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Home My WebLink About200309191st Request of Staff to Idaho Power.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 ~ ; "r- . C. \.1 r.. ~ :-\LLD . J 1003 SEP \ 9 M'i 8: 50 ,,- u UTIL IES cci.ii';lSSION Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION KIMBALL PROPERTIES LIMITED PARTNERSHIP, AND HEWLETT PACKARD CASE NO. IPC-OO- COMPANY COMPLAINANTS FIRST PRODUCTION REQUEST OF THE vs.COMMISSION STAFF TO IDAHO POWER IDAHO POWER COMPANY COMPANY RESPONDENT. The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company; IPC) provide the following documents and information on or before FRIDAY OCTOBER 10, 2003. This Production Request is to be considered as continuing, and Idaho Power Company 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. FIRST PRODUCTION REQUEST TO IDAHO POWER SEPTEMBER 19 2003 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 hearing. Request No.1: For each of the four HP/Kimball Properties buildings that are the subject of this complaint, please state whether each building is metered and billed separately. Are the meter readings for any ofthe buildings consolidated onto a single bill? Request No.2: Please list all other buildings or customers served by the Bethel Court substation that are billed under Schedule 19. For each customer, list the voltage at which the customer takes service. Request No.3: Does Idaho Power own any facilities on the HP/Kimball side(s) of the meter(s)? If so, describe the facilities. Does HP/Kimball pay any facilities charges? If so please list the amounts of facilities charges paid and describe the facilities for which they are paid. Request No.4: For each of the HP/Kimball Properties buildings, identify the rate schedule under which each is billed, and whether the service is at transmission, primary or secondary voltage. Request No.5: If any of the HP/Kimball Properties buildings are Schedule 19 primary or secondary customers, identify the amount built into any component of the rate for substations, based on the cost of service study used in establishing the rate. Request No.6: Does Idaho Power believe HP/Kimball is paying for a portion of transmission and distribution substations through its rates? If so , please explain why Idaho Power believes it is justified in requesting payment for HP/Kimball's share of the Bethel Court substation. Request No.7: Please list the amounts and the accounts to which all of the construction costs of the Bethel Court substation have been booked. FIRST PRODUCTION REQUEST TO IDAHO POWER SEPTEMBER 19 , 2003 Request No.8: What criteria are used to determine which costs are booked to substation transmission account 353 and which costs to distribution substation account 362? Is there a point of demarcation within a substation at which equipment on one side is transmission and equipment on the other side is distribution? Request No.9: Please identify all other Schedule 19 customers in the past 20 years who have been required to make a contribution to the cost of a substation that is not beyond the point of delivery and is not owned by the customer. For each customer, identify the amount contributed, the date of the contribution, the name of the substation involved, the total cost of the substation and the voltage level at which the customer takes service. Request No. 10: Please list all contributions in aid of construction by year for each of the past 20 years that have been booked to a substation-related account. Req uest No. 11: Please identify all Schedule 19 customers in the past 20 years from whom a contribution to the cost of a substation was requested, but from whom a contribution was never collected or paid. For each instance, assuming service was provided, please include the reason for nonpayment or noncollection. DATED at Boise, Idaho , this /tg71.day of September 2003. teA Scott Woodbury Deputy Attorney General Technical Staff: Rick Sterling sw:gdklumisc/prdreq/ipceOO 12 .swrps FIRST PRODUCTION REQUEST TO IDAHO POWER SEPTEMBER 19, 2003 CERTIFICA TE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF SEPTEMBER 2003 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THECOMMISSION STAFF TO IDAHO POWER IN CASE NO. IPC-00-, BY MAILING A COpy THEREOF, POST AGE PREP AID , TO THE FOLLOWING: PETER J RICHARDSON RICHARDSON & O'LEARY PO BOX 1849 EAGLE ID 83616 LARRY D RIPLEY SENIOR ATTORNEY IDAHO POWER COMP ANY PO BOX 70 BOISE ID 83707-0070 BRIAN GRAHAM HEWLETT P ARKARD COMPANY 11311 CHINDEN BLVD BOISE ID 83714 GREGORY W SAID, DIRECTOR REVENUE REQUIREMENT IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 CERTIFICATE OF SERVICE