20080820Staff to ATL 24-37.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
POBOX 83720
BOISE, IDAHO 83720~0074
[phone]
BARNO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702~5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ATLANTA POWER COMPANY FORAN )
ORDER AUTHORIZING INCREASES IN THE )
COMPANY'S RATES AND CHARGES FOR )
ELECTRIC SERVICE IN THE STATE OF )IDAHO. )
)
)
CASE NO. ATL-E-08-2
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ATLANTA POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that Atlanta Power Company (Company)
provide the following documents and information on or before FRIDAY, SEPTEMBER 5, 2008.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Atlanta Power is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder. For
THIRD PRODUCTION REQUEST TO
ATLANTA POWER COMPANY 1 AUGUST 20, 2008
calculations and workpapers, please provide electronic copies in Excel with formulas activated.
For each item, please indicate the name of the person(s) preparing the answers, along with the job
title of such person(s) and the witness who can sponsor the answer at hearng.
Request No. 24: The Company provided a listing of duties performed by and
corresponding pay for Linda Gil, Dave Gil and Israel Ray in response to Staff s Production
Request No. 13. Please provide the number of hours worked each month (by month for each
individual) in 2006,2007 and 2008 associated with those duties for that pay. Please include
within your response any time logs that were kept during those months to document time worked.
Request No. 25: If the information requested in Production Request No. 24 is unown
and/or undocumented, please provide an estimate of average hours worked by each individual for
the monthly pay received during 2006, 2007 and 2008.
Request No. 26: The Company identified a backhoe purchased in 2006 by Atlanta Power
and Ray Brothers Seed Company in response to Production Request No. 11. Please identify the
number of hours the backhoe was used by Atlanta Power and the number of hours the backhoe
was used by Ray Brothers Seed Company. If the information is unown and/or undocumented,
please provide an estimate of average hours used by each Company during 2006. Because the
backhoe was purchased in October 2006, please also estimate the expected average normal use by
each Company. Normal use would exclude use due to the tubine failure during 2007.
Request No. 27: The Company identified a 5KW portble generator purchased in 2007
by Atlanta Power and Ray Brothers Seed Company in response to Production Request No. 11.
Please identify the number of hours the generator was used by Atlanta Power and the number of
hours it was used by Ray Brothers Seed Company. If the information is unown and/or
undocumented, please provide an estimate of average hours used by each Company during 2007.
Because the generator was purchased in 2007, please also estimate the expected average normal
use by each Company. Normal use would exclude use due to the turbine failure during 2007.
THIRD PRODUCTION REQUEST TO
ATLANTA POWER COMPANY 2 AUGUST 20, 2008
Request No. 28: The Company provided two schedules in response to Production
Request Nos. 20 and 22. Please provide an electronic copy of these schedules with formulas
intact.
Request No. 29: The Company identified $4,150 lot rent in response to Production
Request No. 22. Please provide a copy of the rental agreement for the lot that includes the terms
of the rental (paries to the agreement, rental duration, rental costs, etc.) If the rental is month-to-
month, please identify the planed duration of the rental.
Request No. 30: The Company identified meal costs at Chuck~a~rama and the Snake
River Mar in response to Production Request No. 22. Please identify the business purpose of
these meals that appear to be in Marsing and Boise, Idaho.
Request No. 31: The Company identified lodging costs for the Beaver Lodge in response
to Production Request No. 22. Please identify the work that was performed requiring an
overnight stay at the Lodge.
Request No. 32: The Company identified fuel expenses in response to Production
Request No. 22. For some dates there are two to four purchases of fueL. Please provide a detailed
explanation of these fuel purchases.
Request No. 33: The Company identified fuel expenses in response to Production
Request No. 22. Please identify the business purpose of each trip associated with these fuel
purchases.
Request No. 34: Please identify the number of customers that have disconnected service
due to implementation of the emergency surcharge. If any, please identify the number by taiff
schedule.
THIRD PRODUCTION REQUEST TO
ATLANTA POWER COMPANY 3 AUGUST 20, 2008
Request No. 35: Please identify the number of customers that have not paid the amount
biled since the emergency surcharge. If any, please identify the number by tariff schedule. If
there are any customers that are routinely late with bil payments, please identify that number of
customers.
Request No. 36: The Company identified fencing costs of over $9,000 in response to
Production Request No. 20. Please describe the necessity for the fence and the factors causing the
significant cost.
Request No. 37: The Company updated its rate case cost estimate in a filing dated
August 8, 2008. The updated estimate is for $13,500 in rate case costs. Please provide a detailed
breakdown of these costs - tasks to be performed, hours per tasks performed, and rates per hour.
To the extent not already provided, please include within your response documentation of all rate
case costs incurred to date.
Respectfully submitted this c: l) ~ay of August 2008.
Scott Woodbur
Deputy Attorney General
Technical Staff: Patricia Hars
i:umisc:prodreq/atle08.2swph 3rd PR
THIRD PRODUCTION REQUEST TO
ATLANTA POWER COMPANY 4 AUGUST 20, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF AUGUST 2008,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ATLANTA POWER COMPANY , IN CASE NO. ATL~E~08~2, BY MAILING
A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
ISRAEL RAY
PRESIDENT
ATLANTA POWER COMPANY
11140 CHICKEN DINER ROAD
CALDWELL ID 83607
ROBERT SMITH
UTILITY CONSULTANT
2209 N BRYSON RD
BOISE ID 83713
DE-MAIL: utilitygroup(ßyahoo.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
o E~MAIL: joe(ßmcdevitt~miler.com
~.~
SECRETARY
CERTIFICATE OF SERVICE