20210623PAC to Staff 1-34-Redacted.pdf

ROCKY MOUNTAIN
HPYY,EN,,,1407 W Norlh Temple, Suite 330
Salt Lake City, Utah 84116
June 23,2021
Jan Noriyuki
Dayn Hardie
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
ian.norivuki@puc. idaho. eov (C)
RE ID PAC.E.2I-07
IPUC Set I (1-34)
Please find enclosed Rocky Mountain Power's Responses to IPUC I't Set Data Requests 1-34.
Provided via e-mail are the non-confidential Attachment and via encryption are the Confidential
Attachments. Voluminous Attachment IPUC 7 and voluminous Confidential Attachment IPUC
16-2 are provided on CD only. Confidential information is provided subject to protected under
IDAPA 31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject to any
subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
--Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c.: Ronald L. Williams/PIIC [e-mail]
Bradley G. Mullins/PIIC bmrull ins(D.rnwanalvtics. com
Adam Gardner/PIIC [e-mail] $r)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. [e-mail] (W)
Eric L. Olsen/IIPA [e-mail] (C)
Anthony Yankel/IIPA tony@yankel. net (C)
Randall C. Budge/B ayer randy @racineolson. com (C)
Thomas J. Budge/Bayer ti @,racineolson. com $D(C)
Brian C. Collins/Bayer bcoll ins@consul tbai. com (!\D(C)
Maurice Brubaker/Bayer mbrubaker@consultba i. c om (C)
PAC-E-21-07 / Rocky Mountain Power
hlrl,ie 23,2021
IPUC Data Request I
IPUC Data Request I
Please provide copies of the monthly tial balances from January 2018 through the
most current month available. Please supplement your response when additional
months become available throughout 2021.
Response to IPUC Data Request I
Please refer to Attachment IPUC I whichprovides the monthly frial balances
from January 2018 throughz02l to-date (through March 2021). The Company
will supplement this response as additional information becomes available.
Recordholder:Nancy Adolphson
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
h;mre 23,2021
IPUC Data Request 2
IPUC Data Request 2
Please provide a copy of the Company Chart ofAccounts.
Response to IPUC Data Request 2
Please referto AttachmentIPUC 2.
Recordholder: Nancy Adolphson
Sponsor:StEve McDougal
PAC-E-21-07 / Rocky Mountain Power
June23,202l
IPUC Data Request 3
IPUC Data Request 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 through
2021 to date. Please list the amounts paid, accounts charged, and date of payment.
Please also provide a brief swnmary of the services performed. If services were
performed in support of a docketed federaUstate 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.
Response to IPUC Data Request 3
The Company objects to this request to the extent that it seeks privileged
information, and specifically with respect to descriptions of services performed.
The Company further objects to the request as overly broad, outside the scope of
this proceeding and not reasonably calculated to lead to discoverable evidence
because it seeks information about legal expenses not allocated to Idaho. Without
waiving this objection, the Company responds as follows:
Please refer to Confidential Attachment IPUC 3 which provides the costs of legal
matters allocated to Idaho for services during calendar year 2019 through 2021 to-
date (through March 2021).
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Catherine Docekal / Justin Waterman
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
June 23,2021
IPUC Data Request 4
IPUC Data Request 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) Internal 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;
O Overhead items including utilities, properly taxes, security services, and other
corporate headquarter expenses; and
(k) All other allocated expenses.
Response to IPUC Data Request 4
(a) Please refer to Attachment IPUC 4-1 which provides the total costs associated
with intemal audit activities incurred by PacifiCorp for calendar years 2019
and2020.
(b) Please refer to Attachment IPUC 4-2 which provides the issuance costs
associated with extemally filed regulatory reports (Securities and Exchange
Commission (SEC), Federal Energy Regulatory Commission (FERC), and
state reports) for calendar years 2019 and2020.
(c) Please refer to Attachment IPUC 4-3 which provides a detailed listing of
external auditor (Deloitte and Touche, and Deloitte) expenses for calendar
years 2019 and2020.
PAC-E-21-07 / Rocky Mountain Power
June23,202l
IPUC Data Request 4
(d) Please refer to Attachment IPUC 4-4 which provides the total rating agency
fees incurred for 2019 and2020, associated with PacifiCorp's outstanding
long-term debt and preferred stock series, and commercial paper program.
(e) Please refer to Attachment IPUC 4-5 which provides software and hardware
costs incurred by PacifiCorp in calendar years 2019 and2020.
(f) PacifiCorp does not incur expenses for the compensation, ftavel or meetings
related to PacifiCorp's Board of Directors.
(g) Please refer to Attachment IPUC 4-6 which provides the total costs associated
with the Company's corporate aircraft for calendar years 2019 and2020.
(h) Please refer to Attachment IPUC 4-7 which provides the total costs of tavel
and training expenses incurred by PacifiCorp's named executive officers
(NEo).
(i) Please refer to the direct testimony of Company witness, Steven McDougal,
specifically Exhibit No. 40, page 4.7.3 for the insurance premium amounts
booked during 2020. During 2019, the Company booked $4.4 million in
excess liability premiums, and $5.3 million in property premiums.
O The Company does not allocate overhead costs to administrative and general
(A&G) FERC Account 920 through FERC Account 935. Please refer to
Attachment IPUC 4-8 which provides a list of total company A&G costs for
the year ended December 31,2019, and December 31, 2020.
(k) Please refer to the Company's response to subpart O above.
Recordholder:Justin Waterman lLawa Miller
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
Jvne 23,2021
IPUC Data Request 5
IPUC Data Request 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 through202l to date.
Response to IPUC Data Request 5
PacifiCorp objects to this data request on the grounds that it seeks information
that is not relevant and the request is not reasonably calculated to lead to the
discovery of admissible evidence. The Company also objects to the extent that the
request is overly broad and it would be unduly burdensome to produce the
information requested. The request asks for "all orders" from five state
commissions and the Federal Energy Regulatory Commission (FERC) over a
three-year period. Furthermore, "order" is not defined and could include
Administative Law Judge (ALI) rulings and state commission orders on
procedural matters, protective orders, and other non-substantive matters. Finally,
the Company objects to the extent that the information is publicly available.
Subject to and without waiving the foregoing objections, the Company states as
follows:
All regulatory orders are publicly available on the respective websites of each of
the agencies listed below:
California : https : //www. cpuc. ca. qov/documents/
Oregon : https ://apps. puc. state. or. us/edockets/search. asp
Utah: https://psc utah.cov/
Washington:https ://www. ulc.wa. gov/doc uments-and-proceed in gs/dockets
Wyoming : https : //dms. wv o. eov/S earchDocket. aspx
FERC : https ://www. fbrc. qov/maior-orders-requlations
Recordholder Ted Weston
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
June 23,2021
IPUC Data Request 6
IPUC Data Request 6
Please summarize all of the Company's environmental cleanup costs during2019
through 2021 to date. Please show all account numbers and the amount booked to
each subaccount.
Response to IPUC Data Request 6
Please refer to Attachment IPUC 6 which provides a list of environmental projects
and costs incurred in calendar years 2019,2020 and202l to-date (through May
2021).
Recordholder: Nancy Adolphson
Sponsor:James Owen
PAC-E-21-07 / Rocky Mormtain Power
Jt;lne23,202l
IPUC Data Request 7
IPUC Ilata Request 7
Please provide access to all employee newsletters iszued during 2018 through
2A2l b date.
Responsc to IPUC Data Request 7
Please refer to Attachment IPUC 7 which provides copies of PacifiCorp's
employee newsletters issued during 2018 through 2021to-date (through March
2021).
Recordholder:Heather Beery ll';isa h*rn
Melissa NottinghamSponsor:
PAC-E-21-07 / Rocky Mountain Power
June 23,2021
IPUC Data Request 8
IPUC Data Request 8
Please provide a matrix identifying 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").
Response to IPUC Data Request 8
Please refer to Confidential Attachment IPUC 8-l which provides an extact from
PacifiCorp's most recent and approved Corporate Govemance and Approvals
document, Appendix A, which details authorization levels by employee title.
There is no designated approval required from PacifiCorp's Board of Directors.
Capital projects over $50 million must be approved by Berkshire Hathaway
Energy Company's (BHE) chief executive officer (CEO) and PacifiCorp's
Chairman of the Board of Directors and CEO, William Ferhman.
Please refer to Confidential Attachment IPUC 8-2 which provides additional
approval levels for major capital expenditures based on title.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement Q.{DA) executed in this proceeding.
Recordholder:Catherine Docekal
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
Jvne23,202l
IPUC Data Request 9
IPUC Data Request 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.
Response to IPUC Data Request 9
Please refer to Confidential Attachment IPUC 9 which provides information for
calendar years 2 0 I 9 , 2020 and 2021 to-date (through May 2021) .
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Marcy Lanners / Colin Sutherland
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jwrc23,2021
IPUC Data Request 10
IPUC Data Request 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 teatnent.
Response to IPUC Data Request 10
Please refer to Confidential Attachment IPUC l0
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Marcy Lanners /Nathan Bailey
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jvre23,202l
IPUC Data Request 11
IPUC Data Request 11
Please provide a list of "out-of-period adjustnents" and "extraordinary items" for
the years 2019 through202l to date.
Response to IPUC Data Request 11
Please refer to Attachment IPUC 11 which provides the accounting detail of the
2019 and2020 *out of period adjustnents" and "extaordinary items".
Information for the 2021 peiod has not been evaluated for extaordinary or out-
of-period items. 2021 information will not be available until the Company's
December 2021 Results of Operations @OO) has been finalized; anticipated
April 30,2022.
Recordholder:Mike Martin
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
hlrlLe23,2021
IPUC Data Request 12
IPUC Data Request 12
Please provide a schedule showing injuries and damages claims over $10,000 for
the years 2017 throughz02l. Please include within your response the description
of each item, the amount for each item, and the account charged.
Response to IPUC Data Request 12
Please refer to Confidential Attachment IPUC 12 which provides rnjury and
damage claims information through hne202l.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder: Wendy Wallis
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
Jurte 23,2021
IPUC Data Request 13
IPUC Data Request 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 through202l to date.
Response to IPUC Data Request 13
Please refer to Attachment IPUC l3 which provides advertising cost details for
calendar years 2019,2020 and202l to-date (through March 2021). Note: during
the preparation of a general rate case (GRC), the Company makes allocation
corrections to certiain advertising expenses and reflects them on Page 4.1
(Miscellaneous General Revenue and Expense adjustnent) of Exhibit No. 40.
Recordholder: Catherine Docekal / Heather Beery / Justin Waterman
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
June 23,2021
IPUC Data Request 14
IPUC Data Request 14
Please provide copies of all advertisements used during 2019 through202l to date
and correlate the advertisement with the specific details provided in the
Company's response to RequestNo. 13.
Response to IPUC Data Request L4
The Company assumes that the reference to "RequestNo. 13" is intended to be a
reference to IPUC Data Request 13. Based on the foregoing assumption, the
Company responds as follows:
Rocky Mountain Power (RMP) communicates with customers regarding a variety
of topics such as customer service, billing assistance, safety, energy efficiency
(EE), electical facility improvements and more. Please refer to Attachment IPUC
l4-1 which provides accounting information. Note: the categories in column U
"Add Samples" correspond with the categories listed below. Please refer to
Attachment IPUC l4-2 which provides website links to sample advertisements
used in Idaho from 2019 through 2021to-date (through March 2021). Note: the
order of the provided website links also conform to the categories listed below.
A: Service / Reliability Campaign Samples
B: Demand-Side Management (DSM) / Wattsmart EE Samples
C: Safety Samples
D: Mailing Samples
E: Bill Inserts (please also refer to IPUC Data Request l5)
F: Collateral Samples
Recordholder:Heather Beery
Melissa NottinghamSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jvne 23,2021
IPUC DataRequest 15
IPUC Data Request 15
Please provide copies of all billing inserts for 2019 through 2021to 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.
Response to IPUC Data Request 15
Please refer to Attachment IPUC 15-1 through Attachment IPUC 15-3 which
provides website links to copies of billing inserts for 2019 through 2021to-date
(through March 2021) for all states served by Rocky Mountain Power (RMP) and
Pacific Power (PP). Please also refer to the Company's responses to IPUC Data
Request 13 and IPUC Data Request 14 which provide information regarding the
costs to produce, print and dishibute inserts.
Recordholder:Heather Beery
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jtne23,202l
IPUC Data Request 16
IPUC Data Request 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 services in
excess of $5 million from 2018 through20zl to date.
Response to IPUC Data Request 16
Please refer to Confidential Attachment IPUC 16-l and Confidential Attachment
IPUC 16-2. Note: the provided information includes calendar years 2018 through
2020, and calendar year 2021to-date (through May 2021).
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Various
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
Jlune23,2021
IPUC Data Request 17
IPUC Data Request 17
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.
Response to IPUC Data Request 17
The Company assumes that the reference to "Request No. 16" is intended to be a
reference to IPUC Data Request 16. Based on the foregoing assumption, the
Company responds as follows:
Please refer to the Company's response to IPUC Data Request 16, specifically
Confidential Attachment IPUC 16-1, file "2018-May 2021 Additions by Project
GT $5m CONF", column H "Folder" and column I "Supporting Documentation".
The referenced supporting documentation is provided in Confidential Attachment
IPUC 16.2.
In addition, please note the following:
in Confidential Attachment IPUC 16-1, where "Project Description" has been
highlighted blue, these capital projects were part of Case PAC-E-I7-06
(Application for Binding Ratemaking Treafrnent for Wind Repowering), and
in Confidential Attachment IPUC l6-2, where "Project Description" has been
highlighted green, these capital projects were part of Case PAC-E-I7-07
(Application of Rocky Mountain Power for a Certificates of Public
Convenience and Necessity (CPCN) and for Binding Ratemaking Treatment
for New Wind and Transmission Facilities), also known as the Company's
Energy Vision 2020 (EY 2020) projects.
Recordholder: Various
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
Jwrc23,2021
IPUC Data Request 18
IPUC Data Request 18
Please provide all documents the Company used to demonsfate the benefits
realized by the Company for each capital project included in the Company's
response to Request No. 16.
Response to IPUC Data Request 18
The Company assumes that the reference to "Request No. 16" is intended to be a
reference to IPUC Data Request 16. Based on the foregoing assumption, the
Company responds as follows:
The Company does not conduct any costs/benefits analysis after capital projects
are completed.
Recordholder:Not applicable
Not applicableSponsor:
PAC-E-21'07 / Rocky Mountain Power
lluorte 23,2021
IPUC Data Request 19
IPUC Data Request 19
Please provide copies of the monthly, quarterly, and annual comparison of
operating and capital budget to actuals expendihues for 2017 through 2021to
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.
Response to IPUC Data Request 19
Please refer to:
a Confidential Attachment IPUC l9-1 for calendar year 2017;
Confidential Attachment IPUC l9-2 for calendar year 201 8;
O
a
o
Confidential Attachment IPUC l9-3 for calendar year 2019.
Confidential Attachment IPUC l9-4 for calendar year 2020.
Confidential Attachment IPUC l9-5 for calendar year 2021to-date (January
2021 through May 2021).
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and furlher subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Catherine Docekal
Sponsor:Steve McDougal
a
PAC-E-21-07 / Rocky Mountain Power
June23,202l
IPUC Data Request 20
IPUC Data Request 20
Please provide copies of all audit reports issued by the Company's internal
auditors for all audits completed during 2019 through202l to date.
Response to IPUC Data Request 20
Please refer to Attachment IPUC 20-1 which provides a summary of internal audit
reports completed during calendar years 2019 through 2021to-date (through May
202t).
Please refer to Confidential Attachment IPUC 20-2 through Confidential
Attachment IPUC 204 which provide copies of the completed intemal audit
reports, calendar years 2019 through 2021 to-date (through May 2021) listed in
Attachment IPUC 20-1.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Renee Halpem / John Caspar
Nikki KoblihaSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jvrne 23,2021
IPUC Data Request 2l
IPUC Data Request 21
Please provide a copy of each adjusting joumal enty 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 adjustnents,
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.
Response to IPUC Data Request 21
PacifiCorp did not have any accounting adjusftnents proposed by its external
auditors during the year ended December 31,2019 or the year ended December
31,2020 audits.
Recordholder:Catherine Docekal
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
Jlurlre23,2021
IPUC Data Request22
IPUC Data Request22
Please provide a list of all leased items from 2018 throughzD2l to date. Please
separate capital leases from operating leases and show the dates, terms, amounts,
and accounts used for each lease.
Response to IPUC Data Request12
Please refer to Confidential Attachment IPUC 22whrchincludes all leased items
from 2018 through Jwre202l.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:David Holt
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
hxre23,202l
IPUC Data Request 23
IPUC Data Request 23
Please provide a schedule of prepaid items for 2019 through 2021to date showing
amounts posted, vendor names, 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 rrl,2021 and2022.
Response to IPUC Data Request 23
Please refer to Attachment IPUC 23 which provides a schedule of prepaid items
incurred in calendar years 2019,2020 and202l to-date (through May 2A2\by
general ledger (G/L) account.
Recordholder Nancy Adolphson
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
h;rlle23,2021
IPUC Data Request24
IPUC Data Request24
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.
Response to IPUC Data Request24
Please refer to Confidential Attachment IPUC 24 for the requested information
pertaining to the Company's named executive officers (NEO). The Company does
not allocate any NEO total remunerations to subsidiaries. Calendar year 2021
information is not available at this time because the Company does not track other
incentives on a monthly basis.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Dave Curnow
Sponsor:Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
hlrre 23,2021
IPUC Data Request 25
IPUC Data Request 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
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 fulltime equivalents.
Response to IPUC Data Request 25
Please refer to Attachment IPUC 25-1 which provides Total Company
information for calendar years 2018 through 2020.
PacifiCorp does not maintain wages and full time equivalent (FTE) information
by the employee groups listed in the request, but has made efforts to categorize
such information by named executive officer (NEO), exempt employees, non-
exempt (and non-union) and union employee categories.
Costs associated with wages, salaries and payroll taxes are charged to numerous
accounts and to acquire such data on an Idaho jurisdictional basis would result in
copious time and voluminous data. For the purposes of allocating costs on an
Idaho-allocated basis, the Company applies allocation factors calculated using the
prevailing jurisdictional allocation protocol approved for each respective calendar
year.
Please refer to Attachment IPUC 25-2 which provides direct labor and various
other labor related expenses shown by functional group category on both a Total
Company and Idaho allocated basis for calendar years 2018 through 2020.
Recordholder:Craig Stelter
Steve McDougalSponsor
PAC-E-2I-07 / Rocky Mountain Power
June 23,2021
IPUC Data Request26
IPUC Data Request 26
Please provide the quantifiable savings from any cost/workforce reduction
progftrms during the past five years. Please provide any additional workforce
reduction programs planned for 2021through 2022.
Confidential Response to IPUC Data Request 26
PacifiCorp objects to this data request to the extent it requests information that is
privileged. PacifiCorp also objects to this data request as not relevant and not
reasonably calculated to lead to the discovery of admissible evidence in this
proceeding to the extent that the request seeks information not associated with a
normalized test-year, draft or speculative analyses, or materials not associated
with an official company-decision relevant to the Company's filing. Without
waiving this objection, PacifiCorp responds as follows:
PacifiCorp has not actively implemented workforce reduction programs during
past five years. PacifiCorp manages workforce based on the level necessary to
support continued delivery of safe and reliable service. As the business evolves,
PacifiCorp workforce levels may fluctuate in response to changes in operations,
regulations or temporary economic conditions.
PacifiCorp successfu lly implemented Advanced Metering Infrastructure (A MI)
projects in California and The ects led to a net
reduction o tull-
time
a year on a company
are reflected in this
general rate case (GRC) filing.
The Company has AMI projects in Utah and Idaho that are in progress and
scheduled to be complete by the end of 2022. The Utah and Idaho AMI ects
are to deliver combined net reductions
FTE
per year
ona company
PacifiCorp initiated a work from home program in exchange for a 10 percent
reduction in base pay, and a voluntary time-off without .ln2 these
in a total
ona company The
progftrm
continue as permanent programs.
program are anticipated to
PAC-E-21-07 / Rocky Mountain Power
June23,202l
IPUC DataRequest 26
Confidential information is provided zubject to protection under IDAPA
31.01.01.067 aad31.01.01.233, the Idgho Public Utilities Commission's Rules of
Proeedure No. 67 - Information Exeurpt from Fublic Review, and firther subject
to the Non-Disclosme Agreement (NDA) e:recuGd inthis proceeding.
Recordholder:Brithey Davis-Smiley
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jwrc 23,2021
IPUC Data Request 27
IPUC Data Request27
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.
Response to IPUC Data Request27
P1ease refer to Confidential AttachmentlPuc 27.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Denise Neimann
Sponsor:Julie Lewis
PAC-E-21-07 / Rocky Mountain Power
hme 23,2A21
IPUC DataRequest 28
IPUC Data Rquest 28
Please provide the amount of Supplemenral Executive Retirement Plan expense, if
any, which is included in the testyear.
Response to IPUC Date Request2S
There is $0.00 (zero) Supplemental Executive Retirernent Plan (SERP) expense
included in the test year.
Recordholder;Craig Sclter
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jvne23,202l
IPUC Data Request29
IPUC Data Request 29
Please provide copies of the Company's pension and actuarial reports for the years
2018 through202l. 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.
Response to IPUC Data Request 29
Please refer to Confidential Attachment IPUC 29 which provides the actuarial
reports for calendar years 201 8 , 2019 and 2020 which document assumptions and
calculation of PacifiCorp's pension expense as calculated under Accounting
Standards Codification (ASC) 715 (supersedes Financial Accounting Standards
(FAS) 87), Company contributions and balances. The calendar year 2021actuarial
report will become available in approximately January 2022.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Catherine Docekal
Sponsor:Nikki Kobliha
PAC-E-21-07 / Rocky Mountain Power
h;rlre23,2021
IPUC Data Request 30
IPUC Data Request 30
Please provide access to the Board of Directors' meeting minutes for each
meeting n2019 through 2021to date.
Response to IPUC Data Request 30
PacifiCorp's Board of Directors do not meet in person therefore there are no
meeting minutes for the time period requested. The Company's Board of
Directors act through unanimous written consent resolutions. Please refer to
Confidential Attachment IPUC 30 which provides the Company's Board of
Directors' unanimous written consent (UWC) resolutions from 2019 through
2021to-date (through June 2021).
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Frank Grey
To Be DeterminedSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jvne23,202l
IPUC Data Request 31
IPUC Data Request 31
Please provide copies of the Board of Directors' materials distibuted forlat
meetings from 2019 through 2021to date. Please also include the same for the
Compensation Committee.
Response to IPUC Data Request 31
The Company has no documents responsive to this request. As explained in the
Company's response to IPUC Data Request 30, PacifiCorp's Board of Directors
do not meet but rather acts through unanimous written consent (UWC). The
Company does not have a compensation committee.
Recordholder: Frank Grey
Sponsor:To Be Determined
PAC-E-21-07 / Rocky Mountain Power
June 23,2021
IPUC Data Request 32
IPUC Data Request 32
To the extent not previously included in the Company's response to Request No.
3 1, 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.
Response to IPUC Data Request 32
The Company assumes that the reference to "Request No. 31" is intended to be a
reference to IPUC Data Request 31. Based on the foregoing assumption, the
Company responds as follows:
Please refer to Confidential Attachment IPUC 32 which provides the survey lists
used by PacifiCorp in determining market salaries. PacifiCorp's pay philosophy is
to target base pay and related employee benefits at the median (50 percent) of the
markets in which the Company competes. Market data is collected by
PacifiCorp's participation in annual surveys. The survey data is then submitted in
MarketPay, PacifiCorp's online market pricing system. The Company can make
MarketPay available to the Idaho Public Utilities Commission (IPUC) staff, if
required.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Leslie Chase
Sponsor:Julie Lewis / Steve McDougal
PAC-E-21-07 / Rocky Mountain Power
Jwrc 23,2021
IPUC Data Request 33
IPUC Data Request 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 Idaho operations.
Response to IPUC Data Request 33
Please refer to Attachment IPUC 33 which provides the fixed costs associakd
with the Company-owned aircraft for calendar years 2019 and2020 on atotal
company and Idaho allocated basis.
Recordholder:Justin Waterman /Nick Highsmith
Steve McDougalSponsor:
PAC-E-21-07 / Rocky Mountain Power
Jvne 23,2021
IPUC Data Request 34
IPUC Data Request 34
Please provide the variable costs associated with the use of the Company-owned
aircraft. Please provide dollar amount posted ua2019,2020 and202l to date at
the system level, the account(s) posted and how those costs were allocated or
assigned to the Idaho operations.
Response to IPUC Data Request 34
Please refer to Attachment IPUC 34 that provides the variable costs associated
with the use of the Company-owned aircraft for calendar years 2019,2020, and
2021 to-date (through lNday 2021) on a total company and Idaho allocated basis.
Recordholder Justin Waterman /Nick Highsmith
Sponsor:Steve McDougal