20150319Staff 30-35 to PAC .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
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL )
OF THE TRANSACTION TO CLOSE THE DEER )
CREEK MINE AND FOR A DEFERRED )
ACCOUNTTNG ORDER. )
_)
'-' :: a" .'.
:"---! -i
itlt tt[R I I Pi{ 3: 0l
,;) ,, i
i1 lifl-i!'-:l)
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-8.14.I0
FIFTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than THURSDAY, APRIL 9,2015.
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 and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.0I.01.228.
This Production Request is to be considered as continuing, and Rocky Mountain 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.
FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP MARCH I9,2OI5
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.30: Please provide details and copies of the October 3l,20l4labor
settlement agreement, all Memoranda of Understanding, wage agreements, and any other settled
disputes between Deer Creek Mine, Energy West and UMWA.
REQUEST NO. 31: Please provide the number of active employers contributing to the
1974 Pension Trust for each year 2005-2014.
REQUEST NO.32: Please provide copies of the three most recent completed Forms
5500, including all attachments and schedules, for the 1974 Pension Trust.
REQUEST NO.33: Please provide the withdrawal liability amounts for Energy West
for the 1974 Pension Trust for each year beginning with 2010.
REQUEST NO.34: Please provide the value of the unfunded vested benefits as of June
30,2014.
REQUEST NO.35: Please provide a schedule showing all rate base items relating to
the transaction, (both items being transferred and items remaining with the company) including
plant amounts, documented depreciation, net book values, and depreciations rates. This may
include mines, equipment, warehouse facilities, inventory, etc.
FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP MARCH I9,2OI5
DATED at Boise, Idaho, thi, ) ft)huy of March 2015.
Deputy Attorney General
Technical Staff: Donn English (30-34)
Joe Terry (35)
i:umisc:prodreq/pace 14. I 0npmlphjtde prod reqS
FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 3 MARCH 19,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF MARCH 2015,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
CoMMISSION STAFF, IN CASE NO. PAC-E-14-10, BY E-MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
TED WESTON DANIEL E SOLANDER
ID REGULATORY AFFAIRS MANAGER SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I I I
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp. com
ROCKY MOI-INTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 8411I
E-MAIL : daniel. [e-mail]
zuCHARD R HALL
STOEL RIVES LLP
SUITE 19OO
IOI S CAPITOL BLVD.
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE