20220815Atlanta to Staff 1-11.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. lTth St.
Boise, ID. 83702
(208) 384-t2e9
FAX: [phone]sl I
[e-mail]
Attorney for Atlanta Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF THE IIYVESTIGATION OF )
ATLANTA POWER COMPAI{Y SERVICE
AND CUSTOMER RELATIONS
CASE NO. ATL-E,-22.0I
RESPONSE TO FIRST
PRODUCTION REQUESTS
OF COMMISSION STAFF
The Atlanta Power Company hereby responds to Staff s First Production Requests dated
August 8,2022 in the above-captioned matter.
REQUEST NO. 1: Please provide all income tax filings for Atlanta Power from 2017 to
present. This may include copies of the Schedule C, Form 1065, or other filings etc.
RESPONSE TO REQUEST NO. 1: Atlanta Power does not currently have the data
sought by this request. Pursuant to Rule 225(3) of the Commission's Rules of Procedure
(IDAPA, 31.01.01 .225), Atlanta Power has twenty-one (21) days from the date of Staff s
production request in which to respond. That said, and consistent with discussions between the
undersigned and Staff s legal counsel, Atlanta Power will endeavor to provide responses to
Staff s foregoing production request as soon as the information can be obtained and, in any
event, consistent with Rule 225.
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1ATLANTA POWER RESPONSE TO STAFF PRODCTION REQUESTS
REQUEST NO. 2: Please provide the invoices, packing slips, Bill of Ladings etc. for all
ite'nrs purchased for repairs, new construction, or replacements from 2017 to present.
RESPONSE TO REQUEST NO.2: See Response to Request No. l.
REQUEST NO. 3: Please provide a schedule showing each customer's usage and billing
for each month from20l7 to present. Please include the dollar amounts billed as well as the kWh
billed.
RESPONSE TO REQUEST NO.3: See Response to RequestNo. l.
REQUEST NO.4: Please provide an accounts receivable a$ng report for December 31,
2020, December 31,2021, and Ju1y30,2022.
RESPONSE TO REQUEST NO.4: See Response to RequestNo. 1.
REQUEST NO.5: Please provide a complete description of the Company's current
systern. This should include the following: a. A description of each generation resource including
the generation type, type of controls, how it is operated and maintained, amount of average
capacity for each season, and constraints and/or deficiencies (e.9., seasonal water flow, planned
maintenance, fuel capacity and availability, etc.); b. A description of the distribution system
including substations, poles, and conductors, switching mechanisms, how it is operated and
maintained, constraints and/or deficiencies; c. Types and number of customers including a
description of the customer classes, their average usage, seasonal usage patterns.
RESPONSE TO REQUEST NO. 5: See Response to Request No. l.
REQUEST NO. 6: Please provide a scaled system map of the utility. This map should
provide a location and reference identiffing each component of the system. For each component,
please provide a detailed description that includes the following: a. Generating resources (i.e.,
generation type, nameplate capacity rating, installation date, and condition); b. Utility poles (i.e.,
2ATLANTA POWER RESPONSE TO STAFF PRODCTION REQUESTS
type, installation date, and condition); c. Utility transformers (i.e., type, ratings, installation date,
and condition); d. Wire conductor (i.e., type, rating, installation date, and condition); e. Service
connections (i.e., type, rating, installation date, and condition);
RESPONSE TO REQUEST NO. 6: See Response to Request No. 1.
REQUEST NO. 7: Please provide a list of all utility assets (with documentation)
identifring the following for each: a. Asset identifier (Serial number, Asset inventory number,
etc.); b. Whether it is installed or held in inventory; c. Condition of the asset (unused/new or
used/reconditioned, operational or salvage, etc.); d. Date of purchase; e. Date of installation; f.
Original cost with installation cost broken out separately; g. Current book value; h. Depreciation
rate.
RESPONSE TO REQTIEST NO. 7: See Response to Request No. l.
REQUEST NO.8: Please identiff and describe any deficiencies and what action, if any,
is needed to address systern reliability, system integrity, and/or support potential growth. For
each deficiency, please provide the following: a. Improvements and/or investments the Company
plans to implernent to address each individual deficiency. b. Please include the costs and benefits
for each investment.
RESPONSE TO REQUEST NO.8: See Response to RequestNo. 1.
REQUEST NO.9: Please identi$ and describe all maintenance improvement projects to
the utility plant over the past 5-years. Please include documentation for each project.
REQUESTNO. 10: Please provide the past 5-years ofmonthly energy use for all meters located
atl70 Middle Fork Rd., Atlanta, Idaho 83716.
RESPONSE TO REQUEST NO.9: See Response to Request No. 1.
JATLANTA POWER RESPONSE TO STAFF PRODCTION REQUESTS
REQUEST NO. 10: Please provide the past S-years of monthly energy use for all
meters located atl70 Middle Fork Rd., Atlanta Idaho 83716.
RESPONSE TO REQUEST NO. 10: See Response to Request No. 1.
REQUEST NO. 11: Please provide the Company's S-year plan for the purchase and
installation of future utility plant assets.
RESPONSE TO REQIIEST NO. 11: See Response to Request No. l.
DATED, this 15th day of August,2022.
lsl
Brad M. Purdy
4ATLANTA POWER RESPONSE TO STAFF PRODCTION REQUESTS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE ON THIS l5th DAY OF AUGUST,2OZZ,
SERVED THE FOREGOING RESPONSE TO STAFF'S FIRST PRODUCTION REQUEST IN
CASE NO. ATL.E-22.01BY HAND-DELMERING, EMAILING, AND/OR FAXING A
COPY THEREOF TO THE FOLLOWING:
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
[e-mail]. sov
CHRIS NUNEZ
McAnaney & Associates
[e-mail]
lsl
Brad M. Purdy
5ATLANTA POWER RESPONSE TO STAFF PRODCTION REQUESTS