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Home My WebLink About200310011st Request of Idaho Power to Kimball-HP.pdfMONICA B. MOEN ISB # 5734 Idaho Power Company P. O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2692 FAX Telephone: (208) 388-6936 Attorney for Idaho Power Company Street Address for Express Mail 1221 West Idaho Street Boise, Idaho 83702 HECE\VED . fiLED 20B3 OCT - \ AM': 06 tUj~HUF\U\3L1C UT\L\-riES COMMISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION KIMBALL PROPERTIES LIMITED PARTNERSHIP AND HEWLETT PACKARD COMPANY Complainants vs. IDAHO POWER COMPANY, an Idaho Corporation Respondent. CASE NO. IPC-OO- IDAHO POWER COMPANY' FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION COMES NOW , Idaho Power Company ("Idaho Power" or the "Company ) and herewith files its First Set of Interrogatories and Requests for Production To Complainants Kimball Properties Limited Partnership and Hewlett Packard Company in the above-referenced matter: INTERROGATORIES INTERROGATORY NO.: Please provide the basis for the assertion of Stuart IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION - 1 T. Trippel ("Trippel") on page 4 1110-, of his testimony in this action in which Trippel testifies that "HP was. . . unfairly singled out to partially pay for the construction of a new substation know as the Bethel Court Substation. INTERROGATORY NO.: Please provide the basis for Trippel's assertions on page 4, II 22-, of his testimony in this action that Idaho Power allegedly has not consistently applied its policy of recovering the pro-rata costs for the construction of substation and transmission lines from industrial customers. INTERROGATORY NO.: Please provide the basis for Trippel's conclusion on page 5, II 18-, of his testimony in this action that "Idaho Power determined that it was necessary to construct a new substation to provide electric service to HP. INTERROGATORY NO.: Please provide the basis for Trippel's conclusion on page 5, II 20-, of his testimony in this action that it was necessary for Idaho Power Company to construct a new substation to "serve future loads in the area. INTERROGATORY NO.: Please provide the basis for Trippel's conclusion on page 5 , L 21 , of his testimony in this action that it was necessary for Idaho Power Company to construct a new substation "to readjust some existing loads. INTERROGATORY NO.: Please describe the basis for Trippel's statement on page 6, II 9-, of his testimony in this action that construction of the substation was the best solution to providing the power to the area." (Emphasis added. INTERROGATORY NO.: Please identify an alternative to what Trippel identifies as a "time-clustered pattern" of constructing substations as referenced on page 8 , L 20 , of his testimony in this action. INTERROGATORY NO.: Please further describe what is meant by " IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION - 2 excessive cost to the load that comes on-line nearest the time of construction" on page , 1120-22 of Trippel's testimony in this action. (Emphasis added. INTERROGATORY NO.9: Please describe the characteristics of a "uniform system based upon objective cost allocation criteria" as identified on page 10 , II 24- of Trippel's testimony in this action by which Trippel asserts Idaho Power Company allocated costs. INTERROGATORY NO. 10 : Please provide the basis for Trippel's assertions on page 11 , II 13-, in his testimony in this action that customer reimbursement for substation construction based upon "timing" is an "inherently arbitrary policy. INTERROGATORY NO. 11 : Please further describe the "accident of timing referred to by Trippel on page 12, II 4-, of his testimony in this action. INTERROGATORY NO. 12: Please provide the basis for Trippel's assertions on page 16 , II 16-17 of his testimony in this action that "H P is a minor player in creating the need for additional electrical capacity in the area. INTERROGATORY NO. 13: Please provide the basis for Trippel's assertions on page 17, II 19-, of his testimony in this action that "H P is subsidizing other ratepayers by paying for a portion of a substation used to support Idaho Power s overall system. INTERROGATORY NO. 14 : Please provide the basis for Trippel's assertions on page 18, II 20-, that Idaho Power Company s alleged "decision to assess the first customer and not any subsequent customer has no relationship to cost causation. INTERROGATORY NO. 15 : Please identify any instance(s) to the Complainants' knowledge in which Idaho Power Company failed to request a contribution in aid of construction from an industrial customer for a new substation built IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION - 3 to meet the loads of that customer when inadequate capacity existed. REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO.: Please produce documents the Complainants relied upon in preparing their response to Interrogatory No. REQUEST FOR PRODUCTION NO.: Please produce documents Trippel relied upon in concluding on page 5, 1118-19, of his testimony in this action that "Idaho Power determined that it was necessary to construct a new substation to provide electric service to HP. REQUEST FOR PRODUCTION NO.: Please produce documents the Complainants relied upon in preparing their response to Interrogatory No. REQUEST FOR PRODUCTION NO.: Please produce documents Trippel relied upon in concluding on page 5 , II 20-, of his testimony in this action that it was necessary for Idaho Power to construct a new substation to "serve future loads in the area. REQUEST FOR PRODUCTION NO.: Please produce documents the Complainants relied upon in preparing their response to Interrogatory No. REQUEST FOR PRODUCTION NO.: Please produce documents Trippel relied upon in concluding on page 5 , L 21 , of his testimony in this action that it was necessary for Idaho Power to construct a new substation "to readjust some existing loads. DATED at Boise , Idaho, this 30th day of September 2003. cZ- MONICA B. MOEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 30th day of September 2003 , I served a true and correct copy of the within and foregoing IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION upon the following named parties by the method indicated below , and addressed to the following: Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission P. O. Box 83720 Boise, Idaho 83720-0074 ---L Hand Delivered S. Mail Overnight Mail FAX Peter J. Richardson Richardson & O'Leary PLLC 99 E. State Street P. O. Box 1849 Eagle, Idaho 83616 Hand Delivered S. Mail Overnight Mail FAX Brian Graham Hewlett Packard Company 11311 Chinden Blvd. Boise , Idaho 83714 ----K- Hand Delivered S. Mail Overnight Mail FAX ~. 13. MONICA B. MOEN IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION - 5