20080905ATL to Staff 33.pdf

Sep 05 08 01 :02p Robert Smith [phone] p.2
ROBERT E. SMIT
UTILITY CONSULTANT
22()9 N. BRYSON RD.
BOISE, IDAHO 83713
RECEIVED
2ISEP -5 PH I: 06
IOAHOPUBUC
UTILITIES COMMISSION
September 5, 2008
Ida Public Utilities Commssion
P.O. Box 82720
Boise, Idaho 83720-0074
A TL-E-08-02
A TIENTION COMMSSION SECRETARY AND HEAD LEGAL SECRET.ARY
Enclosed is Atlanta Power Company's supplementa reply to the Third Production
Request of the Commssion Sta to Atlanta Power Company together with a Certificate
of Service.
E:~
Robert E. Smith,
Consultat to Atlta Power Co.
Sep 05 08 01 :02p Robert Smith [phone] p.3
Robert E. Smith
2209 N. Bryn Rd.
Boise, Idaho 83713
TeL. [phone]
Fax [phone]
Consultant for Atlanta Power Company, Inc.
RECEIVED
2. SEP -5Pl1 :06
iDAHO PUBLIC
UTJLlTlES COMMJSSlON
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
SUPPLEMENTAL
REPLY TO
PUC STAFF THIRD
PRODUCTION REQUEST
COMES NOW Atlanta Power Company Inc., ("Atlanta Powet'. "Applicant"
or "Company") and hereby files the following supplemental reply to the third
production request of the Idaho Public Utilities Commission Staff (Sta.
After filing Applicants reply to the Staffs third production reques, it was
discovered that Applicant inadvertently skipped Staffs Request No. 33. The
following is the response that should have been included in the earlier reply.
Applicant apologizes to th partes in this case for any inconvenience this
omission may have caused.
I, Robert Smith, am filing this supplemental reply on behalf of Atlanta
Power Company due to the absence of Mr. Israel Ray, President of Atlanta
poweeD.
Request No. 33. The Company identified fuel expenses in response to
Production Reques No. 22. Please identify the business purpose of each trip
associated with these fuel purchases.
RESPONSE TO THIR PRODUCTION
REQUEST OF COMMISSION STAFF 1 September 5,2008
Sep 05 08 01 :03p Robert Smith [phone] pA
Reply. As indicated in our reply to Request No. 24, no time shes or logs are
maintained that would help identify the specific purpose of each trp. As
indicated in our reply to Request No. 25, in addition to Israel Ray's "normal"
(repair and maintenance to the electc system, line rebuilds, general clean-up of
Atlanta Power's facilities, purchasing and transporting materials and supplies to
Atlanta, paying bills, responding to emergency calls and responding to customer
complaints and concerns) duties in 2006, the Company transported and installed
fencing and gates reuired by the United Stats Forest Service and spent
numerous hours working closely wit the U.S. Environmental Protection Agency
performing required clean-up of old mine tailngs on Atlanta Power's properties.
These activitíes required numerous trips to Atlanta throughout the year.
'74 __..~.Respectfully submitted this.5 day of September 2008.
1?Ær~-
Robert E. Smit, Consultant to
Atlanta Power Company
RESPONSE TO THIR PRODUCTION
REQUEST OF COMi\1ISSION STAFF 2 September 5, 2008
Sep 05 08 01 :03p Robert Smith [phone] p.5
CERTIFICATE OF SERVICE
1"-7l HEREBY CERTIFY THAT I HAVE THIS S -DAY OF SEPTEMBER, 2008,
SERVED THE FOREGOING SUPPLEMENTAL REPLY TO PUC STAfF THIRDPRODUCTION REQUEST, IN CASE NO. ATL-Ew08-2, BY FAXCIMIL Y
TRANSMISSION THEREEOF TO THE FOLLOWING:
SCOTT WOODBURY
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720-074
BOISE, IDAHO 83720
DEAN J. MILLER
MCDEVITT & MILLER lLP
PO BOX 2564
BOISE, IDAHO 83701
~
Robert E. Smith, Consultnt to
Atlanta Power Co. Inc.