idaho level of expense for outside contractors and consultants by year from
2005 though 2009 is:
2005 $12,109,210
2006 $13,786,141
2007 $14,088,100
2008 $ 14,548,456
2009 $15,916,106
Recordholder:
Sponsor:
Gary Tawwater
Henr Lay
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P AC-E-I 0-07/Rocky Mountain Power
September 21, 2010
PILC Data Request 76
PIIC Data Request 76
For each year from 2007 though 2009 please provide a breakdown, by FERC
Uniform System of Accounts, ofIdaho allocated and Idaho direct non-labor costs.
Response to PUC Data Request 76
Please refer to Attachment PIlC 76.
Idaho allocated amounts for years 2007 - 2008 are calculated using historical
factors as filed in the yearly Results of Operations reports for each respective
period. Idaho allocated amounts for 2009 are calculated using factors as fied in
tab 10 of Steven R. McDougal's Exhibit No.2.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-IO-07/Rocky Mountain Power
September 21, 2010
PILC Data Request 77
PIle Data Request 77
For the 2010 test year please provide a breakdown by FERC USoA of Idaho
allocated and Idaho direct non-labor costs:
Response to PIIC Data Request 77
Please refer to Attchment PILC 76. Idaho allocated amounts for the test year are
calculated using factors as filed in tab 10 of Steven R. McDougal's Exhibit No.2.
As discussed in the direct testimony of Company witness Steven R. McDougal,
the test period in this case is the twelve-months ended December 31, 2009 with
limited known and measurable adjustments through December 31, 2010.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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PAC-E-10-07/Rocky Mountain Power
September 21, 2010
PILC Data Request 78
PIIC Data Request 78
F or the 2010 test year please provide a breakdown by FERC USoA of Idaho
allocated and Idaho direct labor costs.
Response to PIIC Data Request 78
Please refer to Attachment PUC 78. Idaho allocated amounts for the test year are
calculated using factors as fied in tab 10 of Steven R. McDougal's Exhibit No.2.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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PAC-E-IO-07/Rocky Mountain Power
September 21,2010
PUC Data Request 79
PIIC Data Request 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.
Response to PII C Data Request 79
Please refer to Attchment PUC 79 for descriptions of variances greater than or
equal to 10% from the actual 2009 expenses to the test period levels.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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P AC-E-1 0-07/Rocky Mountain Power
September 21,2010
PUC Data Request 81
PIIC Data Request 81
Please provide the basis/justification for any inflation rate that the company has
utilzed in estimating the calendar ytar 2010 cost levels.
Response to PIIC Data Request 81 l' "
Please refer to the Company's response to PUC Data Request 63.
Recordholder: Steven R. McDougal .
Sponsor: Steven R. McDougal
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PAC-E-10-07/Rocky Mountain Power
September 21, 2010
PUC Data Request 82
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Please provide the company's latest actuarial reports for both pensions and
OPEBs.
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PIIC Data Request 82
Response to PUC Data Request 82 k'c
Please refer to Attachments PILC 82 -1 and 82 -2.
Recordholder:
Sponsor:
Erich D. Wilson
Erich D. Wilson
PAC-E-IO-07/Rocky Mountain Power
September 21, 20 10
PILC Data Request 83
PIIC Data Request 83
Please provide all plan documents that describe incentive compensation programs
available to Rocky Mountan 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 through 2009
and for the test year.
Response to PIIC Data Request 83
The Company objects to this request to the extent that it requests information
related to time periods not relevant to this proceeding. Notwithstading this
objection, the Company responds as follows:
Please refer to Attachment PILC 83 for the incentive compensation programs
available to Rocky Mountain Power employees.
These incentive compensation costs lire combined with all other labor and benefit
expenses before being allocated to jursdictions. As a result, these costs are not
directly available on an Idaho allocated basis. However, these costs can be
calculated using the Idaho allocation of total utilty labor. Please refer to the table
below:
Cy 2007 Cy 2008 Cy 2009 CY 2009
Actual Actual Actual Test Period
Total Company 29,875,948 31,142,229 29,876,294 32,19p,000
Non-Utilty I Capital 8,564,538 8,927,543 8,564,637 9,229,627
(28.667%)
Utilty Labor (72.333%)21,311,410 22,214,686 21,311,657 22,966,373
Idaho % of Utilty Labor 5.537%5.537%5.537%5.537%
Idaho Allocation 1,180,013 ': '1,230,027 1,80,026 1,271,648
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Please note, for puroses of this ,data response, the current rate case percentages
were applied to all accounting periods
Recordholder:
Sponsor:
Erich D.Wilson / Steven R. McDougal
Erich D. Wilson ¡Steven R. McDougal "r
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P AC-E-1 0-07/Rocky Mountain Power
September 21, 2010
PILC Data Request 84
PIIC Data Request 84
Please provide a copy of the most recent consultat report used to assist the
Company in setting and adjusting compensation for its executives.
Response to PIIC Data Request 84
The Company does not have a specific consulting report used for setting
executive compensation.
Recordholder:
Sponsor:
Erich D. Wilson
Erich D. Wilson
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PAC-E-IO-07/Rocky Mountain Power
September 21, 2010
PUC Data Request 85
PIIC Data Request 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
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 currently anticipated
in-service date for each of the above projects.
Response to PIIC Data Request 85
The Company's revenue requirement in this proceeding includes actual rate base
as of December 2009 and pro forma plant additions that are over $5 milion,
which wil be placed into service by December 2010. Please refer to the Pro
Forma Major Plant Addition Adjustment(8.6) in this fiing.
1) PAC Energy IT Projects: This category covers miscellaneous IT related
projects. Please refer to Attchment PUC 85 for a list of projects placed in
servce during 2009 that would fall under this category.
2) The expected in-service date for the Hydro Dam Safety System is October
2011. This project has not been included in the Idaho revenue requirement in
this proceeding.
3) The expected in-service date for the Hydro Dashboard is November 2012.
This project has not been included in the Idaho revenue requirement in this
proceeding.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal