200402021st Request of AARP to ID Power.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
bmpurdy(?Yhotmail. com
Attorney for Petitioner
Community Action Partnership
Association ofldaho and
American Association of
Retired Persons.
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2004 FEB - 2 PI~i 4:
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS INTERIM AND BASE
RATES AND CHARGES FOR ELECTRIC SERVICE
CASE NO. IPC-O3-
FIRST PRODUCTION
REQUESTS OF AMERICAN
ASSOCIATION OF
RETIRED PERSONS
TO IDAHO POWER
COMES NOW, Intervenor American Association of Retired Persons ("AARP"
by and through its attorney of record, Brad M. Purdy, requests that Idaho Power
Company provide the following information and documents in accordance with the Idaho
Public Utilities Commission s Rules of Procedure, and applicable scheduling orders and
notices issued by the Commission in this proceeding.
This production request is to be deemed continuing in nature and Idaho Power is
requested to provide, through supplementation, additional documents or information that
is responsive to this request that it, or any person acting on its behalt: may later come into
possession or become aware of.
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
In answering each request, please provide the name of the person(s) preparing the
answers, along with the title and function such individual holds with the Company and
the witness who can sponsor the answer at the hearing. For all responses to the following
requests, please provide all work papers, diskettes and all underlying formulas in Excel
language.
You are further instructed that whenever the terms "you
" "
your " or "Company
appear herein, they are all construed to refer to Idaho Power Company.
Request No.Please provide the date and edition number for the
NARUC Electric Utility Cost Allocation Manual" cited by Ms. Britz in her direct
testimony at p. 5, line 15.
Request No.On p. 36, line 15 of her testimony, Ms. Britz states that she
does not believe that the increase in the monthly fixed charge will have a detrimental
impact on low-income customers.
Please provide all information in the Company s possession or control pertaining
to its low-income customers' electric consumption patterns and how these differ from or
are similar to other residential customers. 1 Include all analyses Idaho Power has carried
out or is aware other individuals or organizations have carried out on low-income electric
usage patterns over the last 20 years.
Request No.Please provide in spreadsheet format residential
consumption frequency data that allows the determination of the percentage of customers
whose electric consumption is less than any given level for both the proposed summer
and non-summer seasons as well as for the year as a whole.
1 Whenever the term "low-income" is found in these production requests, it is to be defined as 150% of the
federal poverty guidelines as established by the federal Office of Management and Budget.
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
Request No.Please provide transmission capital construction costs per
mile for typical transmission lines operating at the following voltages:
69 kv
115 kv
161 kv
230 kv
500 kv
Request No.Please provide the peak-load capacity of each line, at the
vohage levels indicated in the preceding Request, for which capital construction costs
have been provided.
Request No.When capital costs and capacity can vary depending upon
the conductor size and/or control equipment installed, provide this information for a
typical" installation.
Request No.In his dh-ect testimony, Mr. Keen at p. 19, line 17, indicates
that since 1996, Idaho Power s peak load has increased 526 MW. He then lists
transmission investments whose costs totaled $94.5 million dollars. What percentage
increase does this represent for the peak load carried by Idaho Power s transmission
system and the total depreciated cost of the transmission system?
Request No.In the cost of service analysis provided with the Company
filing in this case, general plant was allocated to customer classes in proportion to other
plant (i.e., production, transmission, distribution, etc.) allocated to that class.
a) Please provide a definition of "general plant" or a listing of the types of
plant included in that category.
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
b) Please explain in what way general plant is primarily related to the
quantity of other plant, i.e. what is the causal relationship that led it to be allocated in
your cost of service analysis on the basis of all other plant?
Request No.The listing of Administrative and General (A&G) costs
shows a $24.5 million "transferred credit." (Exhibit 37, A483) Please explain the source
of this entry.
Request No. 10:Under A&G costs, "salaries" are listed. Exactly what types
of salaries are included in this category instead of in one of the specified functional
categories?
Request No. 11:Under A&G costs there is an "outside services" category.
What types of costs are included in this category?
Request No. 12:Has Idaho Power treated transmission associated with
remotely sited generating facilities as part of power supply (production) or is all
transmission treated the same?
Request No. 13:Please provide a break down ofthat part of power supply
that is transmission facilities that move electricity from remotely sited facilities to Idaho
Power s service territory.
Request No. 14:Please provide the Idaho jurisdictional load factor for all
years since 1990.
Request No. 15:What was the total demand placed on the distribution
system during the test year?
Request No. 16:What was the average demand per customer placed on the
distribution system by each customer class and for all customers as a whole?
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
Request No. 17:For the residential class, please provide data on estimated
class monthly peak demand and monthly energy consumption for each month ofthe year.
If this information is available for historical years, please provide it for all years since
1990. .
Request No. 18:At page 11 , line 10 of his direct testimony, Mr. Gale
indicates that as a matter of policy, Idaho Power has sought in the last several rate cases
to move rates towards cost of service results.
In light of this, for the last three rate cases, please indicate the following:
a. The irrigation class revenue deficiency that Idaho Power s cost of
service study utilized in that case identified.
b. The percentage increase in irrigation class rates that would have been
necessary to eliminate that revenue deficiency.
c. The overall Idaho jurisdiction revenue increase (in dollar and
percentage terms) identified by Idaho Power s cost of service study.
d. The irrigation class revenue increase (in dollar and percentage terms)
recommended by Idaho Power.
Request No. 19:Given the typical time interval between Idaho Power
general rate cases and the rate at which Idaho Power proposes to eliminate the irrigation
class revenue deficiency in this case, how many years will it take before the irrigation
class is paying its full revenue requirement?
Request No. 20:At page 13, line 14 of his direct testimony, Mr. Gale seems
to describe the demand charge as a "fixed charge." Isn t it true that the demand charges
vary by month depending on the electric usage patterns ofthe customer? COULD YOU
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
Request No. 21:At page 13, line 9 of his direct testimony, Mr. Gale
indicates that customer conservation decisions would be improved if energy usage rates
better reflected Idaho Power s energy costs. Is Mr. Gale referring only to the variable
energy costs in this statement or is pe also including the fIXed costs incurred in order to
generate electrical energy?
Request No. 22:Please provide Idaho Power s current estimates of the
levelized long run incremental cost of new electric supply.
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DATED this day of January, 2004.
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Brad M. Purdy
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
CERTIFICATE OF SERVICE
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I HEREBY CERTIFY THAT I HAVE TlllS.:3 C DAY OF JANUARY, 2004
SERVED THE FOREGOING FIRST PRODUCTION REQU:EST OF AARP TO
IDAHO POWER COMPANY, IN CASE NO. IPC-03-, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID. 83707
() u.S. Mail, postage prepaid
Hand delivered
() Facsimile
() Overnight mail
John R. Gale
Idaho Power Company
O. Box 70
Boise, ID. 83707
() u.S. Mail, postage prepaid
('4 Hand delivered
() Facsimile
() Overnight mail
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID. 83702
N U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle, ID. 83616
(;1 U.S. Mail, postage prepaid
(J Hand delivered '
() Facsimile
() Overnight mail
Don Reading
Ben Johnson Associates
6070 Hill Rd.
Boise, ID. 83703
(~ U.S. Mai~ postage prepaid
(J Hand delivered
() Facsimile
(J Overnight mail
Anthony Yankel
29814 Lake Road
M u.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
N u.s. Mail, postage prepaid
(J Hand delivered
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey
201 E. Center
Pocatello , ID. 83204
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
Bay Village, OH. 44140 () Facsimile
() Overnight mail
Dennis Goins
Potomac Management Group
5801 Westchester St.
Alexandria, VA 22310-1149
!xI U.S. Mail, postage prepaid
() Overnight mail
(J Hand delivered
() Facsimile
M U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Lawrence A. Gollomp
1000 Independence Ave., SW
Washington, D.C. 20585
Dean 1. Miller
O. Box 2564
Boise, ID. 83701
W U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Jeremiah 1. Healey
O. Box 190420
Boise, ID. 83719-0420
Dr U.S. Mail, postage prepaid
() Hand delivered
I) Facsimile
() Overnight mail
Nancy Hirsch
219 First Ave. South, Suite 100
Seattle, WA. 98104
~ U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
M U.S. Mail, postage prepaid
n Hand delivered
I) Facsimile
() Overnight mail
William M. Eddie
O. Box 1612
Boise, ID. 83701
Dennis Pesau
1500 Liberty St., Suite 250
Salem, OR. 97302
~ U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
~ U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Conley E. Ward
601 W. Bannock St.
Boise, ID. 83702
Michael L. Kurtz
Kurt J. Boehm
M U.S. Mail, postage prepaid
() Hand delivered
FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY
Boehm, Kurtz & Lowry
36 E. Seventh St., Suite 2110
Cincinnati, OH 45202
() Facsimile
() Overnight mail
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FIRST PRODUCTION REQUEST OF AARP TO IDAHO POWER COMPANY