200405201st Request of Eagle to Idaho Power.pdf

Idaho Public Utilities Commission
Office of the SecretaryRECEIVEDBruce M. Smith, ISB # 3425
Susan E. Buxton, ISB # 4041
MOORE SMITH BUXTON & TURCKE, CHARTERED
Attorneys at Law
225 North 9th Street, Suite 420
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
MAY " 7 2004
Boise, Idaho
Attorney for Respondent, City of Eagle, Idaho
BEFORE THE IDAHO PUBLIC UTILIES COMMISSION
Respondent.
FIRST PRODUCTION REQUEST
OF THE CITY OF EAGLE TO
IDAHO POWER COMPANY
IDAHO POWER COMPANY,
Case No. IPC- E-O4-
Complainant
vs.
CITY OF EAGLE, IDAHO,
The City of Eagle, Idaho, by and through its attorney of record, Susan E. Buxton, requests
that Idaho Power Company provide the following documents and information as soon as
possible, but no later than Friday, June 4, 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.
F or 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.
DEFINITION OF DOCUMENT
REQUEST No.1: Please provide all work papers relating to Exhibit 3 of the
COMPLAINT TO OBTAIN COMMISSION ORDER DIRECTING IDAHO POWER TO
CONSTRUCT IMPROVEMENTS TO SECURE ADEQUATE SERVICES TO ITS
CUSTOMERS, dated February 11 2004.
THE CITY OF EAGLE'
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
Page May 17 2004
REQUEST No.2: Please provide a list of all transmission and sub-transmission lines
proposed for connection to the proposed Star, Idaho substation.
REQUEST No.3: Provide a list of all transmission or sub-transmission lines that are
planned for or under consideration by Idaho Power Company that may be located within the
Eagle City Area of Impact.
REQUEST No.4: Please provide a copy of any study related to Idaho Power Company
future transmission or sub-transmission line needs in the City of Eagle Impact Area or within two
miles of the City of Eagle Area of Impact.
REQUEST No.5: Please provide an estimate of the relative percentage of power the
proposed 138 kv sub-transmission line will supply to Idaho Power Company customers located
in the City of Eagle.
REQUEST No.6: Please provide the estimated depreciation period for the proposed 138
kv sub-transmission line. I f there is more than one depreciation period used by Idaho Power
Company, e.g. for tax calculations, rate making, or replacement, please provide the period for
each accounting method.
REQUEST No.7: Please provide values of the "elevation adder" and the "maximum
over-voltage adder" referred to in Idaho Power Company Response to the Commission Staffs
Production Request No. 10.
REQUEST No.8: With respect to the relocation of overhead power lines referred to in
Mr. Said's testimony on page 6, were the funds supplied by the City of Ketchum used to relocate
an existing line or a new line?
REQUEST No.9: At the meeting held on March 31 , 2004 between Idaho Power
Company, the Commission Staff, and the City of Eagle, a reference was made to the future
construction of a transmission line north of the City of Eagle. Please provide a description of this
proposed line, including the time frame for construction and the proposed area to be serviced by
this line.
REQUEST No. 10: Assuming the transmission line upgrades proposed between Caldwell
and East Lansing Substation and at Beacon Light and Linder, referred to in Mr. Said's testimony
at page 16 are completed prior to the proposed 138 kv line at issue here, how soon would the
proposed 138 kv line be required?
THE CITY OF EAGLE'
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
Page 2 May 17, 2004
REQUEST No. 11: In responses 1 through 3 to Staffs First Production Request the
Company provide the number of customers, kWh used, and revenue within the city limits ofEagle. Please provide for these responses:
1. All data and work papers used to determine these values
2. The breakdown for customer classes for these 6 616 customers
3. Monthly kWh use, revenue, and number of customers for the year 2003.
DATED at Boise, Idaho, this ih day of May, 2004.
MOORE SMITH BUXTON &
CHARTERED
By:
.;:,.~ ~ ~
Susan E. Buxton
Attorney for City of Eagle, Idaho
TURCKE
THE CITY OF EAGLE'
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
Page 3 May 17 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF MAY 2004 SERVED THE
FOREGOING RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-04-, BY
DELIVERING A COpy THEREOF TO THE FOLLOWING:
Mr. Don Howell
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83720-0074
Via Hand delivery
Monica B. Moen
Barton L. Kline
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
Via Hand delivery
~n
/(~
Attorney for City of Eagle, Idaho
THE CITY OF EAGLE'
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
Page 4 May 17 2004