20110825PIIC to PAC 76-84.pdf

WILLIAMS. BRADBURY
ATTORNEYS A T LAW.. . J
RECE\\
tn\ \ ~UG 25 PM 3: 56August 25,2011
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
472 W. Washington
Boise,ID 83702
Re: PAC-E-11-12
Dear Ms. Jewell:
Please find enclosed an original and three copies of the Sixth 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 assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,fl~0~
Ronald 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)
ron~wiliamsbradbur .com
RECEIVED
Lni \ AUG 25 PM 3: 56
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-11-12
SIXTH SET OF DATA REQUESTS
TO ROCKY MOUNTAIN POWER
OF THE PACIFICORP IDAHO
INDUSTRIAL CUSTOMERS
f
PacifiCorp Idaho Industrial Customers ("PUC"), by and though its attorney of record,
Ronald L. Wiliams, requests that PacifiCorp, d//a Rocky Mountain Power (the "Company"),
provide the following documents and information on or before Thursday, September 8, 2011.
This Production Request is to be considered as continuing, and Rocky Mountan 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 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 preparing the document, and the name, location and phone number of the record holder
PAGE 1 - PIIC'S SIXTH 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 filed on CD with formulas activated.
DATA REQUESTS:
76. Please provide a calculation of total company rate base and Idaho-situs rate base-similar
to the presentation of rate base on Exhibit No.1, Page 2 of3 attched to the direct
testimony of Steven R. McDougal-updated for each month staring with June of 20 11.
77. Please provide the average tenure for RMP's Idaho-based employees with a breakdown
between Union and Non-Union.
78. Please provide the average tenure for MEHC employees with a breakdown between
Union and Non-Union.
79. Please provide a detailed description of how the company captued the increase in energy
sales related to customer growth. In the description, please include a discussion of the
time periods examined in the growt calculation, including the end point used. Please
cite all workpapers.
80. Other than the 2011 wage increases, major capita additions and expenses associated with
major capital additions, what specific aspects of the company's case are calculated
through December 31, 2011 ?
81. Please provide copies of each incentive plan used in 2010 and 2011. For each plan please
indicate the total cash payments made, amount capitalized and amount charged to
expense. Please indicate both the total company levels and the RMP-Idaho levels of each
of these items.
82. Please provide all score cards used in the calculation of incentive compensation and
indicate the level of performance achieved, and to which plan each score card relates. If
this results in a voluminous response, please make available for review.
83. Please provide the rationale for RMP's proposal to include 2 methods and sums of
working capita in its rate base.
84. Please identify the name of the "large industrial customer with plans to locate in Idaho
that will add 40 MW of additional load" as referenced in Mr. Walje's direct testimony,
page 4. Please also identify the name of the individual(s) that have acted as
representatives of ths "large industrial customer" and such person's contact information.
Please provide a brief narative description of the natue and location of this potential
industral load and a description of the status of this potential customer locating its
industral facilty or process within the Company's service territory in Idaho. Please
provide copies of all communications the Company has sent to or received from this
PAGE 2 - PIIC'S SIXTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
potential industrial customer with respect to the electric service rates and/or schedules by
which the Company would or might be able to provide electric service thereto, and/or
contract terms and conditions the Company has proposed or discussed regarding electrc
service to such customer, both curently and forecasted for the futue.
1 ~'"DATED: This £ day of August, 2011.
¡¿JIV~
R~d L. Wiliams
PAGE 3 - PIIC'S SIXTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
4'
I HEREBY CERTIFY that on this 2 r day of August, 2011, I caused to be served a tre
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~pacificorp.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
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 - PIle's SIXTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
Eric L. Olsen
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
POBox 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 Utilties Commission
472 W. Washington Street
Boise,ID 83720-0074
E-mail: neii.price~puc.idaho.gov
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J
)?o.¿U~
Ronald L. Wiliams
PAGE 5 - PIIC'S SIXTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER