20110809PIIC 50-75 to PAC.pdf

WILLIAMS. BRADBURY
ATTORNEYS AT LAW RECEIVED
lO' j AUG -9 PM 3: 36
August 9,2011
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilities Commission
472 W. Washington
Boise,ID 83702
Re: PAC-E-ll-12
Dear Ms. Jewell:
Please find enclosed an original and three copies of the Fifth Set of Data Requests to
Rocky Mountain Power of the PacifiCorp Idaho Industrial Customers for filing in the above
referenced case.
Than you for your assistace in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,r¡~~& Vionald L. Wiliams
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)
ronCfwiliamsbradbury.com
Ri:Cr: IV:: f);.i- b_ "e-LJ
2011 AUG -9 PH 3: 36
Attorney for PacifiCorp Idaho Industrial 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
FIFTH 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. Wiliams, requests that PacifiCorp, d//a Rocky Mountan Power (the "Company"),
provide the following documents and information on or before Tuesday, September 6, 2011.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementa responses, additional documents that it or any
person acting on its behalf may later obtain 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 FIFTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
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 filed on CD with formulas activated.
DATA REQUESTS:
50. Please provide the Idaho-jurisdictional 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 Utilties Commission on June 1, 2011, please explain the
$274.5 milion 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 $432.3
milion.
53. For each of the years 2001 through 2010, please provide the Idaho-situs general
business revenues, actual wrte-offs net of recoveries, and any reserve balances.
54. For both 2009 and 2010, please indicate for both allocated and situs operations the
percentage salary increases that were granted to management employees and to
bargaining unit employees.
55. Please provide all justification for the level of salar increases requested in the
curent rate case.
56. Has Rocky Mountain Power calculated the actual dollar value of savings achieved
through the use of incentive compensation? If the answer is yes, please provide
that calculation for all years for which the calculation was made.
57. Please provide all supporting documentation related to the self-insurance expense
booked to Account 924 for the time period of Janua 1 through March 21,2011,
in the amount of$I,894,701 as shown on Mr. McDougal's Workpaper 4.1 1.3.
58. Please confirm the following accurately reflect the Company's filing:
a. Test Year Insurance Booked to Account 924 was $14,205,067 (Tota
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 FIFTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
c. The anualized level of propert insurance for which Rocky Mountain
Power will 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 annual level of "non-major" capita
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 monthly 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 facility, please identify the dates of the scheduled maintenance
outages (including the length of outages in days) from 2001 to present.
63. Please provide an electronic copy of the workpapers supporting the REC revenue
amount in curent rates as a result of case number P AC- E-l 0-07.
64. Please provide an electronic EXCEL file showing the actual RECs generated from
all sources, the specific sale of RECs by source (include the entity to whom the
RECs were sold and the associated price), and the specific RECs retained by
source for 2010.
65. Please provide an electronic EXCEL file showing the projected RECs from all
sources, the specific sale of RECs made to date by source (include the entity to
whom the RECs were sold, the execution date and the associated price), the
remaining projected RECs available for sale and the specific RECs the Company
is planng on retaining by source for 2011.
66. With regard to the EXCEL workbook fie provide by the Company in response to
PUC request 3, the worksheet entitled 3.5.2, please provide the support for the
Company's assumed percent sold value of 75%.
67. With regard to the EXCEL workbook file provide by the Company in response to
PUC request 3, the worksheet entitled 3.5.2, please provide the specific resources
generating the REC amounts shown in EXCEL colum E, rows 7, 9 and 11 of this
worksheet.
PAGE 3 - PIIC'S FIFTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
68. With regard to the EXCEL workbook fie provide by the Company in response to
PIIC request 3, the worksheet entitled 3.5.2, please provide the specific resources
generating the REC amounts shown in EXCEL colum E, rows 46 and 67 of this
worksheet.
69. With regard to the EXCEL workbook file provide by the Company in response to
PIIC request 3, the worksheet entitled 3.5.2, please provide the specific resources
and year generating the REC amounts shown in EXCEL column E, rows 48 of
this worksheet.
70. With regard to the EXCEL workbook file provide by the Company in response to
PIIC request 3, the worksheet entitled 3.5.2, the REC amounts shown in EXCEL
colum E, rows 46 and 67 of this worksheet, please provide the remaining amount
of non-wind RECs that are projected to be available for sale in 2011 by resource.
71. With regard to the Rebuttal Testimony of Stefan A. Bird filed in the Uta docket
number 10-035-124, please provide a non-redacted copy of this testimony.
72. With regard to the Rebuttal Testimony of Stefan A. Bird filed in the Uta docket
number 10-035-124, please provide the details regarding the NV Energy
transaction executed on Februar 9, 2011, including the expected deliveries of
RECs under the agreement by month.
73. With regard to the EXCEL workbook fie provide by the Company in response to
PIIC request 3, has the Company executed additional REC sales beyond those
reflected in this spreadsheet? If so, please provide all the details for each of these
additional transactions and an updated EXCEL fie (comparable to PIIC 3)
containing the additional known transactions.
74. With regard to Schedule 6, please provide individual monthly biling data for any
customer served under this rate schedule with a single biling demand in excess of
1,000 kW in 2010. Please designate if the customer is served at the primar or
secondar voltage leveL.
75. With regard to the EXCEL workbook file the Company provided in response to
lIP A data request 2d, please provide the hourly demands for each Schedule 6
customer the Company has used in its load research program for the test period.
Please identify if the customer receives service at the secondar or primar
voltage leveL.
+\-
DATED: This ~ day of August, 2011
..
X,J L (J~
Ronald L. Wiliams
PAGE 4 - PIIC'S FIFTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
n. "'''i HEREBY CERTIFY that on this ~ day of August, 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.weston(fpacificorp.com
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: daniei.solander~pacificorp.com
Data Request Response Center
PacifiCorp
825 NE Multonomah St., Suite 2000
Portland, OR 97232
E-Mail: datarequest~pacificorp.com
Randall C. Budge
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
POBox 1391
Pocatello,ID 83204-1391
E-Mail: rcb~racinelaw.net
Attorney for Monsanto Company
Brubaker & Associates
16690 Swingley Ridge Road, # 140
Chesterfield, 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~onsanto.com
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PAGE 5 - PIIC'S FIFTH 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 Yanke i
29814 Lake Road
Bay Vilage, OH 44140
E-Mail: tony~yankei.net
Idaho Irrigation Pumpers Association
Brad M. Purdy
2019 N. 17th Street
Boise,ID 83702
E-mail: bmpurdy~hotmaii.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 Utilities Commission
472 W. Washington Street
Boise,ID 83720-0074
E-mail: neii.price~puc.idaho.gov
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?~Ll)~
Ronald L. Wiliams
PAGE 6 - PIIC'S FIFTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER