20080808Greene Tree to ATL 1-3.pdf

McDevitt & Miler LLP
Lawyers
[phone]
[phone] (Fax)
420 West Bannock Street
P.O. Box 2564-88701
Boise, Idaho 88702
I: 16
Chas. F. McDevitt
Dean J. (Joe) Miler
August 8, 2008
Via Hand Delivery
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Greene Tree, Inc.
Case No. ATL-E-08-2
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and three (3) copies of Discovery
Requests of Greene Tree Inc., to Atlanta Power Company.
An additional copy of the document and this letter is included for return to me with your file stamp
thereon.
Very Truly Yours,
~~;Lll\~iler
DJM/hh
Enclosures
ORIGINAL.
Dea J. Miller
McDEVIT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]l2
joe(fcdevitt-miller.com
i :16
Attorneys for Greene Tree lnc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ATLANTA POWER COMPAN FORAN
ORDER AUTHORIING INCREASE IN THE
COMPANY'S RATES AND CHAGES FOR
ELECTRIC SERVICE IN THE STATE OF
IDAHO.
Case No. ATL-E-08-2
DISCOVERY REQUESTS OF
GREENE TREE INC., TO
ATLANTA POWER COMPANY
Greene Tree, Inc., requests that the Atlanta Power Company provide the following
documents and information on or before August 22, 2008.
Atlanta Power Company is reminded that responses puruat to Commission Rules of
Procedure must include the name and phone number of the person preparng the document, and
the name, location and phone number ofthe record holder. Reference IDAPA 31.01.01.228.
Ths Discover Request is to be considered as continuing, and Atlanta Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil augment the documents produced.
Please provide answers to each question; supporting workpaper that provide detail or are
the source of information used in calculations; the name and telephone number of the peron
preparng the documents; and the name, location and telephone number of the record holder.
DISCOVERY REQUESTS OF GREENE TREE INC., TO ATLANTA POWER COMPAN- 1
For each item, please indicate the name of the person(s) preparg the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearng.
REQUEST NO.1: Please provide any and all cost of service studies or analysis used to develop
the proposed 10 cents/kh charge for residential customers and the proposed 20 cents/kwh
charge for commercial customers.
REQUEST NO.2: With respect to Exhbit 2 accompanying your Application, please identify
the listed categories of expense you consider to reflect varable costs, i.e. those costs which
fluctuate depending on the amount of electrcal generation produced.
REQUEST NO.3: Please provide in narative form your rationale, whether based on cost of
serice or otherise, for the proposed 10 cents/kwh charge for residential customers and the
proposed 20 cents/kh charge for commercial customers and the disparty betwee the two
charges.
Dated this ~ day of August, 2008
Respectfully submitted,
McDEVITT & MILLER LLP
~'\
McDevitt & Miler LLP
420 W. Banock
Boise, ID 83702
Phone: [phone]
Fax: [phone]
Counsel for Greene Tree, Inc.
DISCOVERY REQUESTS OF GREENE TREE INC., TO ATLANA POWER COMP AN- 2
CERTIFICATE OF SERVICE
I hereby certify that on the ~ day of August, 2008, I caused to be served, via the
method(s) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
j j ewell(áuc. state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
~....
....
....
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Israel Ray
Atlanta Power Co.
11140 Chicken Dinner Rd.
Caldwell, ID 83406
Robert E. Smith
2209 N. Bryson Rd.
Boise, ID 83713
Hand Delivered ....
U.S. Mail )L
Fax ....
Fed. Express ....
Email ....
Hand Delivered ....
U.S. Mail ~
Fax ....
Fed. Express ....
Email ....
DISCOVERY REQUESTS OF GREENE TRE INC., TO ATLANTA POWER COMPAN- 3