20080905ATL to Staff 24-32, 34-37.pdf

ATLANTA POWER COMPANY INC.
11140 CHICKEN DINER ROAD
CALDWELL, IDAHO 83406
REceIVED
i8ØSEP -5 AH 10:23
IDAHO PUBLIC
UTILITIES COMMISSION
September 5, 2008
Idaho Public Utilties Commission
P.O. Box 82720
Boise, Idaho 83720~0074
ATL~E~08-02
ATTENTION COMMISSION SECRETARY AND HEAD LEGAL SECRETARY
Enclosed is Atlanta Power Company's reply to the Third Production Request of the
Commssion Staff to Atlanta Power Company together with a Certificate of Service.
s~~
Israel Ray
President
Israel Ray
Atlanta Power Company, Inc.
11140 Chicken Dinner Rd.
Caldwell, 10 83406
Tel. [phone]
Fax (208) 459~7014
Representative for Atlanta Power Company, Inc.
REcelVEO
i.SEP -5AKttv 23
IDAHO PUBLlC
OTlLlT1ES COMMlS$lON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )ATLANTA POWER COMPANY )
FOR AN ORDER AUTHORIZING INCREASES IN)
THE COMPANY'S RATES AND CHARGES FOR)
ELECTRIC SERVICE IN THE STATE OF IDAHO)
CASE NO. ATL-E-08-2
REPLY TO
PUC STAFF THIRD
PRODUCTION REQUEST
COMES NOW Atlanta Power Company Inc., ("Atlanta Power", "Applicant"
or "Company") and hereby files the following reply to the second production
request of the Idaho Public Utilties Commission Staff (Staff.
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
Staffs 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 docment time
worked.
Reply. Israel Ray is a salaried Offcer/Owner of the Corporation. His
compensation remains constant from month to month regardless of time
spent working for the Company. No time sheets or logs are maintained. See
response to Request No. 13 referenced above for duties performed. See
response to Request No. 25 below for estimates of time spent working for the
RESPONSE TO THIR PRODUCTION
REQUEST OF COMMISSION STAFF 1 September 5, 2008
Company. Response prepared by Israel Ray, President. Witness, Israel
Ray.
linda Gil is a contract employe of Atlanta Power Co. Her compensation
is constant from month to month. As a contract employee she is paid to
perform the tasks assigned regardless of the time required. No time cards or
logs are maintained. If she were required to maintain and submit time sheets,
she would be considered an hourly employee of the corporation and
applicable taxes would be required including employer paid FICA and
unemployment taxes. An estimate of the time she spends performing her
normal assigned contract duties is approximately 20 hours per month. Her
compensation is biled to Atlanta Power Company on a monthly invoice from
Gil Construction Company. Response prepared by Linda Gil, Customer
Accounting. Witness, linda GilL.
Dave Gil is a contract employee of Atlanta Power Co. His compensation
is constant from month to month. As a contract employee he is paid to
perform the tasks assigned regardless of the time required. No time cards or
logs are maintained. If he were required to maintain and submit time sheets,
he would be considered an hourly employee of the corporation and applicable
taxes would be required including employer paid FICA and unemployment
taxes. An estimate of the time he spends performing his normal assigned
contract duties is approximately 30 hours per month. His compensation is
biled to Atlanta Power Company on a monthly invoice from Gil Construction
Company. When extraordinary repairs and maintenance are required beyond
the normal assigned duties, he bils the Company separately through a
separate itemized charge on the monthly billng from Gil Construction
Company. Estimated annual normal duties time = 360 Hrs. Response
prepared by Dave Gil, Service Man. Witness, Dave Gil.
Request No. 25. If information requested in Production Request No. 24 is
unknown and/or undocumented, please provide an estimate of average hours
RESPONSE TO THIRD PRODUCTION
REQUEST OF COMMISSION STAFF 2 September 5, 2008
worked by each individual for the monthly pay received during 2006, 2007
and 2008.
Reply. Israel Ray spends approximately 300 to 700 hours per year
performing repair and maintenance to the elecric system, line rebuilds,
general clean~up of Atlanta Powets facilities, purchasing and transporting
materials and supplies to Atlanta, paying bils, responding to emergency calls
and responding to customer complaints and concerns.
In 2006, In addition to his normal duties, Israel Ray spent approximately
300 hours over a period of approximately 5 weeks working closely with the
U.S. Environmental Protection Agency performing required clean-up of old
mine tailngs on Atlanta Powets properties including moving and cleaning
stored equipment, hauling and spreading approximately 12" of fill to cover
contaminated soil over approximately 80% of the storage and generator sites.
The Company also constructed fencing around the hydro-generator site.
Much of the work on this fencing project (approximately 150 hours) was
performed in the Ray Brothers Seed Co. shops in Caldwell to construct the
special gates required due to heavy winter snow fall and fabricate a penstock
box cover. No charges for the use of these shop facilities or Israel Ray's
labor were charged to Atlanta Power Company. See also response to
Request No. 36 that follows. 2006 summary: Normal duties = 500 Hrs; EPA
clean~up 300 Hrs; Fabricate gates and penstock box cover 150 Hrs.
Estimated Total 950 Hours.
In 2007, in addition to his normal duties, Israel Ray addresse the problem
of the hydro turbine failure. It is difficult to estimate the hundreds of hours
spent to remove, haul, arrange and coordinate repair of the turbine, obtain
and install a back-up diesel generator, arrange for delivery of diesel fuel,
construct a crane for reinstallation of the turbine and reinstall the turbine.
Israel Ray also had to arrange for financing of the Company's extraordinary
cost. Beginning in 2007, the Federal Energy Regulatory Commission (FERC)
required a fish ladder agreement as part of the FERC license agreement.
Israel Ray spent numerous hours in meetings with various governmental
RESPONSE TO THIR PRODUCTION
REQUEST OF COMMISSION STAFF 3 September 5, 2008
agencies to comply with this requirement. This project is ongoing in 2008.
2007 summary: Normal duties = 500Hrs; Time invested to remove and repair
turbine, acquire install and maintain back-up generator, build crane, reinstall
turbine, acquire financing, 100 hrs/month for 5 months = 500 Hrs; Time spent
to comply with FERC fish ladder agreement 100. Estimated Total 1,100 Hrs.
2008 estimated extraordinary hours through August to file rate case,
attend PUC hearings and workshops and comply with FERC fish ladder
agreement = 360 Hrs. Normal = 500 Hrs. 2008 Estimated Total = 860 Hrs.
To reiterate, in a "normal" year, Israel Ray will spend between 300 and
700 hours performing the "normal" duties and responsibilties required to
operate and maintain Atlanta Power Company. Hours vary considerably by
year depending upon the extent of repair and maintenance required on the
system. The last three years have been quite extraordinary requiring an extra
amount of time for which Israel Ray has received no compensation. Reply
prepared by Israel Ray, President. Witness Israel Ray.
Linda Gil, See Response to No. 24 above.
Dave Gil, See Response to No. 24 above.
Request No. 26. The Company identifed 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 unknown 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 turbine failure during
2007.
Reply. The backhoe hour meter is not operable nor is there a log kept of
hourl use. The backhoe has never left Atlanta since its purchase in 2006.
RESPONSE TO THIR PRODUCTION
REQUEST OF COMMISSION STAFF 4 September 5, 2008
Atlanta Power has used the backhoe for approximately 80 hours on the job
site through the end of 2007. Middle Fork LLC, owner of the propert Atlanta
Power Company rents for its equipment lot and back-up diesel generator has
used the backhoe for approximately 105 hours on the job site over the same
period of time. Reply prepared by Israel Ray, President. Witness Israel Ray.
Request No. 27. The Company identifed a 5 KW portable 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 the
generator was used by Ray Brothers Seed Company. If the information is
unknown 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.
Reply. This generator has been on site in Atlanta since its purchase in 2007.
It has only been used once for a period of approximately 6 to 8 hours during a
power outage in Atlanta. The one use was to provide power for Atlanta
Power Company's President at the motor home located on the Atlanta Power
Company equipment lot while he was making repairs to restore power to the
community. The generator is on hand for use in extreme emergency if both
the hydro and diesel generators should both be out of service at the same
time. Estimated use is impossible to predict. There are no plans to remove
the generator from Atlanta at this time. Response prepared by Israel Ray,
President. Witness, Israel Ray.
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.
RESPONSE TO THIR PRODUCTION
REQUEST OF.COMMISSION STAFF 5 Septembe 5, 2008
Reply. These schedules were prepared with hard input using detail from the
Company's records of expenditures. No formulas exist. An electronic version
would mirror the printed schedules. Response prepared by Robert Smith,
Consultant. Witness, Robert Smith.
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 (parties to the agreement,
rental duration, rental costs, etc.) If the rental is month-to-month, please
identify the planned duration of the rental.
Reply. No rental agreement exists. This is a month-to-month rental that is
intended to continue in perpetuity. It should be noted that the propert owner,
Middle Fork llC, was created by Atlanta Powr Company's owner to protect
Atlanta Power Company from possible liabilit claims resulting from
hazardous mine tailings on the site. Rather than owning the propert outright
and including the cost in Atlanta Power Company's rate base, the llC was
created as a hedge against liabilit claims to protect the utilty company. The
$350 per month rent provides space and a building for the diesel generator
far removed from the Atlanta community, a storage lot and building for spare
parts inventories, tools and equipment and housing for the Company's
president when in Atlanta. Note that the motor home parked on the lot and
used for housing is provided at no cost to the utilty and there are no
motel/hotel facilities available in the communit. Response prepared by Israel
Ray, President. Witness, Israel Ray.
Request No. 30. The Company identifed meal costs at Chuck~a.rama and
the Snake River Mart in response to Production Request No. 22. Please
identify the business purpose of these meals that appear to be in Marsing and
Boise, Idaho.
Reply. Meal charges at Chuck-a-rama are travel expense costs incurred
when traveling between Caldwell and Atlanta for business purposes.
RESPONSE TO THIRD PRODUCTION
REQUEST OF COMMSSION STAFF 6 September 5, 2008
Purchases at the Snake River Mart are for groceries to take to Atlanta for
meals while performing Company related duties for the electric system.
Reply prepared by Israel Ray, President. Witness, Israel Ray.
Request No. 31. The Company identified lodging costs for the Beaver Lodge
in response to Production Request No. 22. Please identif the work that was
performed requiring an overnight stay at the Lodge.
Reply: Round trip travel time to Atlanta from Caldwell is approximately 8
hours. Any time a full day's work is required on the system, an overnight stay
is required. Multiple day projects require multiple overnight stays. As
discussed above in response to Request Nos. 24 and 25, Israel Ray does not
maintain time sheets or log books of work performed. Israel Ray travels to
Atlanta to perform his duties not only as president of the Corporation but to
perform a multitude of repair, rebuild, maintenance and emergency tasks to
maintain the electric system. It is not possible to identify the specific purpose
of each of the visits to the service area two years after the fact. Reply
prepared by Israel Ray, President. Witness, Israel Ray.
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.
Reply. Multiple fuel purchases on the same day reflect several factors. One,
Atlanta Power uses a debit card for fuel purchases. The debit.card is
restricted to a maximum of $75 per transaction. If the vehicle requires more
fuel to fill its tanks, a second transaction is required. Two, often more than
one vehicle travels to Atlanta at the same time to haul parts and materials.
The second vehicle may not fuel at the same location as the first and may
also require two transactions to complete the fuel process. It should be noted
here that these vehicles are privately owned i.e. not owned by Atlanta Power
Company. The only cost incurred by Atlanta Power Company for operation of
these vehicles is the fuel expense for the round trip to Atlanta and return.
RESPONSE TO THIRD PRODUCTION
REQUEST OF COMMISSION STAFF 7 September 5, 2008
Third, there is no fuel available for purchase in Atlanta to fuel the Company's
line trucks and backhoe. Fuel must be hauled to Atlanta in jerry cans. One
line truck uses regular gasoline the other use clear dieseL. The backhoe
uses regular diesel. Therefore multiple transactions are required to fill the
fuel cans from different pumps. Response prepared by Israel Ray, President.
Witness, Israel Ray.
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 tariff schedule.
Reply. No customers have requested disconnection from the system.
Response prepared by linda Gil, Customer Accounting. Witness, Linda Gil.
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.
Reply. Generally all customers have paid their bils on a timely basis. One
new 83 Seasonal Residential Customer has not paid since being connected.
There are 7 83 Seasonal Residential customers that are routinely late but
eventually always pay their electric bil. Response prepared by linda Gil,
Customer Accounting. Witness, Linda Gil.
Request No. 36. The Company identifed 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.
Reply. The U.S. Forest Service required these improvements. The costs
included fencing, adjustable main gates to allow access in deep snow, a
penstock box cover made of 2" pipe welded on 6" centers, bars on the
windows of the turbine building, a building for the compressor, a gate system
cemented to the ground at the penstock box, a 15' wide chain link barrier/gate
RESPONSE TO THIRD PRODUCTION
REQUEST OF COMMISSION STAFF 8 September 5, 2008
to prevent entry to the penstock area and 2 6' by 10' chain link panels and
concrete imbedded support posts to prevent accss to the Company's 250'
long penstock pipe. Note, not included in the expenditures shown in
response to Request No. 20 is labor of approximately 150 hours by Israel Ray
to fabricate the main gate adjustable entrance structure and the penstock box
cover in the Ray Brothers Seed Company shop in Caldwell using the tools
and equipment of Ray Brothers Seed Company. Response prepared by
Israel Ray, President. Witness, Israel Ray.
Request No. 37. The Company updated its rate case costs estimate in filng
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 task performed, and the rates per hour. To the extent
not already provided, please include within your response documentation of
all rate case costs incurred to date.
Reply. Enclosed is a schedule of charges by date. Enclosed behind that
schedule are copies of all billng statements through September 2, 2008 from
Robert E. Smith to Atlanta Power Company that provide the detail requested.
rí(
Respectully submitted this ~ ,, day of September 2008.
RESPONSE TO THIR PRODUCTION
REQUEST OF COMMISSION STAFF 9 September 5, 2008
Date
09/25/07
10/03/07
10/22/07
11/16/07
11/25/07
12/02/07
12/07/07
01/18/08
02/01/08
02/04/08
02/05/08
02/11/08
03/03/08
03/09/08
03/10/08
03/20/08
03/24/08
03/25/08
04/02/08
04/03/08
04/07/08
04/11/07
04/14/08
04/19/08
04/21/08
04/22/08
04/23/08
04/24/08
04/27/08
04/30/08
04/30/08
05/01/08
OS/27/08
05/31/08
06/05/08
06/06/08
06/08/08
06/09/08
06/10/08
06/12/08
06/27/08
06/30/08
07/02/08
07/10/08
Amount
255.00
170.00
69.49
212.50
340.00
212.50
170.00
340.00
42.50
85.00
11.58
212.50
15.10
510.00
552.50
425.00
425.00
552.50
27.97
340.00
297.50
382.50
382.50
297.50
340.00
510.00
382.50
170.00
170.00
425.00
29.37
170.00
170.00
85.27
170.00
340.00
510.00
170.00
255.00
170.00
127.50
85.00
61.65
212.50
Atlanta Power Company
Schedule of Rate Case Costs by Date
Date Amount Balance
07/21/08 170.00 11,052.93
07/24/08 255.00 11,307.93
07/25/08 85.00 11,392.93
07/30/08 85.00 11;477.93
07/31/08 382.50 11,860.43
08/01/08 89.99 11,950.42
08/01/08 212.50 12,162.92
08/05/08 297.50 12;460.42
08/06/08 340.00 12,800.42
08/07/08 382.50 13,182.92
08/08/08 212.50 13,395.42
08/11/08 212.50 13,607.92
08/15/08 170.00 13,777.92
08/18/08 255.00 14,032.92
08/20/08 212.50 14,245.42
09/02/08 79.19 14,324.61 Interest
09/03/08 382.50 14,707.11 Staff 3rd Request
09/04/08 297.50 15,004.61 Staff 3rd Request
09/05/07 170.00 15,174.61 Staff 3rd Request
9/5/2008 ??? Copy expense Staff 3rd Request
Future? Depends on need to file reply
to Staff and/or intervenors. Attend
public hearing?? Meet with staff &
intervenor??? File new tariffs, etc.
Balance
255.00
425.00
494.49
706.99
1,046.99
1,259.49
1;429.49
1,769.49
1,811.99
1,896.99
1,908.57
2,121.07
2,136.17
2,646.17
3,198.67
3,623.67
4,048.67
4,601.17
4,629.14
4,969.14
5,266.64
5,649.14
6,031.64
6,329.14
6,669.14
7,179.14
7;561.64
7,731.64
7,901.64
8,326.64
8,356.01
8,526.01
8,696.01
8,781.28
8,951.28
9,291.28
9,801.28
9,971.28
10,226.28
10,396.28
10,523.78
10,60.78
10,670.43
10,882.93
Robert E. Smith
Utility Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
Date Description
6/25/2007 Met with lsrael Ray and Anna Ray re financial
data needs to complete annual reports
7/11/2007 Met with Anna Ray to find error in beginning balance
of Quick Books and reconcile to 1/31/06 bank stmnt.
Contacted PUC and got coy of last Staff Audit Rpt.
7/1212007 e-mail frm Anna Ray re 2006 check register and
accunt spread. Sent reply.
7/26/2007 Call from Israel Ray re Deferred Accunting Order.
7/27/2007 Met with Anna Ray re 2004 and 2005 financial data.
Recived e-mail from Anna Ray with attchments ie
2004 and 2005 data. 2005 missing. Placed call to
Anna Ray and left message re missing 2005 data.
7/29/2007 Drafted Application and coer letter re Deferred
Accounting Order.
Balance Due:
Thank You
$ 616.25
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
August 1, 2007
Hours Amount Accumulated
Biled ~$85/Hr.Amount
2.5 212.50 $212.50
1.25 106.25 318.75
0.25 21.25 340.00
0.25 21.25 361.25
1 85.00 446.25
2 170.00 616.25
[phone]
Cell [phone]
uniltygroup~yahoo.com
Robert E. Smith
Utilty Consultant
Biling Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
Date Description
Balance Forwrd fron August 1, 2007 Statement
8/8/2007 Began analysis of 04 ~ 06 data for preparation of
PUC Annual Reports
8/14/2007 Met with Israel Ray and Anna Ray re questions on
data classifications
8/24/2007 Picked up bank statements for 2004 from U.S. Bank.
ann began reclassification of 2004 data.
8/27/2007 Picked up additional data frm Dale Watts (Trial Bal
for 03). Called D. Brush and got additional data ie
partial trial balance for 04, AIR and GIL. Cobined all
data from from all sources into a preliminary 2004
trial baance.
8/2812004 Developed new depreciation schedule, finished recon-
ciliation of of 2004 data. Began reclassification of
2005 data to proper accounts.
8/29/2004 Finished 2005 and began recassification of 2006 data
to proper accunts
813012004 Finished distribution of 200 dat. Prepared AIR
entries and adjustment for 200 -2006 and produced
year-end trial balance and financial statements for
2004 - 2006
8/31/2004 Transferred all data to PUC Annual Report Forms.
Balance Due:
Thank You
$ 4,016.25
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
Hours
Biled
3 $
2
3
7.5
6
4
8
6.5
September 4, 2007
Amount
Cë $85/Hr.
Accumulated
Amount
$ 616.25
255.00 $ 871.25
1701,041.25
255.00 1,296.25
637.50 1,933.75
510 2,443.75
340 2,783.75
680 3,463.75
552.5 4,016.25
(208) 322-294
Cell [phone]
uniltygroup~yahoo.com
Robert E. Smith
Utilty Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell. Idaho 83607 Statement Date:
Date
HoursDescnption Biled
Balance Forwrd from September 4, 2007 Staement
9/4/2007 Met with Israel Ray re review PUC Annual Reports.
91712007 Took 2004,05 & 06 Tnal Balances, Balance Sheets
and Income Statements to Dale Watts for taxes.
Phone Wllsrael Ray re financial poition of Company
and PUC application options.
9/25/2007 Reviewed invoices and checks for inclusion in
Deferred Costs Account. Met with Israel Ray and
Anna Ray re above. Phone with Dale Watts re
accunting for contnbution from Atlanta Gold.
Balance Due:
Thank You
$ 4,483.75
Robert E. Smith
2209 N. Bryson Rd
Boise, fdaho 83713
October 1, 2007
Amount
Cf $85/Hr.
0.75 N/C
2.5 212.50
3 255.00
Accumulated
Amount
$ 4,016.25
$ 4,016.25
4,228.75
4,483.75
(208) 322-294
Cell [phone]
uniltygroupCfyahoo.com
Robert E. Smith
Utility Consultant
PAST DUE STATEMENT
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
Date Description
Past Due From 8/1/07 Statement
One Month Interest (e 18% APR
Past Due From 9/04/07 Statement
One Month Interest (e 18% APR
Past Due From Oct 1, 07 Biling
Balance Due:
Thank You
$ 4,553.24
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
$ 616.25
$4,016.25
4,483.75
October 22, 2007
Interest TotalDue Due
$ 9.24 $ 9.24
60.24 60.24
4,483.75
4,553.24
[phone]
Cell [phone]
uniltygroup(eyahoo.com
Robert E. Smith
Utility Consultant
Biling Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
HoursDate Description Biled
Balance Due From October 22, 2007 Statement
For Services through September 31,2007 plus interest
10/3/2007 Meeting with PUC Staff & Phone with Israel
Ray re filing requirements.
111712007 Pmnt Received, Thank You
11/1612007 Met with Israel Ray re info for surcharge Application
and General Rate Case.
1112512007 Updated Loan and Expendature data.
12/212007 Prepared Draf Exhibit for Surcharge and Loan Appl.
1217/2007 Met with Israel Ray and Dale Watt to review Draft
Exhibits and determine Amounts to Capitalize.
Balance Due:
Thank You
$ 1,158.24
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
January 5, 2008
Balance
Charge Due
$4,553.24
2 $170.00 $4,723.24
(4,500.00)223.24
2.5 212.50 435.74
4 340.00 775.74
2.5 212.50 988.24
2 170.00 1,158.24
[phone]
Cell [phone]
unilitygroup~yahoo.com
Robert E. Smith
Utilty Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
HoursDate Desciptin Biled
1/5/2008 Past Due Balance Due From January 5,2008 Statement
For Services through December 31,2007
1/1812008 Completed Draft Application for Debt and Faxed to Co.
2/512008 Interest on Past Due Account ~ 12% APR
Balance Due:
Thank You
$ 1,509.82
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
February 5, 2008
Charge
Balance
Due
$ 1,158.24
4 $ 340.00 $ 1,498.24
$ 11.58 $ 1,509.82
[phone]
Cell [phone]
uniltygroup~yahoo.com
Robert E. Smith
Utility Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell. Idaho 8307 Statement Date:March 3, 2008
Hours Balance
Date Description Biled Charge Due
Past Due Balance From February 5, 2008 Statement
For Services through January 31, 2008 & Interest on Past Due Acct.$1,509.82
211/2008 Phone WI Israel Ray & Phone WI P. Harms (PUC)0.5 $42.50 $1,552.32
21412008 Phone WI Israel Ray. Phone WI P. Harms (PUC) and
draft extension letter to PUC 1 $85.00 $1,637.32
2/11/2008 Meet (s PUC WI Staff, Israel Ray and Anna Ray to
determine lok box terms for loan.2.5 212.50 1,849.82
3/3/2008 Interest on Past Due Acunt (s 12% APR $15.10 $1,864.92
Balance Due:
Thank You
$ 1,864.92
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
[phone]
Ceil [phone]
uniltygroup(syahoo.com
Hours
Description Billed Charee
Past Due Balance From March 3,2008 Statement
For Services through February 29, 2008 & Interest on Past Due Acct.
Robert E. Smith
Utilty Consultant
Biling Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
Date
3/9/2008 Began Clean-up of Raw customer Accunts Data
provided by Ken Henderso to isolate biling
information
3/10/2008 Finished clean-up of biling infor and built model for
bil frquency and rate design analysis. Identified
numerous problem ares. Phoned Israel Ray for
clairification.
3/2012008 Met with linda Gil to clarify biling data and correct
problem ares.
3/24/2008 Corrected model input data for corrections in raw
biling data
312512008 Organized and built Exhibits for rate case and surcharge
Application.
Interest due on Past Due Acct ~ 1 SOk per annum
90 Oays Past Due
60 Days Past Due
30 Oays Past Due
Current
Balance Due:
Thank You
$ 4,357.89
Robert E. Smith
2209 N. Bryon Rd
Boise, Idaho 83713
April2,2008
Balance
Due
$ 1,864.92
6 $510.00 $ 2,374.92
6.5 552.50 2,927.42
5 $425.00 $3,352.42
5 425.00 3,n7.42
6.5 552.50 4,329.92
27.97 4,357.89
$1,158.24
$351.58
$355.10
$2,492.97
$4,357.89
[phone]
Cell [phone]
uniltygroup~yahoo.com
Robert E. Smith
Utilty Consultant
Biling Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
HoursDate Description Biled
Balance From April 2, 2008 Statement
For Services through March 31, 2008 & Interest on Past Due Acc.
4/312008 Continued with Exhibits, Discovered eromeous dat
in Company Notes Payable Data, Contacted Co. for
data to fix Note Payable errors
41712008 Got info from Israel Ray and PUC on Problem with
Notes Payable and calculated correcions for cost of
capitol exhibit.
4111/2008 Completed Exhibts and Bil Frequency for Analysis of
Rates.
4/1412008 Payment Recived, Thank You!
4/14/2008 Met WI Israel Ray to review exhibits for rate case and
disuss rae design. Sent e-mnail to L. Gil with rate
design Exce rate design worksheet atched.
4/1912008 Recalculated Rates per Israel Ray and L. Gil. Began
drafting Application.
412112008 Again reclculated rates Per Israel Ray phone caion
4/19. Went back over Applicaion to make changes for
rate design and continued Application text.
4/2212008 Continued Application, Corrected Exhibits for changes,
checked for errors, prepared current tariff exhibits to
show proposed changes.
412312008 Completed Application, draed noice & new release,
fine tuned and printed exhibits, Application, notice and
cover letter.
4/2412008 Met WI Israel Ray to go over Application & Exhibits. Co.
wants to make changes.
4/27/2008 Made changes per Co. request. Phone call to Israel Ray
for additional info. left message
4/3012008 Reised all Exhibits, Appliction and notice to recnizee
changes Co. requested. Printed package to be filed.
512008 Interest on Past Due Balance ~ 18% per annum
Past Due 30 Days
Current
Balance Due:
Thank You
$
1,957.89
3,726.87
5,68.76
Robrt E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
May 2, 2008
Balance
Charge Due
$4,357.89
4 $340.00 $4,697.89
3.5 297.5 $4,995.39
4.5 382.50 5,377.89
(2,400.00)2,977.89
4.5 382.50 3,360.39
3.5 297.50 3,657.89
4 340 3,997.89
6 510 4,507.89
4.5 382.5 4,890.39
2 170 5,060.39
2 170 5,230.39
5 425 5,655.39
$29.37 $5,684.76
(208) 322-294
Cell [phone]
unilitygroup~yahoo.com
Robert E. Smith
Utilty Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
HoursDate Description Bìled
Balance Fro May 2, 2008 Statement
For Services through April 30, 2008 & Interest on Past Due Acc.
51112008 Met with Israel Ray to sign Applicion and Tariffs, get
copies made, file with PUC and sent news releases
512712008 Idaho Public Utilities Commission Decision Meeing
and met with Staf re surcharge and rate design
Interest on Past Due Account Balances
Past Due 30 Days
Pasr Due 60 Days
Currnt
Balance Due:
Thank You
$
3,726.87
1957.89
425.27
6,110.03
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
June 2, 2008
Balance
Charge Due
$5,684.76
2 $170.00 $5,854.76
2 $170.00 $6,024.76
85.27 6,110.03
[phone]
Cell [phone]
uniltygroup(yahoo.com
Robert E. Smith
Utilty Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Roa
Caldwell, Idaho 83607 Statement Date:
HoursDate Description Biled
Balance From June 2, 2008 Statement
For Services through May 31, 2008 & Interest on Past Due Acc.
6/5/2008 Reviewed PUC Staff Comments, sent fax Copy to Israel Ray
61/2008 Recaculated Staff prosal, contcted Staff for Work paper
recived partial explanation (not complete)
6/812008 Used Staff partial info to replicae Staff calculation, drafted
reply comments and faxed to Israel Ray
61912008 Recived adell Info from Staf. Errors found requiring re-
calculation to correc
6110/2008 Recalculated surcharge requiremnts and redrafed rely
to Staff. Faxed to Isral Ray
6/1112008 Met with Israel to sign and file reply comments
6111/2008 Payment Received. Thank You!
6/12/2003 Public Hearing at PUC
6/27/2008 Reviewed Order #30578 and prepared Tariff in Compliance
6/301008 Met with Israel Ray re Tariff to be filed
7/2/2008 Interest on Past Due Balance
June Statement $6,110.03 less Pmnt $2,000 = 4,110.03 l§ 1.5%
Past Due 30 Days
Pasr Due 60 Days
Current
Balance Due:
Thank You
$
425.27
36.76
1,889.15
6,99.18
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
July 2, 2008
Balance
Charge Due
$6,110.03
2 170.00 $6,280.03
4 340.00 $6,620.03
6 510.00 $7,130.03
2 170.00 $7,300.03
3 255.00 $7,555.03
1 N/C $7,555.03
-2000.00 $5,555.03
2 170.00 $5,725.03
1.5 127.50 $5,852.53
1 85.00 $5,937.53
61.65 $5,999.18
(208) 322-294
Cell [phone]
uniltygroupl§yahoo.com
Robert E. Smith
Utilty Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Road
Caldwell, Idaho 83607 Statement Date:
HoursDat Desription Bille
Balance From July 2,2008 Statement
For Services through June 30, 2008 & Interest on Past Due Acct.
7/10/2008 Reviewed Staf 1st Production Request, Phoned and Faxed
coy to Linda Gil
712112008 Phone with Linda Gill for clarifcation on responses to Staff
1 st Prod. Req. Began draing response documents
7/2412008 Finished drafting response to Staff 1st Prod Req.
712512008 Faxed resose document to Israel Ray and phone instruions
on filing respose on parties and Commission
7/3012008 Phone with PUC Staf ie case timing and customer sample
bils not attached to response to Prod Req #1. Faxed
sample customer bils to PUC and to intervenor J. Miler
7/31/2008 Met with Israel and Anna Ray re Staff 2nd production request
Discussed Amendment to rate design proposal. Drafed an
Amended Applicaion and Exhibit to be filed with PUC
71212008 Interest on Past Due Balance
July Statement 5999.18 * 1.5%
Currnt
Past Due 30 Days
Pasr Due 60 Days
Past Due 90 DaysBalance Due: $
Thank You
1,279.99
1,889.15
425.27
368.76
7,279.17
Robert E. Smith
2209 N. Bryson Rd
Boise, Idaho 83713
August 1, 2008
Balanc
Charge Due
$5,999.18
2.5 212.50 $6,211.68
2 170.00 $6,381.68
3 255.00 $6,636.68
1 85.00 $6,721.68
1 85.00 $ 6,806.68
4.5 382.50 $ 7,189.18
89.99 $ 7,279.17
(208) 322-294
Cell [phone]
uniltygroup~yahoo.com
Robert E. Smith
Utilty Consultant
Billng Statement
Atlanta Power Co.
11140 Chicken Dinner Roa
Caldwell, Idaho 83607 Statement Date:
Date
HoursDecription Biled
Balance From August 1, 2008 Statement
For Services through July 31, 2008 & Interest on Past Due Acct.
8/112008 Prepared response to Staff 2nd production request
question No. 20
815/2008 Bean drafng reonse to Staff 2nd production request.
Called and left messages w/lsrael Ray and Dale Watt.
8/61008 Put together schedules to answer Staf production request NO.2
Continued drafting reply
8ll12oo8 Traveled to Dale Watt offce to get tax return. Numerous phone
and fax with Israel Ray and Insurance Companies. Continued
gathering info and drafting response to Sta request NO.2.
8/812008 Finalized responsde to Staf requet NO.2. Met with Israel
Ray and copied for filing.
8/8/2008 Payment received. Thank You.
8111/2008 Filed response with PUC and delivered to intervenor. Researched
rate history for response to intervenor discvery request.
8/1512008 Put together rate history schedule for reply to intervenor discvery
request.
8/18/2008 Finished reply to intervenor discovery request.
812012008 Met wI Israel Ray to sign reply, copy and file with PUC and
Intervenor. Met WI PUC Staff, received 3rd Staf request.
912/2008 Interest on Past Due Balance
August Statement 7279.17 less $2,000 * 1.5%
Current
Past Due 30 Days
Pasr Due 60 Days
Past Due 90 DaysBalance Due: $
Thank You
Robert E. Smith
2,374.19
1,279.99
1,889.15
2,110.03
7,653.36
2209 N. Bryon Rd
Boise, Idaho 83713
Sepember 2, 2008
Charge
Balance
Due
$ 7,279.17
2.5 212.50 $ 7,491.67
3.5 297.50 $ 7,789.17
4 340.00 $ 8,129.17
4.5 382.50 $8,511.67
2.5 212.50 $8,724.17
(2,000.00) $6,724.17
2.5 212.50 $6,936.67
2 170.00 $7,106.67
3 255 $7,361.67
2.5 212.5 $7,574.17
79.19 $7,653.36
(208) 322.294
Cell [phone]
unilitygroup~yahoo.com
CERTIFICATE OF SERVICE
t;)r!/-
I HEREBY CERTIFY THAT I HAVE THIS .5 DAY OF SEPTEMBER, 2008,
SERVED THE FOREGOING REPLY TO PUC STAFF THIRD PRODUCTION
REQUEST, IN CASE NO. ATL-E-08-2, BY HAND DELIVERY THEREOF TO THE
FOLLOWING:
scon WOODBURY
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720-0074
BOISE, IDAHO 83720
31
DEAN J. MILLER Si l2 ~
MCDEVln & MILLER LLP ~ !. .~
PO BOX 2564 00. In rn
BOISE, IDAHO 83701 ~ ~ ~erO-- ~i; ~gi f!~ ~