200402031st Request of ID Power to Staff.pdf

MONICA B. MOEN ISB # 5734
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
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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-00-
IDAHO POWER COMPANY'
FIRST SET OF
INTERROGATORIES AND
REQUESTS FOR PRODUCTION TO
TO THE COMMISSION STAFF
COMES NOW , Idaho Power Company ("Idaho Power" or the "Company ) and
herewith files its First Set of Interrogatories and Requests for Production to the Idaho
Public Utilities Commission Staff in the above-referenced matter. Please provide the
responses and the requested documents and information on or before Friday,
February 13, 2004.
IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION TO
THE COMMISSION STAFF-
INTERROGATORIES
INTERROGATORY NO.: Based upon Mr. Sterling s statement on Pages 6-7 of
his testimony that "HP/Kimball is (and has been) paying for this share of substation costs
through its rates as a Schedule 9 customer " is it Staff's contention that HP/Kimball has
been paying its specific cost of service or that HP/Kimball has been paying the cost of
service attributed to the Schedule 9 class cost of customers?
INTERROGATORY NO.: Does the Staff have an opinion as to the relative cost of
service for a new customer requiring additional substation facilities as opposed to the cost
to serve the incumbent customer within the same customer class? If so, please state the
Staff's opinion and the basis for said opinion.
INTERROGATORY NO.: Is it the Staff's position that any refund to HP/Kimball
will then be considered an investment of Idaho Power that will be an increase to rate base?
If yes, which customers does the Staff believe will pay the return on investment on that
rate base?
INTERROGATORY NO.: Please describe the Staff's understanding of who pays
for the return on investment for the unused capacity of substations included in rate base.
INTERROGATORY NO.: Does the Staff believe that it is in ratepayer s interest
that new customers be encouraged to locate in area where unused substation capacity
already exists? If not , please explain.
INTERROGATORY NO.: In Mr. Sterling s testimony on Page 11 , he states that
HP/Kimball will effectively pay twice.
(a)Has the Staff performed an HP/Kimball-specific cost of service study
that would demonstrate that HP/Kimball would be paying twice its cost of service?
IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION TO
THE COMMISSION STAFF - 2
(b)Is it Staff's position that HP/Kimball would be paying twice its cost of
service?
(c)If the answer to (b) above is "" to what does the word
, "
twice
refer?
INTERROGATORY NO.On Page 15 of Mr. Sterling s testimony, he states
, "
It is
discriminatory whenever one customer has to pay for substation facilities and another
customer, who may require the same or even larger substation capacity, does not have to
pay just because extra substation capacity is already available.
(a)Would Staff also contend that it is discriminatory whenever one
customer has to pay for distribution facilities and another customer , who may require the
same or even larger distribution capacity, does not have to pay just because extra
distribution capacity is already available?
(b)If the answer to (a) is yes , does the Staff believe that Rule H is
discriminatory?
(c)If the answer to (a) is yes and the answer to (b) is no , please explain
why Rule H is not discriminatory.
REQUESTS FOR PRODUCTION
REQUEST FOR PRODUCTION NO.: Has the Staff performed any studies to
determine if HP/Kimball's cost of service is greater or less than the cost of service for the
Schedule 9 class? If so , please provide such studies.
REQUEST FOR PRODUCTION NO.In the Staff Attorney s question on Page 10
of Mr. Sterling s testimony is a statement that "Certainly at least some of the unused
capacity that HP/Kimball originally requested is now being used to serve new customers.
IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION TO
THE COMMISSION STAFF - 3
If HP/Kimball requested 4 MW and Idaho Power added 20 MW, is it the Staff's position that
other new customers are utilizing both the 16 MW that Idaho Power funded for use by
customers other than HP/Kimball and a portion of the 4 MW for which HP/Kimball paid? If
, please provide the analysis that supports that position.
REQUEST FOR PRODUCTION NO.: Please produce any Staff studies that
demonstrate that, by paying an upfront contribution for substation costs , HP/Kimball will
pay higher than its costs of service.
REQUEST FOR PRODUCTION NO.: Please produce any Staff analyses that
demonstrate that after having made a contribution in aid of construction, HP/Kimball has a
lower cost of service than other Schedule 9 customers.
DATED at Boise, Idaho, this 2nd day of February 2004.
MONICA B. MOEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION TO
THE COMMISSION STAFF - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of February 2004 , I served a true
and correct copy of the within and foregoing IDAHO POWER COMPANY'S FIRST SET OF
INTERROGATORIES AND REQUESTS FOR PRODUCTION TO THE COMMISSION
STAFF on 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
---1L 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
---1L
Hand Delivered
S. Mail
Overnight Mail
FAX
Brian Graham
Hewlett Packard Company
11311 Chinden Blvd.
Boise , Idaho 83714
---1L
Hand Delivered
S. Mail
Overnight Mail
FAX
(13.
MONICA B. MOEN
IDAHO POWER COMPANY'S FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION TO
THE COMMISSION STAFF - 5