+---+----+------+---------------------+-------------------------------+
| * | *  | **A  | > **Issue**         | **Discussion**                |
| * | *S | ccou |                     |                               |
| I | ch | nt** |                     |                               |
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| N |    |      |                     |                               |
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| * |    |      |                     |                               |
| * |    |      |                     |                               |
+===+====+======+=====================+===============================+
| * | *  | *    | Functionalization   | In response to Data Request   |
| * | *S | *Acc | of the Account      | 8, PAC stated that asset      |
| 1 | ch | ount |                     | 3031570 supports the          |
| * | -1 | 3    | KWH HISTORICAL DATA | Transmission and Generation   |
| * | ** | 03** | COLLECTION          | functions of the Company and  |
|   |    |      |                     | should be allocated to PT.    |
|   |    | **3  | Should PT be an     | PAC claims PT is not an       |
|   |    | 0315 | "allowable"         | "allowable"                   |
|   |    | 70** | functionalization?  | functionalization, and        |
|   |    |      |                     | therefore functionalized it   |
|   |    |      | Would the PT ratio  | to PTD.                       |
|   |    |      | be plant based?     |                               |
|   |    |      |                     | Direct analysis does not      |
|   |    |      |                     | preclude the direct           |
|   |    |      |                     | functionalization of an       |
|   |    |      |                     | account by any means as long  |
|   |    |      |                     | there is a clear description  |
|   |    |      |                     | and justification for the     |
|   |    |      |                     | functionalization.            |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | > Functionalization | In response to Data Request   |
| * | *S | *Acc | > of the Account    | 8, PAC stated that the        |
| 2 | ch | ount |                     | Customer Service System is    |
| * | -1 | 3    | CUSTOMER SERVICE    | the software which contains   |
| * | ** | 03** | SYSTEM (CSS)        | information on all of the     |
|   |    |      |                     | Company's customers. PAC      |
|   |    | **3  | Does the direct     | contends that the system      |
|   |    | 0318 | analysis justify    | bills customers for           |
|   |    | 30** | the                 | Generation, Transmission and  |
|   |    |      | functionalization   | Distribution services and is  |
|   |    |      | of the account to   | thus appropriately            |
|   |    |      | PTD?                | functionalized PTD.           |
|   |    |      |                     |                               |
|   |    |      | Should customer     | When direct analysis is used, |
|   |    |      | information systems | there is a requirement for a  |
|   |    |      | be functionalized   | clear description and         |
|   |    |      | to distribution     | justification for the         |
|   |    |      |                     | functionalization of all      |
|   |    |      |                     | accounts and sub-accounts.    |
|   |    |      |                     |                               |
|   |    |      |                     | PAC did not explain the how   |
|   |    |      |                     | the Customer Information      |
|   |    |      |                     | System was being utilized in  |
|   |    |      |                     | the company wide energy       |
|   |    |      |                     | information system and        |
|   |    |      |                     | specifically how Customer     |
|   |    |      |                     | Information was being         |
|   |    |      |                     | utilized at the production    |
|   |    |      |                     | and /or transmission          |
|   |    |      |                     | functions.                    |
|   |    |      |                     |                               |
|   |    |      |                     | The description of the        |
|   |    |      |                     | software indicates that the   |
|   |    |      |                     | software is primarily used    |
|   |    |      |                     | for the retail side of the    |
|   |    |      |                     | business.                     |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | > Functionalization | In response to Data Request   |
| * | *S | *Acc | > of the Account    | 8, PAC stated that asset      |
| 3 | ch | ount |                     | 3032030 takes revenue &       |
| * | -1 | 3    | FRANCHISE TAX       | volumetric data from the CSS  |
| * | ** | 03** | SYSTEM              | and SAP systems to compute    |
|   |    |      |                     | and report taxes. PAC states  |
|   |    | **3  | Does the direct     | that since both the CSS and   |
|   |    | 0320 | analysis justify    | SAP systems are               |
|   |    | 30** | the                 | functionalized with PTD, this |
|   |    |      | functionalization   | asset should also be          |
|   |    |      | of the account to   | functionalized with PTD.      |
|   |    |      | PTD?                |                               |
|   |    |      |                     | BPA believes that since       |
|   |    |      | Should the          | franchise taxes are not       |
|   |    |      | functionalization   | exchangeable and              |
|   |    |      | of a software       | functionalized to             |
|   |    |      | system follow the   | Distribution, it seems that   |
|   |    |      | functionalizations  | the software used to track    |
|   |    |      | of the operation it | the franchise taxes should    |
|   |    |      | supports?           | not be exchangeable. The      |
|   |    |      |                     | franchise tax system should,  |
|   |    |      | Should the computer | therefore, be functionalized  |
|   |    |      | system that is used | to Distribution.              |
|   |    |      | to compute and      |                               |
|   |    |      | report the          |                               |
|   |    |      | Franchise Taxes be  |                               |
|   |    |      | functionalized to   |                               |
|   |    |      | Distribution so as  |                               |
|   |    |      | to conform to the   |                               |
|   |    |      | income statement    |                               |
|   |    |      | accounts?           |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **3  | EMPLOYEE            | Functionalization of the      |
| * | *S | 03** | PERFORMANCE &       | Account                       |
| 4 | ch |      | SALARY SYSTEM       |                               |
| * | -1 | **3  |                     | In response to Data Request   |
| * | ** | 0322 | Should the          | 8, PAC stated that asset      |
|   |    | 90** | functionalization   | 3032290 is the software which |
|   |    |      | of a software       | allows employees to enter     |
|   |    |      | system follow the   | their annual goals and        |
|   |    |      | functionalizations  | development plans.            |
|   |    |      | of the operation it | PacifiCorp's original filing  |
|   |    |      | supports?           | functionalized this account   |
|   |    |      |                     | using PTD. PacifiCorp now     |
|   |    |      | Should the          | supports functionalization    |
|   |    |      | functionalization   | using the Labor ratio.        |
|   |    |      | of asset 3032290 be |                               |
|   |    |      | changed to the      |                               |
|   |    |      | Labor ratio?        |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | > Functionalization | > Functionalization of the    |
| * | *S | *Acc | > of the Account    | > Account                     |
| 5 | ch | ount |                     |                               |
| * | -1 | 3    | ELECTRONIC TAGGING  | In response to Data Request   |
| * | ** | 03** | OUTAGE MANAGE       | 8, PAC stated this asset      |
|   |    |      | SYSTEM              | develops NERC-mandated        |
|   |    | **3  |                     | information for the tracking  |
|   |    | 0323 | What is the correct | of its energy transactions    |
|   |    | 20** | functionalization   | between power marketing and   |
|   |    |      | of the ELECTRONIC   | transmission companies. It    |
|   |    |      | TAGGING OUTAGE      | supports the Transmission and |
|   |    |      | MANAGE SYSTEM?      | Generation functions of the   |
|   |    |      |                     | Company and should be         |
|   |    |      | Should the PT ratio | allocated PT. As this is not  |
|   |    |      | be plant based?     | an "allowable"                |
|   |    |      |                     | functionalization, the        |
|   |    |      |                     | Company has functionalized it |
|   |    |      |                     | PTD.                          |
|   |    |      |                     |                               |
|   |    |      |                     | Direct analysis does not      |
|   |    |      |                     | preclude the direct           |
|   |    |      |                     | functionalization of an       |
|   |    |      |                     | account by any means as long  |
|   |    |      |                     | there is a clear description  |
|   |    |      |                     | and justification for the     |
|   |    |      |                     | functionalization.            |
+---+----+------+---------------------+-------------------------------+
| * | *  | **3  | HR- BENEFITS OPEN   | Functionalization of the      |
| * | *S | 03** | ENROLLMENT ONLINE   | Account                       |
| 6 | ch |      |                     |                               |
| * | -1 | **3  | Should the          | Asset 3032380 is the software |
| * | ** | 0323 | functionalization   | system that allows employees  |
|   |    | 80** | of a software       | select among medical, dental  |
|   |    |      | system follow the   | and vision plans.             |
|   |    |      | functionalizations  | PacifiCorp's original filing  |
|   |    |      | of the operation it | functionalized this account   |
|   |    |      | supports?           | using PTD. In response to     |
|   |    |      |                     | Data Request 8, PacifiCorp    |
|   |    |      | Should the          | now supports                  |
|   |    |      | functionalization   | functionalization using the   |
|   |    |      | of asset HR-        | Labor ratio.                  |
|   |    |      | BENEFITS OPEN       |                               |
|   |    |      | ENROLLMENT ONLINE   |                               |
|   |    |      |                     |                               |
|   |    |      | \(3032380\) be      |                               |
|   |    |      | changed to the      |                               |
|   |    |      | Labor ratio?        |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **3  | FIELDNET PRO METER  | Functionalization of the      |
| * | *S | 03** | READING SYST -HRP   | Account                       |
| 7 | ch |      | REP                 |                               |
| * | -1 | **3  |                     | In response to Data Request   |
| * | ** | 0323 | Should the          | 8, PAC believes that Account  |
|   |    | 30** | functionalization   | 3032330 should more           |
|   |    |      | of a software       | appropriately be              |
|   |    |      | system follow the   | functionalized to             |
|   |    |      | functionalizations  | distribution.                 |
|   |    |      | of the operation it |                               |
|   |    |      | supports?           |                               |
|   |    |      |                     |                               |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of asset HR-        |                               |
|   |    |      | FIELDNET PRO METER  |                               |
|   |    |      | READING SYST -HRP   |                               |
|   |    |      | REP (3032330) be    |                               |
|   |    |      | changed to the      |                               |
|   |    |      | Labor ratio?        |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | MID OFFICE          | In response to Data Request   |
| * | *S | *Acc | IMPROVEMENT PROJECT | 8, PAC stated that asset      |
| 8 | ch | ount |                     | 3032450 are software programs |
| * | -1 | 3    | What is the purpose | which support the Company's   |
| * | ** | 03** | of the software?    | Mid-Office group, part of the |
|   |    |      |                     | Commercial and Trading        |
|   |    | **3  | Does the direct     | organization, and thus        |
|   |    | 0324 | analysis justify    | functionalized to PROD.       |
|   |    | 50** | the                 |                               |
|   |    |      | functionalization   | The explanation of the items  |
|   |    |      | of the account to   | was not sufficiently clear to |
|   |    |      | PROD?               | allow an understanding of the |
|   |    |      |                     | software's purposes and       |
|   |    |      |                     | therefore the applicability   |
|   |    |      |                     | of the functionalization.     |
+---+----+------+---------------------+-------------------------------+
| * | *  | **3  | OUTAGE CALL         | Functionalization of the      |
| * | *S | 03** | HANDLING            | Account                       |
| 9 | ch |      | INTEGRATION         |                               |
| * | -1 | **3  |                     | In response to Data Request   |
| * | ** | 0324 | Should the          | 8, PAC believes that Account  |
|   |    | 80** | functionalization   | 3032480 should more           |
|   |    |      | of a software       | appropriately be              |
|   |    |      | system follow the   | functionalized to             |
|   |    |      | functionalizations  | distribution.                 |
|   |    |      | of the operation it |                               |
|   |    |      | supports?           |                               |
|   |    |      |                     |                               |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of asset HR- OUTAGE |                               |
|   |    |      | CALL HANDLING       |                               |
|   |    |      | INTEGRATION         |                               |
|   |    |      |                     |                               |
|   |    |      | \(3032480\) be      |                               |
|   |    |      | changed to the      |                               |
|   |    |      | Distribution?       |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **3  | ON LINE EMPLOYEE    | Functionalization of the      |
| * | *S | 03** | EXPENSE EXPRESS     | Account                       |
| 1 | ch |      |                     |                               |
| 0 | -1 | **3  | Should the          | PacifiCorp's original filing  |
| * | ** | 0325 | functionalization   | functionalized this account   |
| * |    | 00** | of a software       | using PTD. In response to     |
|   |    |      | system follow the   | Data Request 8, PacifiCorp    |
|   |    |      | functionalizations  | now supports                  |
|   |    |      | of the operation it | functionalization by the      |
|   |    |      | supports?           | Labor ratio.                  |
|   |    |      |                     |                               |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of asset HR- ON     |                               |
|   |    |      | LINE EMPLOYEE       |                               |
|   |    |      | EXPENSE EXPRESS be  |                               |
|   |    |      | changed to the      |                               |
|   |    |      | Labor ratio?        |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | Functionalization   | In response to Data Request   |
| * | *S | *Acc | of the Account      | 8, PAC stated that asset      |
| 1 | ch | ount |                     | 3032560 is the Powertax       |
| 1 | -1 | 3    | POWER TAX           | software which develops       |
| * | ** | 03** |                     | detailed estimates and        |
| * |    |      | Should the          | forecasts of current and      |
|   |    | **3  | functionalization   | deferred taxes for Federal,   |
|   |    | 0325 | of a software       | State tax and regulatory      |
|   |    | 60** | system follow the   | filings. It supports all      |
|   |    |      | functionalizations  | areas of the Company and is   |
|   |    |      | of the operation it | functionalized PTD.           |
|   |    |      | supports?           |                               |
|   |    |      |                     | Under the 2008 ASCM           |
|   |    |      | Should software     | Regulatory costs and current  |
|   |    |      | used develops       | and deferred taxes for        |
|   |    |      | detailed estimates  | Federal, State tax are not    |
|   |    |      | and forecasts of    | exchangeable.                 |
|   |    |      | current and         |                               |
|   |    |      | deferred taxes for  | The software used develops    |
|   |    |      | Federal, State tax  | detailed estimates and        |
|   |    |      | and regulatory      | forecasts of current and      |
|   |    |      | filings should not  | deferred taxes for Federal,   |
|   |    |      | be exchangeable?    | State tax and regulatory      |
|   |    |      |                     | filings should therefore not  |
|   |    |      |                     | be exchangeable.              |
+---+----+------+---------------------+-------------------------------+
| * | *  | **A  | SCHOOL -            | Functionalization of the      |
| * | *S | sset | Substation/Circuit  | Account                       |
| 1 | ch | 3    | History of O        |                               |
| 2 | -1 | 0325 |                     | In response to Data Request   |
| * | ** | 90** | Should the          | 8, PAC stated that asset      |
| * |    |      | functionalization   | 3032590 is a software system  |
|   |    |      | of a software       | which provides load           |
|   |    |      | system follow the   | information for substations   |
|   |    |      | functionalizations  | and circuits. The PacifiCorp  |
|   |    |      | of the operation it | now supports a                |
|   |    |      | supports?           | functionalization of TD       |
|   |    |      |                     | rather than PTD as more       |
|   |    |      | Should the          | appropriate for this asset.   |
|   |    |      | functionalization   |                               |
|   |    |      | of asset 3032590 be |                               |
|   |    |      | changed to the TD   |                               |
|   |    |      | ratio?              |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **3  | MAPPING AND         | Functionalization of the      |
| * | *S | 03** | CONNECTIVITY        | Account                       |
| 1 | ch |      | ENABLER SOFTWARE    |                               |
| 3 | -1 | **3  |                     | In response to Data Request   |
| * | ** | 0327 | Should the          | 8, PAC believes that Account  |
| * |    | 20** | functionalization   | 3032720 should more           |
|   |    |      | of a software       | appropriately be              |
|   |    |      | system follow the   | functionalized to             |
|   |    |      | functionalizations  | distribution.                 |
|   |    |      | of the operation it |                               |
|   |    |      | supports?           |                               |
|   |    |      |                     |                               |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of asset HR-        |                               |
|   |    |      | MAPPING AND         |                               |
|   |    |      | CONNECTIVITY        |                               |
|   |    |      | ENABLER SOFTWARE    |                               |
|   |    |      | (3032720) be        |                               |
|   |    |      | changed to the      |                               |
|   |    |      | Distribution?       |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **A  | COMPUTER BASED      | In response to Data Request   |
| * | *S | sset | TRAINING (CBT)      | 8, PAC stated that asset      |
| 1 | ch | 3    |                     | 3032810 is a computer based   |
| 4 | -1 | 0328 | Should the          | training system at the        |
| * | ** | 10** | functionalization   | Company's production plants.  |
| * |    |      | of a software       | The Company now supports a    |
|   |    |      | system follow the   | functionalization of PROD     |
|   |    |      | functionalizations  | rather than PTD as more       |
|   |    |      | of the operation it | appropriate for this asset.   |
|   |    |      | supports?           |                               |
|   |    |      |                     |                               |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of asset HR-        |                               |
|   |    |      | COMPUTER BASED      |                               |
|   |    |      | TRAINING (CBT)      |                               |
|   |    |      |                     |                               |
|   |    |      | \(3032810\) be      |                               |
|   |    |      | changed to the      |                               |
|   |    |      | PROD?               |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | > Functionalization | In response to Data Request   |
| * | *S | *Acc | > of the Account    | 8, PAC stated that asset      |
| 1 | ch | ount |                     | 3033020 is the Regulation     |
| 5 | -1 | 3    | RCDA REGULATION     | Discovery software which      |
| * | ** | 03** | DISCOVERY TOOL      | supports the discovery        |
| * |    |      |                     | process in all Federal and    |
|   |    | **3  | Should the          | State regulatory proceedings. |
|   |    | 0330 | functionalization   | PAC claimed that it is        |
|   |    | 20** | of a software       | appropriately functionalized  |
|   |    |      | system follow the   | using PTD because regulation  |
|   |    |      | functionalizations  | embraces all assets of the    |
|   |    |      | of the operation it | Company.                      |
|   |    |      | supports?           |                               |
|   |    |      |                     | Under the 2008 ASCM,          |
|   |    |      | What is the correct | Regulatory costs are not      |
|   |    |      | functionalization   | exchangeable. The software    |
|   |    |      | of a computer       | used to support the discovery |
|   |    |      | system that is used | process in all Federal and    |
|   |    |      | in conjunction with | State regulatory proceedings  |
|   |    |      | the regulatory O&M  | should therefore not be       |
|   |    |      | expenses?           | exchangeable.                 |
|   |    |      |                     |                               |
|   |    |      | Should it be        |                               |
|   |    |      | functionalized to   |                               |
|   |    |      | Distribution so as  |                               |
|   |    |      | to conform to the   |                               |
|   |    |      | O&M Accounts?       |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | > Functionalization | In response to Data Request   |
| * | *S | *Acc | > of the Account    | 8, PAC stated that asset      |
| 1 | ch | ount |                     | 3033020 is the software       |
| 6 | -1 | 3    | PI2PI SCHOOL PI TO  | interface between Asset       |
| * | ** | 03** | RANGER PI INTERFACE | 3032590 (a software program   |
| * |    |      |                     | which provides load           |
|   |    | **3  | Should the          | information for substations   |
|   |    | 0330 | functionalization   | and circuits) and other       |
|   |    | 50** | of a software       | software programs             |
|   |    |      | system follow the   |                               |
|   |    |      | functionalization   | In response to Data Request   |
|   |    |      | of the operation it | 8, PAC believes that Account  |
|   |    |      | supports?           | 3033050 should more           |
|   |    |      |                     | appropriately be              |
|   |    |      | What is the correct | functionalized to TD.         |
|   |    |      | functionalization   |                               |
|   |    |      | of a computer       |                               |
|   |    |      | system that is used |                               |
|   |    |      | in conjunction with |                               |
|   |    |      | the regulatory O&M  |                               |
|   |    |      | expenses?           |                               |
|   |    |      |                     |                               |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of asset PI2PI      |                               |
|   |    |      | SCHOOL PI TO RANGER |                               |
|   |    |      | PI INTERFACE        |                               |
|   |    |      |                     |                               |
|   |    |      | \(3033020\) be      |                               |
|   |    |      | changed to the TD   |                               |
|   |    |      | ratio?              |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | > Functionalization | In response to Data Request   |
| * | *S | *Acc | > of the Account    | 8, PAC stated that asset      |
| 1 | ch | ount |                     | 3033110 is the software       |
| 7 | -1 | 3    | CTHAS-C&T Hedge     | interface between Commercial  |
| * | ** | 03** | Actg/Actg Standards | and Trading Hedging           |
| * |    |      | Inte                | Accounting System and the     |
|   |    | **3  |                     | Commercial and Trading        |
|   |    | 0331 | Should the          | Accounting Standards Data     |
|   |    | 10** | functionalization   | Base and is thus              |
|   |    |      | of a software       | functionalized to PROD.       |
|   |    |      | system follow the   |                               |
|   |    |      | functionalizations  | Under the 2008 ASCM           |
|   |    |      | of the operation it | Derivatives are               |
|   |    |      | supports?           | functionalized to             |
|   |    |      |                     | Distribution.                 |
|   |    |      | Should the software |                               |
|   |    |      | interface           | The cost of software used to  |
|   |    |      | (CTHAS-C&T Hedge    | support hedging activity      |
|   |    |      | Actg/Actg Standards | should therefore be           |
|   |    |      | Inte) be            | functionalized to             |
|   |    |      | functionalized to   | Distribution.                 |
|   |    |      | Distribution so as  |                               |
|   |    |      | to conform to the   |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of Derivatives?     |                               |
|   |    |      |                     |                               |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of asset HR-        |                               |
|   |    |      | CTHAS-C&T Hedge     |                               |
|   |    |      | Actg/Actg Standards |                               |
|   |    |      | Inte                |                               |
|   |    |      |                     |                               |
|   |    |      | \(3033110\) be      |                               |
|   |    |      | changed to the      |                               |
|   |    |      | Distribution?       |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | > Functionalization | In response to Data Request   |
| * | *S | *Acc | > of the Account    | 8, PAC stated that asset      |
| 1 | ch | ount |                     | 3034900 include miscellaneous |
| 8 | -1 | 3    | MISC --             | small software packages - not |
| * | ** | 03** | Miscellaneous       | specifically identified in    |
| * |    |      |                     | SAP. Those assigned to a      |
|   |    | **3  | What is the correct | specific state are            |
|   |    | 0349 | functionalization   | functionalized DIST, those    |
|   |    | 00** | of the MISC --      | allocated system wide are     |
|   |    |      | Miscellaneous?      | functionalized PTD although   |
|   |    |      |                     | functionalization of Labor    |
|   |    |      | Does the level of   | may also be appropriate.      |
|   |    |      | difficulty in       |                               |
|   |    |      | functionalizing an  | In                            |
|   |    |      | account that        | PacifiCor                     |
|   |    |      | requires direct     | p_2007_ASC_Appendix1_PAC.xls, |
|   |    |      | analysis allow for  | 303490 are called EMS -       |
|   |    |      | a functionalization | ENERGY MANAGEMENT SYSTEMS     |
|   |    |      | other than the      | using the Production          |
|   |    |      | default             | functionalization code.       |
|   |    |      | functionalization?  |                               |
|   |    |      |                     | The explanation of the items  |
|   |    |      | Given the limited   | was not sufficiently clear to |
|   |    |      | documentation       | allow an understanding of the |
|   |    |      | should the asset be | software's purposes and       |
|   |    |      | functionalized to   | therefore the applicability   |
|   |    |      | distribution?       | of the functionalization.     |
|   |    |      |                     |                               |
|   |    |      |                     | PACs explanation indicated    |
|   |    |      |                     | that it would be difficult to |
|   |    |      |                     | provide a detailed            |
|   |    |      |                     | description of the            |
|   |    |      |                     | miscellaneous software        |
|   |    |      |                     | packages / systems.           |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | **Generic Direct    | Inconsistency between how the |
| * | *S | *Acc | Analysis Issue**    | IOUs functionalize certain    |
| 1 | ch | ount |                     | types of software, i.e.       |
| 9 | -1 | 3    | Should BPA adopt    | metering, customer            |
| * | ** | 03** | common              | information systems, work     |
| * |    |      | functionalization   | management, etc.              |
|   |    |      | for similar types   |                               |
|   |    |      | of software assets? | The issue is whether BPA      |
|   |    |      |                     | should maintain consistency   |
|   |    |      | Should the          | in the functionalization of   |
|   |    |      | functionalization   | these common types of         |
|   |    |      | of Account 303      | programs amongst utilities    |
|   |    |      | follow the          | when calculating ASC.         |
|   |    |      | functionalization   |                               |
|   |    |      | of the Account      |                               |
|   |    |      | where the expense   |                               |
|   |    |      | is recorded?        |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | **Generic Direct    | Inconsistency in the way the  |
| * | *S | *Acc | Analysis Issue**    | IOUs functionalize Deferred   |
| 2 | ch | ount |                     | Pension, Pay and other labor  |
| 0 | -1 | 1    | Should BPA adopt    | related Assets and            |
| * | ** | 82.3 | common              | Liabilities.                  |
| * |    | and  | functionalization   |                               |
|   |    | Acc  | for similar types   | PGE and Avista and NW use the |
|   |    | ount | of regulatory       | Labor Ratio.  IPC uses PTD.   |
|   |    | 2    | assets and          | PSE and PAC functionalize     |
|   |    | 54** | liabilities?        | these assets to               |
|   |    |      |                     | Distribution.                 |
|   |    |      | Should the          |                               |
|   |    |      | functionalization   | The issue is whether BPA      |
|   |    |      | of Regulatory       | should maintain consistency   |
|   |    |      | Assets and          | in the functionalization of   |
|   |    |      | Liabilities follow  | deferred pension, pay and     |
|   |    |      | the                 | other labor related assets    |
|   |    |      | functionalization   | and liabilities amongst       |
|   |    |      | of the Account      | utilities when calculating    |
|   |    |      | where the expense,  | ASC.                          |
|   |    |      | revenue, or         |                               |
|   |    |      | amortization is     |                               |
|   |    |      | recorded?           |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **   | **Generic Direct    | Direct analysis is required   |
| * | *S | Acco | Analysis Issue**    | in the functionalization of   |
| 2 | ch | unts |                     | Other Regulatory Assets       |
| 1 | -1 | 18   | Should BPA require  | (Account 182.3),              |
| * | a  | 2.3, | that asset accounts | Miscellaneous Deferred Debits |
| * | nd | 186, | that have a         | (Account 186), Other Deferred |
|   | S  | 253, | corresponding       | Credits (Account 253), and    |
|   | ch | and  | liability account   | Other Regulatory Liabilities  |
|   | -3 | 2    | have a common       | (Account 254).                |
|   | ** | 54** | functionalization?  |                               |
|   |    |      | For example, should | Direct analysis should        |
|   |    |      | pension costs in    | include maintaining a         |
|   |    |      | Accounts 182.3 and  | consistency in                |
|   |    |      | 254 have the same   | functionalization where there |
|   |    |      | functionalization?  | is an asset in either Account |
|   |    |      |                     | 182.3 or 186 and offsetting   |
|   |    |      | Should the          | liabilities in either Account |
|   |    |      | functionalization   | 253 or 254.                   |
|   |    |      | of the amortization |                               |
|   |    |      | match the           | Direct analysis also requires |
|   |    |      | functionalization   | showing how the assets and    |
|   |    |      | of the              | liabilities flow through the  |
|   |    |      | corresponding       | Income Statement.             |
|   |    |      | assets and          |                               |
|   |    |      | liabilities?        |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **   | Other Regulatory    | Direct is the default         |
| * | *S | Acco | Assets (Account     | functionalization of Other    |
| 2 | ch | unts | 182.3),             | Regulatory Assets (Account    |
| 2 | -1 | 18   | Miscellaneous       | 182.3), Miscellaneous         |
| * | a  | 2.3, | Deferred Debits     | Deferred Debits (Account      |
| * | nd | 186, | (Account 186),      | 186), Other Deferred Credits  |
|   | S  | 253, | Other Deferred      | (Account 253), and Other      |
|   | ch | and  | Credits (Account    | Regulatory Liabilities        |
|   | -3 | 2    | 253), and Other     | (Account 254).                |
|   | ** | 54** | Regulatory          |                               |
|   |    |      | Liabilities         | PacifiCorp uses its latest    |
|   |    |      | (Account 254)       | results of operations to      |
|   |    |      |                     | allocate and then             |
|   |    |      | Should PacifiCorp   | functionalize the assets and  |
|   |    |      | functionalize the   | liabilities (Accounts         |
|   |    |      | actual Other        | 182.3,186, 253, and 254).     |
|   |    |      | Regulatory Assets   | This is then used to allocate |
|   |    |      | (Account 182.3),    | and functionalize the total   |
|   |    |      | Miscellaneous       | assets and liabilities        |
|   |    |      | Deferred Debits     | (Accounts 182.3,186, 253, and |
|   |    |      | (Account 186),      | 254) as reported in the 2006  |
|   |    |      | Other Deferred      | FERC Form 1.                  |
|   |    |      | Credits (Account    |                               |
|   |    |      | 253), and Other     | PacifiCorp does not allocate  |
|   |    |      | Regulatory          | and functionalize (Accounts   |
|   |    |      | Liabilities         | 182.3,186, 253, and 254),     |
|   |    |      | (Account 254) shown | shown in the FERC Form on a   |
|   |    |      | in the FERC Form 1  | line-by-line basis.           |
|   |    |      | on a line by line   |                               |
|   |    |      | detail?             | Direct analysis should be     |
|   |    |      |                     | performed on the assets and   |
|   |    |      |                     | liabilities shown in the      |
|   |    |      |                     | utilities FERC Form 1 data.   |
|   |    |      |                     | The direct analysis should    |
|   |    |      |                     | not exclude any of the sub    |
|   |    |      |                     | accounts from the FERC        |
|   |    |      |                     | Form 1. All sub accounts,     |
|   |    |      |                     | regardless of whether they    |
|   |    |      |                     | are in the utility's rate     |
|   |    |      |                     | base, should be included. .   |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | Other Regulatory    | Account 1823040 is            |
| * | *S | *Acc | Assets -            | functionalized to Production. |
| 2 | ch | ount | Functionalization   | Line 825, Regulatory Assets   |
| 3 | -1 | 182  |                     | Tab.                          |
| * | ** | .3** | Does the direct     |                               |
| * |    |      | analysis justify    | This account encompasses      |
|   |    |      | the                 | costs related to Oregon's     |
|   |    |      | functionalization   | Electric Restructuring Law.   |
|   |    |      | of the account to   |                               |
|   |    |      | PROD?               | The explanation of the items  |
|   |    |      |                     | was not sufficiently clear to |
|   |    |      | What is the correct | allow an understanding of the |
|   |    |      | functionalization   | software's purposes and       |
|   |    |      | of Oregon's         | therefore the applicability   |
|   |    |      | Electric            | of the functionalization.     |
|   |    |      | Restructuring Law?  |                               |
|   |    |      |                     | It is not clear how costs     |
|   |    |      |                     | related to Oregon's Electric  |
|   |    |      |                     | Restructuring Law relate to   |
|   |    |      |                     | production or transmission.   |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | **Other Regulatory  | Account 182.3 Oregon SB 408   |
| * | *S | *Acc | Assets -            | is functionalized using the   |
| 2 | ch | ount | Functionalization** | PTD ratio.                    |
| 4 | -1 | 182  |                     |                               |
| * | ** | .3** | **Assets not        | PacifiCorp does not include   |
| * |    |      | included in PAC     | sufficient information to     |
|   |    |      | regulated rate      | allow BPA to understand the   |
|   |    |      | base**:             | justification of the use of   |
|   |    |      |                     | the PTD ratio.                |
|   |    |      | Does the direct     |                               |
|   |    |      | analysis justify    |                               |
|   |    |      | the                 |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of the account to   |                               |
|   |    |      | PTD?                |                               |
|   |    |      |                     |                               |
|   |    |      | What is the correct |                               |
|   |    |      | functionalization   |                               |
|   |    |      | of Oregon's SB 408? |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | Other Regulatory    | Account 182.3 ARO Regulatory  |
| * | *S | *Acc | Assets -            | is functionalized to          |
| 2 | ch | ount | Functionalization   | Distribution.                 |
| 5 | -1 | 182  |                     |                               |
| * | ** | .3** | Assets not included | PacifiCorp stated in its      |
| * |    |      | in PAC regulated    | response to BPA data request  |
|   |    |      | rate base:          | 25 that the account           |
|   |    |      |                     | established to offset the     |
|   |    |      | Does the direct     | difference between the annual |
|   |    |      | analysis justify    | FAS 143 accretion and         |
|   |    |      | the                 | depreciation expense and the  |
|   |    |      | functionalization   | Commission depreciation       |
|   |    |      | of the account to   | expense.                      |
|   |    |      | PTD?                |                               |
|   |    |      |                     | It is not clear that the      |
|   |    |      | What is the correct | income statement accounts     |
|   |    |      | functionalization   | associated with these assets  |
|   |    |      | of ARO Regulatory   | are functionalized to         |
|   |    |      | assets?             | distribution.                 |
|   |    |      |                     |                               |
|   |    |      | Should PAC adjust   |                               |
|   |    |      | the FERC Form 1data |                               |
|   |    |      | depreciation        |                               |
|   |    |      | expense so as to    |                               |
|   |    |      | conform to the      |                               |
|   |    |      | Distribution        |                               |
|   |    |      | functionalization?  |                               |
|   |    |      |                     |                               |
|   |    |      | Should PAC adjust   |                               |
|   |    |      | the FERC Form 1     |                               |
|   |    |      | depreciation        |                               |
|   |    |      | expense so as to    |                               |
|   |    |      | conform to the      |                               |
|   |    |      | Distribution        |                               |
|   |    |      | functionalization?  |                               |
|   |    |      |                     |                               |
|   |    |      | Should PAC adjust   |                               |
|   |    |      | the FERC Form 1     |                               |
|   |    |      | data for any and    |                               |
|   |    |      | all non             |                               |
|   |    |      | Depreciation        |                               |
|   |    |      | expenses so as to   |                               |
|   |    |      | conform to the      |                               |
|   |    |      | Distribution        |                               |
|   |    |      | functionalization?  |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | Other Regulatory    | Account functionalization of  |
| * | *S | *Acc | Assets -            | FAS 158 Pension Account.      |
| 2 | ch | ount | Functionalization   |                               |
| 6 | -1 | 182  |                     | PacifiCorp stated in its      |
| * | ** | .3** | Assets not included | response to BPA data request  |
| * |    |      | in PAC regulated    | 25, that the account          |
|   |    |      | rate base:          | recognizes the net transition |
|   |    |      |                     | obligation, prior service     |
|   |    |      | What is the correct | cost and gain/loss of the     |
|   |    |      | functionalization   | pension expense. The cost is  |
|   |    |      | of FAS 158 Pension  | not amortized, rather the     |
|   |    |      | Account?            | actuarially determined is     |
|   |    |      |                     | recognized and accrued and is |
|   |    |      | Should of FAS 158   | a loading to the labor        |
|   |    |      | Pension Account be  | expense.                      |
|   |    |      | functionalized      |                               |
|   |    |      | using the Labor     | PAC has not suggested a       |
|   |    |      | Ratio?              | functionalization of this     |
|   |    |      |                     | account.                      |
+---+----+------+---------------------+-------------------------------+
| * | *  | **2  | Other Deferred      | It is unclear how the         |
| * | *S | 53** | Credits             | following accounts are        |
| 2 | ch |      |                     | related to distribution.      |
| 7 | -1 |      | Credits not         |                               |
| * | ** |      | included in PAC     | PAC functionalizes these      |
| * |    |      | regulated rate      | accounts to distribution.     |
|   |    |      | base:               |                               |
|   |    |      |                     | These expenses include power  |
|   |    |      | Sunnyside           | costs, transmission costs,    |
|   |    |      | Cogeneration Bonds  | depreciation and fuel         |
|   |    |      |                     | purchases.                    |
|   |    |      | Deferred Credits -- |                               |
|   |    |      | Right of way        | It is not clear that the      |
|   |    |      |                     | income statement accounts     |
|   |    |      | Deseret Power       | associated with these Credits |
|   |    |      | Security Deposits   | are functionalized to         |
|   |    |      |                     | distribution. e.g. Sunnyside  |
|   |    |      | Centralia           | Cogeneration appears in       |
|   |    |      | Environmental       | Account 555.                  |
|   |    |      | Liabilities         |                               |
|   |    |      |                     |                               |
|   |    |      | Should PAC adjust   |                               |
|   |    |      | the FERC Form 1     |                               |
|   |    |      | data for any        |                               |
|   |    |      | expenses so as to   |                               |
|   |    |      | conform to the      |                               |
|   |    |      | Distribution        |                               |
|   |    |      | functionalization?  |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  | **2  | Other Deferred      | It is unclear how the         |
| * | *S | 53** | Credits             | following accounts are        |
| 2 | ch |      |                     | related to production,        |
| 8 | -1 |      | What is the correct | transmission or distribution. |
| * | ** |      | functionalization   |                               |
| * |    |      | of these accounts?  | \'SOFTWARE LICENSE PAYMENTS   |
|   |    |      |                     | -- MICROSOFT                  |
+---+----+------+---------------------+-------------------------------+
| * | *  | **2  | Other Deferred      | It is unclear how the         |
| * | *S | 53** | Credits             | following accounts are        |
| 2 | ch |      |                     | related to production,        |
| 9 | -1 |      | What is the correct | transmission or distribution. |
| * | ** |      | functionalization   |                               |
| * |    |      | of these accounts?  | \'AMERICAN ELECTRIC POWER CRP |
|   |    |      |                     |                               |
|   |    |      |                     | \'DEF REV-DUKE/HERMISTON GAS  |
|   |    |      |                     | SALE NOVATION                 |
|   |    |      |                     |                               |
|   |    |      |                     | The explanation of the items  |
|   |    |      |                     | was not sufficiently clear to |
|   |    |      |                     | allow an understanding of     |
|   |    |      |                     | their purpose and therefore   |
|   |    |      |                     | the applicability of the      |
|   |    |      |                     | functionalization.            |
+---+----+------+---------------------+-------------------------------+
| * | *  | **4  | > Other Electric    | It is unclear how the         |
| * | *S | 56** | > Revenues          | following accounts are        |
| 3 | ch |      |                     | related to production,        |
| 0 |  - |      | What is the correct | transmission or distribution: |
| * | 3B |      | functionalization   |                               |
| * |  - |      | of these accounts?  | > OTH EL/EXCL WHEEL           |
|   | O  |      |                     | >                             |
|   | th |      |                     | > USE OF FACIL REV            |
|   | er |      |                     | >                             |
|   | I  |      |                     | > MISC OTHER REV              |
|   | te |      |                     |                               |
|   | ms |      |                     | The explanation of the items  |
|   | ** |      |                     | was not sufficiently clear to |
|   |    |      |                     | allow an understanding of     |
|   |    |      |                     | their purpose and therefore   |
|   |    |      |                     | the applicability of the      |
|   |    |      |                     | functionalization             |
+---+----+------+---------------------+-------------------------------+
| * | *  | *    | **Generic Issue -   | PacifiCorp is reducing the    |
| * | *S | *555 | Purchased Power     | amount of its purchased power |
| 3 | ch | &    | Expense, Sales for  | expense and sales for resale  |
| 1 | 3, | 4    | Resale, and Price   | revenue by book-outs and      |
| * | ** | 47** | Spread**            | trading adjustments. It       |
| * |    |      |                     | appears that the other        |
|   | *  |      | How should          | utilities do not.             |
|   | *S |      | book-outs and       |                               |
|   | ch |      | trading adjustments | The inclusion or exclusion of |
|   | 3  |      | be treated for      | book-outs and trading         |
|   | B, |      | calculations of     | adjustments in purchased      |
|   | 3- |      | purchased power     | power and sales for resale    |
|   | yr |      | expense and sales   | numbers affects the price     |
|   | pp |      | for resale revenue  | spread calculation. BPA is    |
|   | &  |      | and the price       | considering whether it is     |
|   | O  |      | spread calculation? | appropriate to remove these   |
|   | SS |      |                     | adjustments when performing   |
|   | ** |      | Should the          | the price spread calculation  |
|   |    |      | treatment be        | and the ASCs.                 |
|   |    |      | consistent across   |                               |
|   |    |      | utilities?          |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  |      | **Generic Issue -   | Forecasted natural gas prices |
| * | *A |      | New Plant Additions | vary significantly between    |
| 3 | SC |      | --**                | utilities forecasting natural |
| 2 | Fo |      |                     | gas burning new additions.    |
| * | re |      | **Natural Gas       | None of the utilities         |
| * | ca |      | Prices**            | submitted documentation on    |
|   | st |      |                     | long term firm natural gas    |
|   | M  |      | Should BPA adopt a  | supply contracts, so it is    |
|   | od |      | common natural gas  | assumed that the differences  |
|   | el |      | price forecast in   | are a result of different     |
|   | ** |      | the ASC Forecast    | natural gas price forecasting |
|   |    |      | Model for all *new* | techniques.                   |
|   |    |      | natural gas-fired   |                               |
|   |    |      | plant additions?    |                               |
+---+----+------+---------------------+-------------------------------+
| * | *  |      | **Generic Issue -   | Projected capacity factors    |
| * | *A |      | New Plant           | vary significantly between    |
| 3 | SC |      | Additions -         | utilities for similar types   |
| 3 | Fo |      | Capacity Factor**   | of new resources.             |
| * | re |      |                     |                               |
| * | ca |      | Should BPA use      |                               |
|   | st |      | common              |                               |
|   | M  |      | representative      |                               |
|   | od |      | capacity factors in |                               |
|   | el |      | the ASC Forecast    |                               |
|   | ** |      | model for           |                               |
|   |    |      | estimating the      |                               |
|   |    |      | operating costs and |                               |
|   |    |      | expected energy     |                               |
|   |    |      | output for plant    |                               |
|   |    |      | additions of        |                               |
|   |    |      | similar type?       |                               |
+---+----+------+---------------------+-------------------------------+
| * | ** | **V  | **Generic Issue --  | There is inconsistency        |
| * | Sc | ario | Inclusion -**       | between utilities in the      |
| 3 | h. | us** |                     | functionalization of          |
| 4 | 1, |      | **Other Regulatory  | Regulatory Assets and         |
| * | In |      | Assets and          | Liabilities when not included |
| * | co |      | Liabilities**       | in rate base.                 |
|   | me |      |                     |                               |
|   | S  |      | What should be the  | For example, PAC              |
|   | ta |      | functionalization   | functionalized all Other      |
|   | te |      | of Other Regulatory | Regulatory Assets and         |
|   | me |      | Assets and          | Liabilities that are not in   |
|   | nt |      | Liabilities that    | its retail rate base to       |
|   | ** |      | are not included in | distribution. Idaho           |
|   |    |      | rate base by the    | functionalized several items  |
|   |    |      | regulatory          | in these same accounts, also  |
|   |    |      | authority?          | not included in its retail    |
|   |    |      |                     | rate base, to PTD.            |
|   |    |      | What should be the  |                               |
|   |    |      | functionalization   | Many of these accounts are    |
|   |    |      | of the              | included in working capital   |
|   |    |      | corresponding       | for ratemaking purposes.      |
|   |    |      | income statement    |                               |
|   |    |      | accounts for the    | There is concern that the     |
|   |    |      | Regulatory Assets   | treatment of the income       |
|   |    |      | and Liabilities     | statement accounts for Other  |
|   |    |      | that are not        | Regulatory Assets and         |
|   |    |      | included in rate    | Liabilities are not           |
|   |    |      | base by the         | consistent with the asset and |
|   |    |      | regulatory          | liability treatment for ASC   |
|   |    |      | authority?          | purposes.                     |
+---+----+------+---------------------+-------------------------------+
| * | ** | **5  | **Inclusion of      | It seems that the PAC did not |
| * | 3- | 55** | Residential         | remove the Residential        |
| 3 | yr |      | Exchange Payments   | Exchange payments from        |
| 5 | pp |      | in the calculation  | account 555 for th3e purpose  |
| * | &  |      | of the price        | of calculating the price      |
| * | O  |      | spread**            | spread.                       |
|   | SS |      |                     |                               |
|   | ** |      | Should the          | The Residential Exchange      |
|   |    |      | Residential         | payments are not exchangeable |
|   |    |      | Exchange payments   | costs and should be removed   |
|   |    |      | be removed from the | from the calculation of the   |
|   |    |      | price spread        | spread.                       |
|   |    |      | calculation?        |                               |
|   |    |      |                     | Pac has removed the           |
|   |    |      |                     | Residential Exchange payments |
|   |    |      |                     | from their Appendix 1 filing  |
|   |    |      |                     | for account 555 in Schedule   |
|   |    |      |                     | 3.                            |
|   |    |      |                     |                               |
|   |    |      |                     | Removal of the Residential    |
|   |    |      |                     | Exchange payments from the    |
|   |    |      |                     | spread calculation will       |
|   |    |      |                     | change the spread from 21.73% |
|   |    |      |                     | to 23.97%.                    |
+---+----+------+---------------------+-------------------------------+