20210602Staff 1-34 to PAC.pdf

DAYN HARDIE (ISB No. 99t7)
MATT HUNTER (tSB No. 10665)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC.E.-2I-07
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and Matt Hunter, Deputy Attomeys General, request that Rocky Mountain
Power ("Company") provide the following documents and information as soon as possible, but
no later than WEDNESDAY, JUNE 23,2021.
This Production Request is to be considered as continuing, and the Company 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 or information produced.
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 also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
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JUNE 2,2021
In addition to the written copies provided as response to the requests, please provide all
EXCEL spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide copies of the monthly trial balances from January
2018 through the most current month available. Please supplement your response when
additional months become available throughout 2021.
REQUEST NO.2: Please provide a copy of the Company Chart of Accounts
REQUEST NO.3: Please provide a list of all extemal attorneys who performed services
for the Company or who were paid by the Company for services during 2019 through2}2l to date.
Please list the amounts paid, accounts charged, and date of payment. Please also provide a brief
summary of the services performed. If services were performed in support of a docketed
federal/state court or regulatory action, please identifu the case name, case number, and jurisdiction.
For each expense, please illustrate how the charge was allocated to the Company's jurisdictions.
REQUEST NO. 4: Please provide the total amount that the Company spent on the
following activities for 2019 and2020, and show how the Company allocated the amounts
between the PacifiCorp operating division and the rest of the Company and its subsidiaries:
a. Intemal auditing expenses;
b. The Company's annual report;
c. Deloitte & Touche and Deloitte Consulting;
d. Rating agencies;
e. All software or information system-related issues;
f. Board of Directors compensation, travel expenses, and meeting expenses;
g. Corporate or chartered aircraft;
h. Travel and training for all shared executives of PacifiCorp and affiliates;
i. Insurance coverage;
j. Overhead items including utilities, property taxes, security services, and other
corporate headquarter expenses; and
k. All other allocated expenses.
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 JUNE 2,2021
REQUEST NO. 5: Please provide a copy of all regulatory orders relating to PacifiCorp
or the Company and its subsidiaries issued by state agencies in Oregon, Washington, California,
Wyoming, Utah, or the Federal Energy Regulatory Commission in 2018 through 2021to date.
REQUEST NO. 6: Please summarize all of the Company's environmental cleanup costs
during 2019 through202l to date. Please show all account numbers and the amount booked to
each subaccount.
REQUEST NO. 7: Please provide access to all employee newsletters issued during
2018 throughZl2l to date.
REQUEST NO. 8: Please provide a matrix identiffing the major capital expenditure
approval levels that includes the dollar level of authorization by employee title, division, and
company. Please include within your response the dollar level at which the individual capital
expenditures require approval by the Company's Board of Directors ("Board of Directors").
REQUEST NO. 9: Please provide an analysis of any sales of land and/or plant for the
years 2019 through 2021to date, if any. Please show gains, losses, and supporting
documentation including accounting entries for removal of items from rate base.
REQUEST NO. 10: Please provide details of any planned sales of land and/or plant for
the remainder of 2021through 2022. Please include within your response the estimated date of
these sales and the planned accounting treatment.
REQUEST NO. 11: Please provide a list of "out-of-period adjustments" and
"extraordinary items" for the years 2019 through 2021 to date.
REQUEST NO. 12: Please provide a schedule showing injuries and damages claims
over $10,000 for the years 2017 through202l. Please include within your response the
description of each item, the amount for each item, and the account charged.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J JUNE 2,2021
REQUEST NO. 13: Please provide detail of all advertising expenses recorded above the
line including account and subaccounts where posted, dates posted, vendor names, explanations,
and amounts posted during 2019 through2l2l to date.
REQUEST NO. 14: Please provide copies of all advertisements used during 2019
through 2021to date and correlate the advertisement with the specific detail provided in the
Company's response to Request No. 13.
REQUEST NO. 15: Please provide copies of all billing inserts for 2019 through 2021 to
date. Please indicate the states where they were sent. Please also provide a schedule showing
the amount and account numbers charged for all costs to produce, print, and distribute the inserts.
REQUEST NO. 16: Please prepare a schedule for plant in service that includes project
name and description, and the dollar amount of each project closed to plant in service in excess
of $5 million from 2018 through2}2l to date.
REQUEST NO. l7: Please provide copies of the cost/benefit analysis, internal rates of
retum, or similar analysis for each capital project included in the Company's response to Request
No. 16.
REQUEST NO. 18: Please provide all documents the Company used to demonstrate the
benefits realized by the Company for each capital project included in the Company's response to
Request No. 16.
REQUEST NO. 19: Please provide copies of the monthly, quarterly, and annual
comparison of operating and capital budget to actuals expenditures for 2017 through202l to
date. Please include within your response a narrative explanation for budget variations. This
should include, but not be limited to, written operating and capital budget variance reports and
explanations used by Company officers and managers to monitor and control budgets under their
responsibility. Please supplement your response as additional information becomes available
throughout 2021.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JLINE 2,2021
REQUEST NO.20: Please provide copies of all audit reports issued by the Company's
internal auditors for all audits completed during 2019 through202l to date.
REQUEST NO.21: Please provide a copy of each adjusting joumal entry proposed by
the Company's independent auditors in the two most recent audits of the Company. Please
include within your response the documentation supporting these adjustments, and the
documentation supporting any items that the Company decided not to adjust that are not reflected
in the Company's financial records and/or financial statements.
REQUEST NO. 22: Please provide a list of all leased items from 2018 through2}2l to
date. Please separate capital leases from operating leases and show the dates, terms, amounts,
and accounts used for each lease.
REQUEST NO. 23: Please provide a schedule of prepaid items for 2019 through 2021
to date showing amounts posted, vendor narnes, explanations, and accounts to which these items
were booked. Please include within your response any significant changes to prepaid items
occurring or planned to occur in202l and2022.
REQUEST NO. 24: For each offrcer of the Company, please provide the total dollar
amount of remuneration for 2018 through202l. Please separate by year, salary, incentive pay,
options, benefits, and other. For each officer, please provide the percentages of his or her total
remuneration that is allocated to other subsidiaries each year along with the basis for that
allocation.
REQUEST NO. 25: Please provide the following direct labor related information as
recorded annually for the twelve months ended December 31,2018 through 2020. Information,
where applicable, should be listed by O&M expense, other expense, construction and other
account groups (listed by functional categories, i.e., generation, transmission, distribution,
customer, A&G, etc.). Please provide the information on a system-wide basis, and on an Idaho
jurisdiction basis. The response should include wages and salaries for each employee category
(officer, exempt, non-exempt, and union), paid time-off, overtime, bonuses, incentive pay, and
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JUNE 2,2021
overheads for pension, benefits, and payroll taxes. Please also include average and year-end
number of employees by employee category. Include part-time and temporary employees as full-
time equivalents.
REQUEST NO. 26: Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years. Please provide any additional workforce
reduction programs planned for 2021through 2022.
REQUEST NO. 27: Please summarize all benefit and retirement plans provided to any
classification of Company employees. Please also include any changes that have occurred to the
benefits/accruals during the past five years.
REQUEST NO. 28: Please provide the amount of Supplemental Executive Retirement
Plan expense, if any, which is included in the test year.
REQUEST NO.29: Please provide copies of the Company's pension and actuarial
reports for the years 2018 through 2021 . Also, please provide any actuarial calculations and
documentation that shows the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified), Company contributions, balances, and assumptions.
REQUEST NO.30: Please provide access to the Board of Directors' meeting minutes
for each meeting in2019 through 2021to date.
REQUEST NO.31: Please provide copies of the Board of Directors' materials
distributed forlat meetings from 2019 through 2021 to date. Please also include the same for the
Compensation Committee.
REQUEST NO.32: To the extent not previously included in the Company's response to
Request No. 31, please provide access to copies of all studies used to determine employee
compensation, including executive compensation, and explanations of how the Company applied
them in the years 2018 through202l to date.
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 6 JUNE 2,2021
REQUEST NO.33: Please provide the fixed costs associated with the use of the
Company-owned aircraft, such as pilot salaries, hangar fees, etc. Please provide the total dollar
amount posted in 2019 and2020 at the system level, the account(s) posted, and how those costs
were allocated or assigned to the Idatro operations.
REQUEST NO. 34: Please provide the variable costs associated with the use of the
Company-owned aircraft. Please provide dollar amount posted in2019,2020 and202l to date,
at the system level, the account(s) posted, and how those costs were allocated or assigned to the
Idatro operations.
DATED at Boise,Idaho, tti" Lil day of June 2021
Matt Hunter
Deputy Attomey General
i:umisc:prodreq/pace2l.Tdhmhjt prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JUNE 2,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF JUNE 2021, SERVED
THE FOREGOING FRIST PRODUCTION REQUEST OF TIIE COMMISSION STAFF
TO ROCKY MOIINTATN POWER, N CASE NO. pAC-E-2t-07, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
idahodockets@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@ paci fi corp.com
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOI-INTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
matthew.mcvee@pacifi com.com
CERTIFICATE OF SERVICE