20101122PIIC 177-186 to PAC.pdf

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
f:.
'l8\ß NQV 22 M~ 8: 44
Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays St.
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 APPLICATION OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES.
)
) CASE NO. PAC-E-10-07
)
) TWENTIETH 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/b/a Rocky Mountain Power (the
"Company"), provide the following documents and information on or before Friday,
November 26,2010. 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 TWENTIETH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
Please provide the responses to these DataRequests by no later than Friday,
November 26,2010, to:
Melinda Davison
Davison Van Cleve, P.C.
333 S.W. Taylor St., Ste. 400
Portland, Oregon 97204
[phone]
mjd~dvclaw.com
Greg R. Meyer
Brubaker & Associates, Inc.
P. O. Box 412000
St. Louis, Missouri 63141-2000
[phone]
gmeyer~consultbai.com
DATA REQUESTS
177. Please provide the anual number of employees who have left Rocky Mountain
Power during the last 5 years which cited compensation as the reason for leaving
Rocky Mountain Power. Please provide the information by year.
178. Does Rocky Mountain Power/PacifiCorp conduct exit interviews or employee exit
sureys? Are these interviews or sureys documented? Please provide a copy of any
documentation used to conduct exit interviews or exit surveys.
179. What is the average employment tenure of Rocky Mountain Power/PacifiCorp
employees over the past five years? Please provide the information on a union and
non-union basis.
180. For calendar years 2008 and 2009, please provide the number and percentage of
Rocky Mountain Power/PacifiCorp employees who did not receive any incentive
compensation payments. For the same period of time, please provide the number and
percentage of employees who received taget, below taget and above target incentive
compensation payments.
181. Please indicate the last year when Rocky Mountain Power/PacifiCorp did not pay
incentive compensation to its employees. Please provide an explanation why there
was no incentive compensation paid for that year.
182. Please indicate the last year when the Rocky Mountain Power/PacifiCorp workforce,
as a whole, was paid incentive compensation below the target leveL.
PAGE 2 - PILC'S TWENTIETH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
183. Historically has Rocky Mountain Power/PacifiCorp only made incentive
compensation payments up to the level that was determined to be recovered in
customer rates?
184. Please provide the 20 year normal for weather as calculated by Rocky Mountain
Power/PacifiCorp. Is the 20 year normal based off of 50 degree cooling degree day
, temperatue? If so, please provide all rational for use of that level ofCDD
temperatue. If not please provide the CDD temperatue used. What is NOAA's
temperature for measurng CDD?
185. Referencing page 16 of Steven R. McDougal's rebuttal testimony:
a. For each of the jurisdictions listed on lines 19 and 20, plea~e indicate if Cash
Working Capital was a fully litigated issue or if the issue was settled.
b. If Cash Working Capital was a litigated issue, please provide a copy of each
Commission or regulatory body's decision as it related to Cash Working CapitaL.
c. If Cash Working Capital was a settled issue, please provide a copy of each settlement
agreement or testimony showing that other paries accepted the Company's Cash
Working Capital Position.
d. Please explain why the Company decided not to use the 2007 Cash Working Capital
Study for the most recent Washington rate case.
186. For each of the capital projects projected to be in service by December 31, 2010 in
and included in the Company's direct filed revenue requirement calculation, please
list all changes in expected in-service dates.
PAGE 3 - PUC'S TWENTIETH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing Twentieth Set of
Data Requests to Rocky Mountain Power on behalf of the PacifiCorp Idaho Industrial Customers
upon the paries, on the official service list shown below for PAC-E-10-07, via electronic maiL.
Dated at Portland, Oregon, this 18th day of November, 2010.. ~/eJ"
Sarah A. Kohler
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
PAGE 4 - PUC'S TWENTIETH 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
Anthony Yankel
Idaho Irrigation Pumpers Association, Inc.
29814 Lake Road
Bay Vilage, OH 44140
tony~yankei.net
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
POBox 844
Boise, ID 83702
botto~idahoconservation.org
Dr. Don Reading
Idaho Conservation League
6070 Hil Road
Boise, ID 83603
dreading~mindspring.com
(ELECTRONIC COPIES ONLY)
Brad M. Purdy
Community Action Partnership Association of
Idaho
Attorney at law
2019 N. 17th Street
Boise, ID 83702
bmpurdy~hotmail.com
Ronald L. Wiliams
PacifiCorp Idaho Industrial Customers
Wiliams Bradbury, P.C.
1015 W. Hays St.
Boise, ID 83702
ron~wiliamsbradbur .com
Tim Buller
Jason Harris
Agrium, Inc.
3010 Conda Road
Soda Springs, ID 83276
tbuller~agrium.com
jaharis~agrium.com
PAGE 5 - PUC'S TWENTIETH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER