20110805Staff 136-180 to PacifiCorp.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
oi:. C,i:1 nl" '- 1-. ¡'j
ZOIl ~,UG -5 PM I: 29
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-11-12
FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilties 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 26, 2011. For Question Nos. 157-180, please also make the information
available and provide the responses during the on-site audit in Salt Lake City, Utah on or before
August 17, 2011 or in Portland, Oregon.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementay 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
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 5, 2011
person preparing the document, and the name, location and phone number of the record holder
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 fies on CD with formulas activated.
REQUEST NO. 136: Please identify all Supplemental Executive Retirement Plan
(SERP) costs associated with Company employees included in the filing. If none, please identify
how they have been removed or are otherwse excluded.
REQUEST NO. 137: For Bridger Coal Company (BCC), 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 turover ratios for each account. Please include within your response how these
amounts are included within the Company's filing.
REQUEST NO. 138: For BCC, 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 chart changed or is expected to change during 2010
and 201 1.
REQUEST NO. 139: For BCC, please provide the total number of employees and
employee expenses by month by account and in total for 2010 through 2011 to date. In addition,
please provide the budgeted amounts for 2011. Please include within your response how these
amounts are included within the Company's fiing.
REQUEST NO. 140: For BCC, please provide a copy of the most recent employee
handbook.
REQUEST NO. 141: For BCC, please provide a copy of all agreements with union
employees effective during 2010 and 2011. Please include within your response a synopsis of
the major compensation changes in these agreements from year to year.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 5, 2011
REQUEST NO. 142: For BCC, please provide a description of all incentive!bonus plans
in effect during fiscal years 2010 and 2011. 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 and describe any changes to the incentive!bonus plans that are
anticipated or under consideration.
REQUEST NO. 143: For BCC, please provide the account numbers and amounts
posted that the Company used to book incentive payments for 2010.
REQUEST NO. 144: For BCC, please provide all documents supporting budgeted and
actual wage increases (if any) for non-union and exempt employees during 2010 through 2011.
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. 145: For BCC, 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 salar sureys or other documentation used to set employee salaries.
REQUEST NO. 146: For BCC, please provide details of all bonus plans included in the
test period and the criteria and goals used to grant employees bonuses.
REQUEST NO. 147: Please describe in detail any hiring constraints affecting the abilty
of BCC to attract qualified employees. If these constraints are material to mine operation, what
is the estimated financial impact of these constraints? Please include any spreadsheets or other
workpapers used in the analysis of financial impact due to hiring constraints at BCC. What steps
has BCC taken to address this issue?
REQUEST NO. 148: Please provide a list of all Berkshire Hathaway affiiate
companies.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 5, 2011
REQUEST NO. 149: Has there been any buyback of unused personal time from senior
management included in the test year? If so, please identify the amount, accounts posted and
Idaho jursdictional allocation.
REQUEST NO. 150: Please provide copies of the Actuarial Reports for the Company's
pension plans for 2010.
REQUEST NO. 151: Please provide copies of any correspondence between the
Company and its actuaries, specifically any correspondence regarding futue funding levels or
changes in assumptions for 2010 and 2011.
REQUEST NO. 152: Please provide a table comparing the annual target incentive
amounts to the amounts actually paid for the years 2009-2010.
REQUEST NO. 153: Please describe in detail the nature of all affliate relationships
between PacifiCorp or its parent companies and any company under contract to transport coal to
any of the PacifiCorp coal-fired plants.
REQUEST NO. 154: Please provide a listing of all SEC comment letters received by or
being responded to during 2010 to date. Please include in the listing a detailed description of the
issue and curent status.
REQUEST NO. 155: The Company hired Cadmus Group to complete a study
measurng the impact of Rocky Mountain Power's Idaho Irrigation Load Control Program. On
page 7 of the study, Cadmus Group weather normalizes load data using the "daily
evapotranspiration rate, temperature (hourly), and rainfall (hourly)." Please explain why the
Cadmus Group would weather normalize the irrigator load data for purposes of the impact study,
but the Company would not for rate case purposes.
REQUEST NO. 156: In the Cadmus Group study referenced above, the estimated load
reduction for July 16,2010 is 130.5 MW (Page 13, Table No.8). Why is this different from
FIFTH PRODUCTION REQUESTTO ROCKY MOUNTAIN POWER 4 AUGUST 5, 2011
McDougal's Exhibit No.2, page 10.13, where the program's load impact for the same day is 144
MW? As par of the response, please provide the supporting workpapers and load data used to
estimate the impact.
For the next series of questions (Nos. 157-177), please also make this information available
during the on-site audit in Salt Lake City:
REQUEST NO. 157: Company workpaper page 4.1.1 indicates the amounts of
Miscellaneous General Expense removed from the 2010 Results of Operations. Please provide
an itemized schedule of each expense that was removed that reconciles with page 4.1.1. Please
include within your response the invoice number, description of payment, vendor name, date
posted, FERC account posted and dollar amount.
REQUEST NO. 158: Please provide a complete itemized listing of "Settlement Fees"
that were removed from the 2010 Results of Operations (see workpaper page 4.5.1, line 3).
Please include within your response the invoice number, description of payment, vendor name,
date posted, FERC account posted and dollar amount.
REQUEST NO. 159: Please provide the supporting detail of the Mid-American Energy
Holdings Company (MEHC) management fees biled to PacifiCorp and the amounts included
within the Company's filing. Please include within your response the amount biled for
legislative costs, SERP and bonuses to employees of MEHC and how they have been excluded
from the Company's filing in response to Commission Order No. 32196. Staffhas identified that
in accordance with Commission Order, Adj. 4.10 removes the SERP portion of the MEHC cross
charge booked above the line.
REQUEST NO. 160: Please provide the average cost and tonnage of coal delivered
from BCC and Black Butte for each year 2008 to date.
REQUEST NO. 161: For the years 2008 through 2011 to date, please provide costs and
tons delivered per month per year from both BCC and Black Butte.
FIFTH PRODUCTION REQUESTTO ROCKY MOUNTAIN POWER 5 AUGUST 5, 2011
REQUEST NO. 162: Please identify whether coal costs from BCC and Black Butte are
expected to increase during the remainder of2011 and during 2012. If these costs are expected
to increase, please provide supporting data to support those increases.
REQUEST NO. 163: Please describe the method of determining cost of coal for the
BCC and how it is incorporated into the general rate case.
REQUEST NO. 164: Please provide the coal inventory by location and by month for
the period 2008 to date. Please provide both tonnage and cost for each data point. Please
provide this data in excel format.
REQUEST NO. 165: For the information provided in the above question, please explain
any significant change in either volume (tonnage) or cost for each coal pile during this period.
REQUEST NO. 166: Please provide a copy of the new coal contracts entered into
durng 2010 to date, any coal contracts renegotiated during the same timeframe and any existing
contracts having any price change adjustments/escalators that occurred during the same
timeframe.
REQUEST NO. 167: Please provide the underlying documentation associated with the
incremental operation and maintenance expense adjustment 4.13. Please include within your
response any contracts and other documentation supporting the 2011 forecast.
REQUEST NO. 168: For major plant addition project, CMIN201OCOOl, DEER
CREEK-RECONSTRUCT LONGWALL SYSTEM, the total costs by vendor do not match the
amount by month per Confidential Attachment IPUC 2d. Please explain and provide a summary
schedule showing other charges by fuction.
REQUEST NO. 169: For major plant addition project, SHA Y/2005/C/009, Hayden UO
Coal Unloading Facilty, the total costs by vendor when multiplied by the PacifiCorp share do
FIFTH PRODUCTION REQUESTTO ROCKY MOUNTAIN POWER 6 AUGUST 5, 2011
not match the amount by month per Confidential Attachment IPUC 2d. Please explain and
provide a summary schedule showing other charges by fuction.
REQUEST NO. 170: 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) 909
b) 930
c) 9280000
1. Only include items with allocation factor ID Situs and SO
d) 9282000
1. Only include items with allocation factor ID Situs
e) 5490000
t) 5660000
g) 5570000
REQUEST NO. 171: Account 5660000, Misc Trans Expense, has increased from a
($1,087,479) in 2006 to $4,257,862 in 2010. Please explain the increase and provide a summary
schedule showing major components.
REQUEST NO. 172: Account 5540000, MNT MSC OTH PWR GN, has increased
from a $329,679 in 2006 to $2,195,997 in 2010. Please explain the increase and provide a
summar schedule showing major components.
REQUEST NO. 173: Account 5490000, MIS OTH PWR GEN EX, has increased from
a $2,369,726 in 2006 to $18,701,555 in 2010. Please explain the increase and provide a
summary schedule showing major components.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 5, 2011
REQUEST NO. 174: Account 5570000, Other Expenses, has increased from a
$38,468,459 in 2006 to $62,931,863 in 2010. Please explain the increase and provide a sumary
schedule showing major components.
REQUEST NO. 175: Account 5654600, Post-MRG Wheel Exp, has increased from a
$26,285,138 in 2006 to $70,767,335 in 2009 to $125,193,289 in 2010. Please explain the
increase and provide a summar schedule showing major components.
REQUEST NO. 176: Please refer to McDougal Exhibit No.2, Tab 9. Please provide
supporting documentation and electronic workpaper for page 9.1, item 4, Fuel Stock.
REQUEST NO. 177: Please explain and provide documentation to support why one line
for Account 9280000, Regulatory Comm Exp uses a SO allocation factor.
For the next three questions (Nos. 178-180), please also make this information available
during the on-site audit in Portland:
REQUEST NO. 178: Please provide all information supporting the December 2011
projected amounts listed in Column D of work paper 4.3.9, Wage and Employee Benefit
Adjustment.
REQUEST NO. 179: Please reference PacifiCorp Environmental Remediation
Company (PERCO) Spending by Environmental Project Page 8.4.1. Please update this
workpaper to provide the current status of proforma spending by site in calendar year 20 1 1.
Please include within your response the actual spending to date for calendar year 2011 by site
and the basis for any amounts not yet spent but proformed for calendar year 2011.
REQUEST NO. 180: Please identify the status of any tax audits underway or concluded
in 2010 to date. Please include within your response the results of the audits and how they are
incorporated into the Company's fiing.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 AUGUST 5, 2011
DATED at Boise, Idaho, thi§~ay of August 2011.
¿l-
Neil Price
Deputy Attorney General
Technical Staff: Patricia Hars/136-154/157 -167/178-180
Matt Elam155-156
Joe Terr/168-177
i:umisc:prodreqlpaceI1.2np prod req5
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 AUGUST 5, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF AUGUST 2011,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER,
IN CASE NO. PAC-E-II-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 84111
E-MAIL: ted.westonCÐpacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solanderCÐpacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datareguestCÐpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbCÐracinelaw.net
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: bcollnsCÐconsultbai.com
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithCÐmonsanto.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloCÐracinelaw.net
ANTHONY Y ANKEL
29814 LAK ROAD
BAYVILLAGEOH 44140
E-MAIL: tonYCÐyanel.net
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdYCÐhotmail.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: bottoCÐidahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: ronCÐwillamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dwsCÐr-c-s-inc.com
CERTIFICATE OF SERVICE
E-MAIL: ONLY
TIM BULLER
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INCINU- WEST INDUSTRIES
E-MAIL: tbullerCÐagrium.com
--1&SECRETARY
CERTIFICATE OF SERVICE