20110722Staff 51-113 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 14
ISB NO. 6864
RrCEP!¡: lìc,; i~i-_'
2011 JUl 22 PM 2: 18
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
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-l1-12
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information on or before
FRIDAY, AUGUST 12,2011.
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 wil 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
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JULY 22,2011
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 51: Please provide all revenue normalization models used to develop
the biling determinants shown in Exhibit No. 48. As par of the response, please include:
a. The executable electronic models used to determine the proposed adjustments for
special contract curailments, Class 1 DSM programs, and weather.
b. Detailed explanation of all the modeling variables, along with the descriptive
statistics used to evaluate the predictive accuracy of each modeL.
REQUEST NO. 52: On page 8, lines 15-16 of McDougals testimony, regarding how
the 2010 coincident peaks in the filing were adjusted to reflect the load curtailments from Class 1
DSM programs, he states, "Reductions in peak loads due to the programs operating at time of
system coincident peak were added back to the relevant jurisdictions." In the last case, the
coincident peaks for relevant jurisdictions were adjusted downward to reflect programs not
operating at the time of system coincident peak (Case No. PAC-E- 1 0-07). Please explain why
treatment of Class 1 DSM program impacts on system coincident peak is treated differently in
the two cases.
REQUEST NO. 53: On page 7, lines 4-6 of Griffth's testimony, regarding the need for
higher increases in the demand charges than for energy charges, he states "Based on the class
cost of surey (sic) results which show that higher increases are needed for demand charges than
for energy charges, the Company proposes slightly greater increases to demand rates than to
energy rates." Please explain why higher demand charges are indicated in this COS study
compared to the COS study provided in Case No. PAC-E-10-07 (e.g. - changing methodologies,
dropping load factors, etc.).
REQUEST NO. 54: Please provide a schedule of Contributions in Aid of Construction
(CIAC) as of December 31, 2010 showing names, dates, amounts and accounts used. Please
include within your response any significant changes to CIAC occuring in, or planed for 201 1.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 22, 2011
REQUEST NO. 55: Please provide a schedule of Customer Advances for Construction
for the year ending 2010 showing names, dates, amounts and accounts used. Please include
within your response any significant changes to Advances occurring in, or planed for 201 1.
REQUEST NO. 56: Please provide an analysis of the sale of land and plant for the years
2010 and 201 1 to date. Please show gains, losses and supporting documentation including
accounting entries for removal of items from rate base.
REQUEST NO. 57: Please provide details of any planned sales ofland and/or plant for
the remainder of 201 1. Please include within your response the estimated date of these sales and
planed treatment (including accounting entries) of them.
REQUEST NO. 58: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2010 through 201 1 to date.
REQUEST NO. 59: Please provide a list of all pending legal cases and their status
including description of the issue, estimates of liability and possible ramifications to the
Company.
REQUEST NO. 60: Please provide the amounts spent for injuries and damages for the
years 2010 to date. Please include within your response the description of each item, the amount
for each item and the account charged.
REQUEST NO. 61: Please provide detail of all advertising expenses recorded above the
line including account and subaccount where posted, dates posted, vendor names, explanations,
and amounts posted during 2010. Please identify each expense that is related to safety.
REQUEST NO. 62: Please provide copies of the ads used during 2010 and correlate the
ad copy with the specific detail provided in the preceding production request response.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 22,2011
REQUEST NO. 63: Please provide a list of all consultants who performed services for
Rocky Mountain Power and PacifiCorp for the years 2010 to date. Please include within your
response the services performed, amounts paid, the accounts charged, the allocation factor and
amount allocated to the Idaho jurisdiction.
REQUEST NO. 64: Please provide copies of all internal audit reports for the years 2010
to date.
REQUEST NO. 65: Please provide a description of all audits/organizational reviews
currently in progress or planned through 2012 year-end. Please include within your response the
description of reviews that are curently underway for which no report has been issued and the
estimated report date.
REQUEST NO. 66: Please provide a copy of the policy for bad debt write-offs and
collection of past due amounts.
REQUEST NO. 67: Please provide a schedule of bad debt amounts for 2010 and 201 1
to date.
REQUEST NO. 68: Please provide an analysis of the growth in uncollectibles the
Company has experienced and the related factors, the actions taken to manage those
uncollectibles and the likelihood of that growing trend to reverse (and when).
REQUEST NO. 69: Please provide the amounts spent for injuries and damages for the
years 2010 and 2011 to date. Please include within your response the description of each item,
the amount for each item and the account charged.
REQUEST NO. 70: Please provide copies of all biling inserts for the year 2010.
Indicate the states where they were sent. Please provide a schedule showing the amount and
account numbers charged for all costs to produce, print, and distribute inserts.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 22,2011
REQUEST NO. 71: Please provide a biling summary showing monthly breakdown of
revenue by class for the years 2010 through 2011 to date for Idaho. Please include within your
response the amounts, KWhs, and number of customers biled.
REQUEST NO. 72: Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division and
company. Please include within your response the dollar level at which individual capital
expenditure projects require approval by the Board of Directors.
REQUEST NO. 73: Please provide a detailed listing of all entries to Account 456 -
Other Electric Revenues for the years 2010 and 2011 to date.
REQUEST NO. 74: Please provide copies of the narative monthly, quarerly and
anual comparison of operating and capital budgets to actual expenditures for the years 2010 and
2011 to date. Please include within your response any narrative explanations for budget
variations. This should include, but not be limited to, written operating and capital budget
variance reports and explanations used by Company officers and managers to monitor and
control budgets under their areas of responsibility.
REQUEST NO. 75: Please provide copies of the monthly, quaerly, and annual
presentations to the Company's Executive Board and Chief Executive and Operating Officers for
2010 and 2011 to date. Please include within your response a paper copy of any slides and notes
used in such presentations.
REQUEST NO. 76: Please provide the Company's monthly operating and financial
reports for each month from January 2010 to date. These should be in the most detailed format
possible and should include all attached supporting schedules and analysis received by
management.
REQUEST NO. 77: Please provide a copy of each adjusting journal entry proposed by
the Company's independent auditors in the two (2) most recent audits of the Company. Please
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 22, 2011
include within your response the documentation supporting these adjustments and documentation
supporting any items that were "passed upon" and not reflected in the Company's financial
records and/or financial statements.
REQUEST NO. 78: Please provide a narrative explaining how the Company accounts
for its relicensing costs. Please include within your response the accounts posted and ratemaking
implications, including how the revenue requirements for the state jurisdictions are impacted.
REQUEST NO. 79: Please provide a current organization chart showing names of
employees and their titles that includes all managers and executives. Please include within your
response how this organization char changed or is expected to change during 2010 and 201 1.
REQUEST NO. 80: For each offcer of the Company, please provide the following:
a.) Total dollar amount of remuneration for 2010 and the amounts separated by
salary, incentive pay, options, benefits and other.
b.) The percentages of his or her total remuneration that is allocated to other
subsidiaries along with the basis for that allocation.
c.) Please provide all officers' salaries for 2008 through 2010 for each officer by
month, and please itemize by base salary, bonuses, and benefits, along with the
amount included in test year and the amount paid for by shareholders.
REQUEST NO. 81: Please provide the total number of employees and employee
expenses by account and in total for the last two (2) years as well as the budgeted amounts for
2011.
REQUEST NO. 82: Please provide a copy of all agreements with union employees
effective during 2009, 2010 and 2011. Please include within your response a synopsis of the
major compensation changes in these agreements from year to year.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JULY 22, 2011
REQUEST NO. 83: Please provide both federal and state quarerly and annual payroll
tax reports for the year ending 2010.
REQUEST NO. 84: Please provide a description of all incentive!bonus plans in effect
during fiscal years 2009, 2010 and 201 1. Please include within your response the employees or
group of employees eligible under each of the plans and the costs attributable to each of these
plans. Indicate whether there are any changes and describe any changes to the incentive/bonus
plans that are anticipated or under consideration.
REQUEST NO. 85: Please provide the account numbers and amounts posted that the
Company used to book incentive payments for 2010.
REQUEST NO. 86: Please provide all documents supporting budgeted and actual wage
increases (if any) for non-union and exempt employees during 2009 through 201 1. Please
include within your response the number of employees (budgeted and actual) to which these
wage increases applied and their associated salaries pre and post wage increase.
REQUEST NO. 87: Please provide a written narrative that explains how the Company
sets employee salaries, incentive payments and other employee benefits. Please provide a copy
of the salary surveys or other documentation used to set employee salaries.
REQUEST NO. 88: Please provide all offcers' employee numbers, names, job titles,
detailed job descriptions, responsibilties, base salaries, and other compensation by year since
2008.
REQUEST NO. 89: Please explain the basis for all officers' salary increases from the
2010 level to the 2011 leveL. Also, please provide all documents that are relevant to this inquiry.
REQUEST NO. 90: Please provide screen prints of the links to the Company's policies
and other relevant materials provided as an "employee handbook" made available on the
Company's intranet (PacifiCorp Policies and Procedures and Human Resources Policies and
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JULY 22, 2011
Guidelines). This request is to obtain a listing of policies and, if considered necessary, individual
policies wil subsequently be requested.
REQUEST NO. 91: Please provide copies of the employee newsletters issued during
the period June 2010 to date.
REQUEST NO. 92: Please provide a listing of all penalties and fines included in the
test year, citing the account it is located in, the payee, and the amount.
REQUEST NO. 93: Please provide a listing of any costs included in the test year related
to sporting or entertainment events, including but not limited to season tickets or sky boxes.
Provide the accounts where booked and if above the line, please include any explanation as to
the business purose.
REQUEST NO. 94: Please provide a listing of all charitable contributions, including
names, amounts and account numbers included in the test year.
REQUEST NO. 95: Please provide a listing of licenses paid for by the Company, such
as PE, CPA, Legal, etc. included in the test year by FERC account and sub-account included in
the test year.
REQUEST NO. 96: Please provide the audit workpapers from the external auditors for
2010.
REQUEST NO. 97: Please provide the Board of Director minutes, including all
material distributed and/or discussed at the meetings, including but not limited to external
reports, committee reports, handouts, chars, etc. for the years 2010 and 2011 to date.
REQUEST NO. 98: Please provide an organizational chart for PacifiCorp and Rocky
Mountain Power that shows each of its subsidiaries, and the parent companies. In addition,
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 JULY 22,2011
please provide a description of each company location and the functions performed at each
location.
REQUEST NO. 99: Please provide a schedule showing 2010 through 2011 to date
monthly balances for the materials and supplies subaccounts. Please include within your
response the descriptions of the accounts, the amounts in each account and the turnover ratios for
each account.
REQUEST NO. 100: Please provide a list of all leased items in 2010 and to date in
2011. Please separately identify those leases historically accounted for as capital leases and
operating leases. Please include within your response the dates, terms, amounts and accounts
used for each lease.
REQUEST NO. 101: Please provide copies of the Company's most recent cost
allocation manuals.
REQUEST NO. 102: Please update Exhibit 2, page 8.6.2 (Major Plant Additions Detail)
to reflect actual and/or revised plant in-service dates and dollar amounts. If any plant in-service
dates extend beyond December 2011, please identify the revenue requirement in the original
associated with these projects specifically identifying the adjustments necessary to depreciation,
taxes, rate base and other expense items.
REQUEST NO. 103: Please provide the copies of the contracts associated with the
plant additions listed on Exhibit 2, page 8.6.2 (Major Plant Additions Detail).
REQUEST NO. 104: For each of the plant additions listed on Exhibit 2, page 8.6.2
(Major Plant Additions Detail), please provide the following information separately for each
project: invoice number, description of payment, vendor name, date posted and amount, for
inception of project to date.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 JULY 22, 2011
REQUEST NO. 105: Please describe the derivation of any surcharge booked to capital
projects including all factors included in the surcharge. Please include within your response the
frequency with which the surcharge is updated.
REQUEST NO. 106: Please identify the costs included within the filing that are
associated with any projects that have been abandoned. Please include within your response the
amount and accounts posted along with the applicable allocation factors.
REQUEST NO. 107: Please provide a list showing a summar of all consultants and
attorneys (internal and external) who performed services for PacifiCorp or who were paid by
PacifiCorp for 2010 that are included in the test year. For all attorneys, show services
performed, amounts paid, and accounts charged. If services were performed in support of a
docketed federal/state court or regulatory agency action, please identify the case name, case
number and jurisdiction. If studies were the result of any of these payments, please provide a
copy of those studies.
REQUEST NO. 108: Please update the Exhibit 2, page 8.6.2 (Major Plant Additions)
fied in Case No. PAC-E-I0-07 to reflect actual plant in-service dates and actual dollars
expended for each project listed.
REQUEST NO. 109: For each of the plant additions listed on Exhibit 2, page 8.6.2
(Major Plant Additions Detail) fied in Case No. PAC-E-I0-07, pléase provide the following
information separately for each project: invoice number, description of payment, vendor name,
date posted and amount, for inception of project to date.
REQUEST NO. 110: Please explain how each of the allowed National and Regional
Trade Memberships benefit Idaho Customers. If the benefit is from seminars or training held by
the organization, please identify how many attendees attended from PacifiCorp and provide the
meeting agendas.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 JULY 22, 2011
REQUEST NO. 111: Please give the dollar amounts incured for each event used in the
calculation for page 4.1 1.4 "Anual Losses Above Deductable".
REQUEST NO. 112: For the following FERC accounts, please provide at least the
following information for 2009,2010 and 2011 to date: invoice number, description of payment,
vendor name, date posted and dollar amount. Please also provide the allocation factor and
amount allocated to the Idaho jurisdiction.
a.) 902
1. Only those items that have the factor of ID Situs or CN
b.) 923
c.) 935
REQUEST NO. 113: Please provide the supporting documentation for page 9.1 item 2,
Pro Forma Wage Increases.
DATED at Boise, Idaho, this ?~ay of July 2011.
¡J~~
Neil Price
Deputy Attorney General
Technical Staff: Matt Elam51-53
Patricia Hars/54-1 09
Joe Terry/11O-113
i:umisc:prodreqlpacel 1.2npme prod req3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 11 JULY 22, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF JULY 2011,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER,
IN CASE NO. PAC-E-11-12, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MGR
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 8411 1
E-MAIL: ted.westoncmpacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 841 1 1
E-MAIL: daniel.solandercmpacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datarequestcmpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbcmracinelaw.net
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: bcollns(fconsultbai.com
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithcmmonsanto.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elocmracinelaw.net
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tonycmyanel.net
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdycmhotmail.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID83702
E-MAIL: bottocmidahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: roncmwiliamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dwscmr-c-s-inc.com
CERTIFICATE OF SERVICE
E-MAIL: ONLY
TIM BULLER
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INC/NU- WEST INDUSTRIES
E-MAIL: tbullercmagrium.com
!~V2SECRETARY~
CERTIFICATE OF SERVICE