20220808Staff 1-11 to Atlanta.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO,83720-0074
[phone]
IDAHO BAR NO. 98IO
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF ATLANTA POWER COMPANY SERVICE
AND CUSTOMER RELATIONS
CASE NO. ATL-8.22.0I
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ATLANTA POWER
COMPANY
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its attorney of
record, Chris Burdin, Deputy Attorney General, requests that Atlanta Power Company
("Company" or "Atlanta Power") provide the following documents and information as soon as
possible, but no later than MONDAY, AUGUST 15,2022.r
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 or information produced.
I Stuff i, requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ATLANTA POWER
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AUGUST 8,2022
REQUEST NO. l,: 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.
REQUEST NO. 2: Please provide the invoices, packing slips, Bill of Ladings etc. for all
items purchased for repairs, new construction, or replacements from 2017 to present.
REQUEST NO.3: Please provide a schedule showing each customer's usage and billing
for each month from 2017 to present. Please include the dollar amounts billed as well as the kWh
billed.
REQUEST NO.4: Please provide an accounts receivable aging report for December 31,
2020, December 31,2021, and July 30,2022.
REQUEST NO. 5: Please provide a complete description of the Company's current
system. 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.g., 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.
REQUEST NO. 6: Please provide a scaled system map of the utility. This map should
provide a location and reference identifuing 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., 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);
FIRST PRODUCTION REQUEST
TO ATLANTA POWER 2 AUGUST 8,2022
REQUEST NO. 7: Please provide a list of all utility assets (with documentation)
identi$ing the following for each:
a. Asset identifier (Serial number, Asset inventory number, etc.);
b. Whether it is installed or held in inventory;
c. Condition ofthe 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.
REQUEST NO. 8: Please identiff and describe any deficiencies and what action, if any,
is needed to address system reliability, system integrity, and/or support potential growth. For each
deficiency, please provide the following:
a. Improvements and/or investments the Company plans to implement to address each
individual deficiency.
b. Please include the costs and benefits for each investment
REQUEST NO. 9: Please identifi and describe all maintenance improvement projects to
the utility plant over the past 5-years. Please include documentation for each project.
REQUEST NO. 10: Please provide the past 5-years of monthly energy use for all meters
located at 170 Middle Fork Rd., Atlanta, Idaho 83716.
REQUEST NO. 11: Please provide the Company's 5-year plan for the purchase and
installation of future utility plant assets.
FIRST PRODUCTION REQUEST
TO ATLANTA POWER 3 AUGUST 8,2022
DATED at Boise,Idaho, ttris (11 day of August2022.
a*ul t
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/afle22. lcbksk prod req I
FIRST PRODUCTION REQUEST
TO ATLANTA POWER 4 AUGUST 8,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY oF AUGUST 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO ATLAI\ITA POWER COMPANY, IN CASE NO.
ATL.E.L2.OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ISRAEL RAY
ATLANTA POWER COMPANY
508 AUKLET PLACE
FAIRBANKS AK 99709
E-MAIL: israelray I [e-mail]
GENE HAUGHT
235 WEST YUBA DRIVE
ATLANTA,ID 83716
E-MAIL: pgfd247 @yahoo.com
CHRISTOPHER R NUNEZ
McANANEY & ASSOCIATES
IIOI RTVERSTSTE IOO
BOISE ID 83702
E-MAIL: [e-mail]
-h,/LA,-r,SECRET&-Y//
CERTIFICATE OF SERVICE