20150422OR UM-1712 ICNU Set 7 (95-99) 4-8-15.pdf

UM-1712/PacifiCorp
April 8, 2015
ICNU Data Request 7.95
ICNU Data Request 7.95
Does the Company agree that the $86 million of unrecovered investment, for which the
Settling Parties propose rate treatment in Paragraph 12(a) of the Stipulation, includes
approximately $5 million of construction work in progress (“CWIP”), as was
demonstrated on Attachment B, Page 2 to the initial Application? If no, please state the amount of CWIP included in the $86 million of unrecovered investment.

Response to ICNU Data Request 7.95

The Company objects to this request as not reasonably calculated to lead to the discovery of admissible evidence. Without waiving this objection, the Company responds as
follows:

Yes.
UM-1712/PacifiCorp
April 8, 2015
ICNU Data Request 7.96
ICNU Data Request 7.96
Please provide accounting detail, at the most granular level available, of the total amount
of CWIP that was included in the $86 million of unrecovered investment, for which the
Company seeks rate treatment in Paragraph 12(a) of the Stipulation.
Response to ICNU Data Request 7.96 The Company objects to this request as not reasonably calculated to lead to the discovery
of admissible evidence. Without waiving this objection, the Company responds as
follows:
Please see Attachment ICNU 7.96.
UM-1712/PacifiCorp
April 8, 2015
ICNU Data Request 7.97
ICNU Data Request 7.97
Please provide accounting detail, at the most granular level available, of the total amount
of Preliminary Survey/Investigation amounts that are included in the $86 million of
unrecovered investment, for which the Company seeks rate treatment in Paragraph 12(a)
of the Stipulation.
Response to ICNU Data Request 7.97
The Company objects to this request as not reasonably calculated to lead to the discovery
of admissible evidence. Without waiving this objection, the Company responds as
follows:
Please see Attachment ICNU 7.97.
UM-1712/PacifiCorp
April 8, 2015
ICNU Data Request 7.98
ICNU Data Request 7.98
Please describe how CWIP is traditionally accounted for in general rate proceedings in
Oregon.

Response to ICNU Data Request 7.98 The Company objects to this request as not reasonably calculated to lead to the discovery
of admissible evidence and as requiring a legal opinion, legal research, or legal analysis
that is protected from disclosure by the attorney-client privilege or attorney work product
doctrine.

UM-1712/PacifiCorp
April 8, 2015
ICNU Data Request 7.99
ICNU Data Request 7.99
Has the Company ever been allowed to recover a return on or return of an amount
designated as CWIP in Oregon? If yes, please list all such instances.

Response to ICNU Data Request 7.99
The Company objects to this request as overly broad, unduly burdensome, vague,
ambiguous, and as requiring information not maintained in the ordinary course of
business. Without waiving these objections, the Company responds as follows:
The Company did not perform a comprehensive review of all cases in the Company’s
lengthy history in order to respond to this data request. In recent Company history, it is unusual for the Company to close a plant under a schedule that precludes completion of
ongoing construction projects and a transfer of these costs to plant in service in the
normal course. For this reason, the Company is unaware of recent cases similar to this
one where CWIP was recovered as a part of the Company’s unamortized investment
under ORS 757.140.