200404271st Request of Staff to ID Power.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
;CJ
L~J
" ,- (' ;-
, 'I r
:, ;
--G~~" '
;,:...') . :.'"
f'\ C if
" ; l.
dT iLl r iLS COi"ii'1iSSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Respondent.
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
IDAHO POWER COMPANY,
CASE NO. IPC-04-
Complainant,
CITY OF EAGLE, IDAHO,
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Donald L. Howell Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
TUESDAY, MAY 11, 2004.
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 or information
produced.
For each item, please indicate the name ofthe person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY APRIL 27 , 2004
REQUEST NO.1: Please provide the number of Idaho Power customers within the city
limits of Eagle, Idaho, by customer class, for the year 2003.
REQUEST NO.2: Please provide the total energy consumed by Idaho Power customers
within the city limits of Eagle, Idaho, by customer class, for the year 2003.
REQUEST NO.3: Please provide the total revenue generated by Idaho Power
customers within the city limits of Eagle, Idaho, by customer class, for the year 2003.
REQUEST NO.4: Please provide the estimated incremental capital cost of Alternative
Alignment No. I (as described in the Company s Complaint at Exhibit 3) assuming a buried
transmission line from Edgewood Street south, then to the west side of the Highway 44 (Eagle
Bypass)/Eagle Road intersection.
REQUEST NO.5: Please provide the estimated incremental, Idaho Power Company
annual revenue requirement for the buried Alternative No.1 described in Request No.4 above.
Use Amortization periods of 5, 10 and 20 years.
REQUEST NO.6: Please provide the estimated incremental, Idaho Power Company
annual revenue requirement to construct Alternative No.4 rather than Alternative No.2 (as
described in the Company s Complaint at Exhibit 3) using amortization periods of 5, 10 and 20
years.
REQUEST NO.7: Idaho Power indicated on April 19 that Alternative Nos. 2, 3 and 4
as described in the Company s Complaint at Exhibit 3 are still possible but at higher cost. Please
provide the updated cost estimate and describe the reasons for the price escalation(s).
REQUEST NO.8: Idaho Power indicated on April 19 that Alternative Nos. 5 and 6 as
described in the Company s Complaint at Exhibit 3 are not viable transmission upgrade options.
Please explain why these options are not viable.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY APRIL 27, 2004
REQUEST NO.9: Please indicate the height of the poles or structures and the necessary
amount of vertical clearance for the 138-kv transmission line for the aerial portion of Alternative
No. I in Exhibit 3.
REQUEST NO. 10: Please specify what table or section of the 2002 National Electric
Safety Code the Company uses to calculate the necessary vertical clearance for the 138-
transmission line if it were to be aligned as proposed in Alternative No.1 in Exhibit 3.
DATED at Boise, Idaho, this Z 7~ay of April 2004.
Donald L. H ell, II
Deputy Attorney General
Technical Staff: Randy Lobb
i:umisc:prodreqlipceO4.4dhrl ipc
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY APRIL 27, 2004
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF APRIL 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER, IN CASE NO. IPC-04-, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
MONICA B MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
SUSAN BUXTON
MOORE SMITH
225 N 9TH ST SUITE 420
BOISE ID 83702
CITY OF EAGLE
PO BOX 1520
EAGLE ID 83616
)(~
SECRETARY
CERTIFICATE OF SERVICE