20060130NW Energy Coalition 1st request to IPC.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ill 83701
[phone]
fax: [phone]
billeddieCfYrmci.net
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iOS/OU
Express Mail:
1320 W. Franklin St.
Boise, ill 83702
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
CASE NO.IPC-05-
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION
Intervenor NW Energy Coalition, by and through counsel, requests that Idaho Power
Company ("Idaho Power" or "Company ) provide the following information.
This Production Request is considered to by continuing, and the Company is requested to
provide, by way of supplementary responses, additional documents or information that it or any
person acting on its' behalfmay later obtain that will augment the infonnation or do?uments
produced.
In answering each request, pl~ase 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.
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION --
REQUEST NO.1: Please provide any work papers, memos, studies, or similar
documents supporting the Company s request to increase fixed customer charges for
customers taking service under Schedules I and 7 from $3.30 to $6.00.
REQUEST NO.2: What components of the Company s costs of service does
th~ Company intend to recover through the proposed $6 customer charge for customers
taking service under Schedules I and 7.
~QUEST NO.3: Exhibit 42 in the Company s last general rate case, IPC-
03-, stated that the unit costs for "Meters
" "
Install on Cust. Premises
" "
Meter
Reading," and "Customer Accounts" (Schedule 1 and Schedule 7 customers) were less
costly than the amounts stated in Exhibit 45 in the above-captioned case. For example
the function "Customer Accounts" (Schedule 1) had a stated unit cost of
$2.68819/cust/month in the IPC-03-13 filing; while "Customer Accounts" have a
stated unit cost of$3.43765/cust/month in Exhibit 45 for the above-captioned case.
Please explain why the stated unit costs for the "Meters
" "
Install on Cust. Premises
Meter Reading," and "Customer Accounts" functions in Schedules 1 and 7have
increased between the IPC-03-13 case and the above-captioned matter; and please
provide any workpapers or other documents that explain these differences.
DATED this 27th day of January, 2006.(7
' -....
iA./~
William M. Eddie
On behalf ofNW Energy Coalition
FIRST PRODUCTION REQUESTS OF NW ENERGY COALITION -- 2
CERTIFICATE of SERVICE
I hereby certify that on this 27TH day of January 2006, tru~ and correct copies of
the foregoing FIRST PRODUCTION REQUESTS OF NW ENERGY COALITiON were
delivered to the following persons via hand delivery (for Idaho Power recipients) andS. Mail (for all others):
Barton Kline
Monica Moen
Idaho Power Company
O. Box 70'
Boise, ill 83707-0070
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Lawrence Gollomp
Assistant General Counsel
S. Dept. of Energy
1000 Independence Ave., SW
Washington, DC 20585
Don L. Howell
Cecelia A. Gassner
Deputy Attorney Generals
Idaho Public Utilities Commission
O. Box 83720
Boise, ill 83720
John R. Gale
Idaho Power Company
O. Box 70
Boise, ill 83707-0070
Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ill 83703
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ill 83703
Randall Budge
Eric Olsen
Racine, Olson, et al.
O. Box 139~
Pocatello, ill 83204-1391
Dennis Goins
Potomac Management Group
5801 Westchester St.
Alexandria, VA 22310-1149
Conley Ward
Givens Pursley'
O. Box 2720
Boise, ill 83701-2720
Dennis Peseau
Utility Resources
1500 Liberty St, S.
Suite 250
Salem, OR 97302
Michael Kurtz
Kurt 1. Boehm
Boehm, Kurtz & Lowry
36 E. Seventh St., Suite 2110
FIRST PRODUCTION REQUESTS OF'NW ENERGY COALITION -- 3