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Home My WebLink About200601275th staff request to IPC.pdfTi E iJ ; , CECELIA A. GASSNER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 IDAHO BAR NO. 6977 :J":?7 F,; 1:59 JfiLi iT~S CCi iS'SIU!J Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY) TO INCREASE ITS BASE RATES AND CHARGES FOR ELECTRIC SERVICE IN THESTATE OF IDAHO. CASE NO. IPC-05- FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Cecelia A. Gassner, Deputy Attorney General, requests that Idaho Power Company (Company; IPC) provide the following documents and information as soon as possible, but no later than FRIDAY, FEBRUARY 17, 2006. 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. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number ofthe record holder. FIFTH PRODUCTION REQUEST TO IDAHO POWER JANUARY 27, 2006 For 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. Request No. 36: Pengilly pg 19, lines 2 - 6, states "setting the energy threshold at 2 000 kWh will require an estimated 13 percent of the current Schedule 7 customers, who account for approximately 27 percent of the overall Schedule 7 revenue, to be transferred to Schedule 9. Please provide an analysis of the effect on cost of service that this move of customers from Schedule 7 to Schedule 9 will have. In particular, what is the cost of service revenue requirement for Schedules 7 and 9 after this move of customers? Request No. 37: Please provide the analysis that supports a $17.50 in-season service charge for Schedule 24 and an out-of-season service charge of only $3.00. Request No. 38: For Schedule 24, could the out-of-season service charge be increased to off-set revenue lost through elimination of the demand charge? Request No. 39: Please explain why Schedule 25 is closed to new customers. Request No. 40: Please provide the cost justification for the Company practice of proration of the service charge in partial monthly bills. Request No. 41: Please provide the cost justification for Schedule 66, No. , " off-site meter reading service" monthly charge of $3.65 and $4.40. Request No. 42: Please provide a bill frequency analysis for Service Schedules 1 and 7 for each month with incremental blocks of 100 kWh for usage from 0 to 1200 kWh; 1200 to 1500 kWh; 1500 to 2 000 kWh; 2 000 to 2 500 kWh; 2 500 to 3 000 kWh; 3 000 to 4 000 kWh; 4 000 to 000 kWh and over 5 000 kWh. Include both number of bills in the block and energy use in the block. Please provide this in Excel 2000 format. FIFTH PRODUCTION REQUEST TO IDAHO POWER JANUARY 27, 2006 Request No. 43: Please provide a bill frequency analysis for each month for Service Schedule 9. Include both the number of bills in the block and energy use in the following usage blocks: 0 to 1 000 kWh; 1 000 to 1 500 kWh; 1500 to 2 000 kWh; 2 000 to 2 500 kWh; 2 500 to 000 kWh; 3 000 to 4 000 kWh; 4 000 to 5 000 kWh; 5 000 to 10 000 kWh; 10 000 to 25 000 kWh; 25 000 to 50 000 kWh; and over 50 000 kWh. Please provide this in Excel 2000 format. Request No. 44: Please provide a bill frequency analysis for Service Schedule 24 for each month. Include both the number of bills in the block and energy use in the block for each of the following usage blocks: 0 to 1 000 kWh; 1 000 to 5 000 kWh; 5 000 to 10 000 kWhs; 10 000 to 000 kWh; 25 000 to 50 000 kWh; 50 000 to 100 000 kWh; 100 000 to 350 000 and over 350 000 kWh. Please provide this in Excel 2000 format. Request No. 45: On page 32 ofIPUC Order No. 29505, the Commission ordered Idaho Power to increase its LIW A payments to CAP agencies by $1 million to approximately $1. million for each of the next three years, effective coincident with the rate increases authorized by the Order. The Commission stated "these dollars are to be booked and tracked in a separate balancing sub-account... unpaid funds shall carryover and be available in the next year." Please provide the following: The account number of the separate balancing sub-account referenced in Order No. 29505; The actual amounts paid to the CAP agencies from the sub-account in 2004; The actual amounts paid to the CAP agencies from the sub-account in 2005; The budgeted amounts expected to be paid to the CAP agencies from the sub-account in 2006 and 2007; The revenue requirement in this Case No. IPC-05-28 associated with these payments (please show the Company s calculation and source of information in addition to Exhibit and line references). Request No. 46: If the amounts provided in response to items b. and c. in the previous request does not equal the balance in the sub-account as reflected in the Company s December 2004 and December 2005 ending trial balance, please provide a detailed reconciliation that describes the dollars and reasons for the differences between the amounts in the Company response and that contained in its accounting records. FIFTH PRODUCTION REQUEST TO IDAHO POWER JANUARY 27, 2006 Request No. 47: Please provide the actual capital structure and actual cost of debt at December 31 , 2005 with the detailed information as shown on Idaho Power Company Exhibit Nos. 11 and 12. Dated at Boise, Idaho , this J;f~ay of January 2006. cece Jr- Deputy Attorney General Technical Staff: Dave Schunke Beverly Barker Terri Carlock i:umisc:prodreqlipceO5.28ccdesbabtc pr 5 FIFTH PRODUCTION REQUEST TO IDAHO POWER JANUARY 27, 2006 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF JANUARY 2006 SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER IN CASE NO. IPC-05-, 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 MAIL: bkline~idahopower.com mmoen~idahopower.com RANDALL C BUDGE ERIC L OLSEN RACINE, OLSON, NYE, BUDGE, BAILEY 201 E CENTER PO BOX 1391 POCATELLO, ID 83204-1391 MAIL: rcb~racinelaw.net elo~racinelaw.net PETER J. RICHARDSON RICHARDSON & O'LEARY LLP 515 N 27TH ST PO BOX 7218 BOISE ID 83702 MAIL: peter~richardsonandoleary. com CONLEY E WARD GIVENS PURSLEY LLP 601 W BANNOCK ST PO BOX 2720 BOISE ID 83701-2720 MAIL: cew((p,givenspursley.com LA WRENCE A. GOLLOMP ASSISTANT GENERAL COUNSEL UNITED STATES DEPT OF ENERGY 1000 INDEPENDENCE AVE. SW WASHINGTON, DC 20585 MAIL: lawrence.gollomp((p,hq.doe.gov JOHN R GALE VICE PRESIDENT REGULATORY AFFAIRS IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 MAIL: rgale((p,idahopower.com ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 MAIL: yankel~attbi.com DR. DON READING 6070 HILL ROAD BOISE ID 83703 MAIL: dreading~mindspring.com DENNIS E. PESEAU, PH. UTILITY RESOURCES INC 1500 LIBERTY STREET S. SUITE 250 SALEM, OR 87302 MAIL: dennytemp((p,yahoo.com DENNIS GOINS POTOMAC MANAGEMENT GROUP PO BOX 30225 ALEXANDRIA VA 22310-8225 MAIL: dgoinspmg~ao1.com CERTIFICATE OF SERVICE WILLIAM MEDDlE ADVOCATES FOR THE WEST PO BOX 1612 BOISE ID 83701 MAIL: billeddie((p,rmci.net KEN MILLER NW ENERGY COALITION 5400 W FRANKLIN STE G BOISE ID 83705 MICHAEL L KURTZ ESQ KURT J BOEHM ESQ BOEHM KURTZ & LOWRY 36 E SEVENTH ST STE 1510 CINCINNATI OH 45202 MAIL: mkurtz((p,bkllawfirm.com kboehm~bkllawfirm.com \~0tL- CERTIFICATE OF SERVICE