20110725PIIC 50-62 to PAC.pdf

WILLIAMS. BRADBURY
ATTORNEYS AT LAW R ri
2011 JUL 25 PM 3: 0
July 22,2011
Ms. Jean Jewell
Commission Secretar
Idaho Public Utilties Commission
472 W. Washington
Boise,ID 83702
Re: PAC-E-II-12
Dear Ms. Jewell:
Please find enclosed an original and three copies of the Fourh Set of Data Requests to
Rocky Mountain Power of the PacifCorp Idaho Industrial Customers for filing in the above
referenced case.
Than you for your assistace in ths matter. Please feel free to give me a call should
you have any questions.
Sincerely,
RLW/jr
Enclosures
1015 W. Hays Street - Boise, ID 83702
Phone: [phone] - Fax: [phone] - ww.wiamsbradbur.com
Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
[phone]
[phone] (Fax)
roncÐwillamsbradbur.com
RECEI D
231 i JUL 25 Pri 3= 0'
Attorney for PacifiCorp Idaho Industral Customers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL )
OF CHANGES TO ITS ELECTRIC SERVICE )
SCHEDULES AND A PRICE INCREASE OF )
$32.7 MILLION, OR APPROXIMATELY 15.0 )PERCENT )
)
)
)
CASE NO. PAC-E-II-12
FOURTH SET OF DATA
REQUESTS TO ROCKY
MOUNTAIN POWER OF THE
PACIFICORP IDAHO
INDUSTRIAL CUSTOMERS
PacifiCorp Idaho Industrial Customers ("PUC"), by and through its attorney of record,
Ronald L. Willams, requests that PacifiCorp, d//a Rocky Mountain Power (the "Company"),
provide the following documents and information on or before Friday, August 19,2011.
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 obtan 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 preparng the document, and the name, location and phone number of the record holder
PAGE 1 - PIIC'S FOURTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
and, if different, the witness who can sponsor the answer at hearng if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic fied on CD with formulas activated.
DATA REQUESTS:
50. Please provide the Idaho-jursdictional amount of additions and retirements
booked to plant in service and to the accumulated depreciation for each of the
years 2004 through 2011.
51. Referencing the 2010 Idaho supplement to the FERC Form 1, submitted to the
Idaho Public Utilities Commission on June 1, 2011, please explain the
$274.5 millon growth in Plant in Service and the $69.2 milion growth in
Accumulated Depreciation & Amortization.
52. Please provide an explanation for the drop in the Accumulated Depreciation &
Amortization from $437.2 milion in 2010, to the proposed level of $432.3
milion.
53. For each of the years 2001 though 2010, please provide the Idaho-situs general
business revenues, actual write-offs net of recoveries, and any reserve balances.
54. For both 2009 and 2010, please indicate for both allocated and situs operations the
percentage salar increases that were granted to management employees and to
bargaining unt employees.
55. Please provide all justification for the level of salar increases requested in the
curent rate case.
56. Has Rocky Mountain Power calculated the actual dollar value of savings achieved
though the use of incentive compensation? If the answer is yes, please provide
that calculation for all years for which the calculation was made.
57. Please provide all supporting documentation related to the self-insurance expense
booked to Account 924 for the time period of Januar 1 through March 21,2011,
in the amount of$I,894,701 as shown on Mr. McDougal's Workpaper 4.11.3.
58. Please confirm the following accurately reflect the Company's filing:
a. Test Year Insurance Booked to Account 924 was $14,205,067 (Total
Company) and $500,888 (Idaho-situs).
b. Test Year Insurance Booked to Account 925 was $1,584,944 (Total
Company) and $91,836 (Idaho-situs).
PAGE 2 - PIIC'S FOURTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
c. The anualized level of property insurance for which Rocky Mountain
Power wil self-insure after March 21, 2011, is $1,876,063
(97,755+ 1,778,308).
d. The anualized level of property losses that will now be under Rocky
Mountain Power's deductible after March 21,2011, is $2,768,137
(810,421 +587,868+ 1,369,848).
59. Please provide the capital additions not associated with "major" plant additions
since the end of 2010. Please provide the anual level of "non-major" capital
additions for each of the years 2001-2010.
60. In reference to page 4.13.1, please provide the actual dollars charged to operations
and maintenance expense for each project separately on a monthy basis through
the most recent month available. Please provide the above figues broken out
between labor and non-labor.
61. In reference to page 4.13.1, please describe the nature of the increased expenses
associated with Cholla 4 Scrubber. Please explain why these costs are not subject
to capitalization.
62. By generation facilty, please identify the dates of the scheduled maintenance
outages (including the length of outages in days) from 2001 to present.
DATED: This 22nd day of July, 2011
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PAGE 3 - PIIC'S FOURTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of July, 2011, I caused to be served a true and
correct copy of the foregoing document upon the following individuals in the manner indicated
below:
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: ted.westoncÐpacificorp.com
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: danie1.solandercÐpacificorp.com
Data Request Response Center
PacifiCorp
825 NE Multonomah St., Suite 2000
Portland, OR 97232
E-Mail: datarequestcÐpacificorp.com
Randall C. Budge
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello,ID 83204-1391
E-Mail: rcb~racinelaw.net
Attorney for Monsanto Company
Brubaker & Associates
16690 Swingley Ridge Road, # 140
Chesterfeld, MO 63017
E-Mail: bcollns~consultbai.com
Monsanto Company
James R. Smith
Monsanto Company
PO Box 816
Soda Springs, ID 83276
E-mail: jim.r.smith~monsanto.com
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PAGE 4 - PIIC'S FOURTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
Eric L. Olsen
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello,ID 83204-1391
E-Mail: elo~racinelaw.net
Attorney for Idaho Irrigation Pumpers
Association
Anthony Yankel
29814 Lake Road
Bay Vilage, OH 44140
E-Mail: tony~yanke1.net
Idaho Irrigation Pumpers Association
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83702
E-mail: bmpurdy~hotmai1.com
Attorney for CAP AI
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,ID 83702
E-mail: botto~idahoconservation.org
Neil D. Price
Idaho Public Utilties Commission
472 W. Washington Street
Boise,ID 83720-0074
E-mail: nei1.price~puc.idaho.gov
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PAGE 5 - PIIC'S FOURTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER