HomeMy WebLinkAbout20090213IPC to Staff 1-3.pdfLISA D. NORDSTROM
Senior Counsel
1~~~f
\O~i;q
\J\\\J\\C.S
esIDA~POR~
An IDACORP Company
February 13, 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-08-22
RuleH
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Supplemental Response to the Commission Staff's First Production Request to
Idaho Power Company in the above matter.
i would appreciate it if you would return a stamped copy of this letter for Idaho
Power's file in the enclosed stamped, self-addressed envelope.
Very truly yours,
~~ £!.11 fh~
Lisa D. Nordstrom.
LDN:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
LISA D. NORDSTROM, ISB No. 5733
BARTON L. KLINE, ISB No. 1526
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Tel: 208-388-5825
Fax: 208-338-6936
Inordstrom~idahopower.com
bklineú?idahopower.com
R.'l
Lnn~ fEB \ 3 ?l' 3: 2 \
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-08-22
AUTHORITY TO MODIFY ITS RULE H )
TARIFF RELATED TO NEW SERVICE ) IDAHO POWER COMPANY'S
ATTACHMENTS AND DISTRIBUTION ) SUPPLEMENTAL RESPONSE TO
LINE INSTALLATIONS OR ALTERATIONS ) THE COMMISSION STAFF'S FIRST
) PRODUCTION REQUEST TO
) IDAHO POWER COMPANY
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
supplemental response to the First Production Request of the Commission Staff to
Idaho Power Company dated January 21, 2009, herewith submits the following
information:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 1
REQUEST NO.1: Please provide a table of current costs charged by Idaho
Power for overhead and pad-mounted transformers for all sizes and types typically used
for Schedule 1, 7, 9 and 24 customers. For each size and type of transformer, list the
number installed in 2007 and 2008.
SUPPLEMENTAL RESPONSE TO REQUEST NO.1: Costs charged by Idaho
Power for overhead and pad-mounted transformers are considered confidential
information and are available upon request at Idaho Power Company's corporate
offces. Please contact Doug Jones at 388-2615 or Camila Victoria at 388-5821 to
arrange a time to review the requested materiaL.
The response to this Request was prepared under the supervision of Scott
Sparks, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
, COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 2
REQUEST NO.2: Please provide a summary of service attachments made for
Schedule 1 customers for each of the years 2006 - 2008. In the summary, include at
least the following:
a. Total number of new residential line extensions;
b. Average actual cost for all service extensions;
c. Number of underground and overhead service cable installations;
d. Number of installations in which conduit was installed;
e. Number of transformers installed, whether pad mounted or overhead, and
their size rating;
f. Average number of customers per transformer;
g. Number of single and three phase installations;
h. Average length of service cable;
i. Number of meters by meter type and cost; and
j. Average cost of other incidental equipment.
SUPPLEMENTAL RESPONSE TO REQUEST NO.2: Information specific to the
Company's service attachments are collected, inputted, and stored in a Passport
database. Many of the data requested in Request No. 2 are not collected in this
database or are considered incomplete. The Company has made great efforts to be as
responsive as possible while supplying data that can be deemed reliable.
a. The number of new residential line extensions in 2006, 2007, and 2008
was 1,650; 1,380; and 830, respectively.
b. The average actual cost to Idaho Power of all service extensions is not
readily available and would require manually reviewing individual work orders.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 3
However, the estimated average cost to customers for all underground service
attachments is approximately $90 based on an assumed length of 85 feet charged at
$1.05 per foot. Since overhead services receive an allowance equal to the cost of
terminal facilties, no costs are associated with these service extensions.
c. The Company was not able to extract an accurate count of underground
and overhead service cable installations. However, based on Company experience and
assuming that 80 percent of all service installations are underground and 20 percent are
overhead, in 2006 the Company had approximately 9,825 underground and 2,456
overhead service cable installations. In 2007, approximately 5,758 were underground
and 1,440 overhead and in 2008 there were 2,493 underground and 623 overhead.
d. All underground installations require conduit. Please see above response
to letter c.
e. The Company does not track installed transformers by rate schedule;
however, please see the Response to Request NO.1 for a breakdown of installed
transformers by type and size.
f. The Company's standard engineering practice within most subdivisions is
to design each transformer to service 8 to 10 customers. In large lot subdivisions, the
Company designs for each transformer to serve 2 to 4 customers and, in rural locations,
1 transformer is typically installed for each customer.
g. Based on the Company's count of new Schedule 1 customers, the number
of single phase installations totaled 12,281 in 2006; 7,198 in 2007; and 3,116 in 2008.
The Company's Schedule 1 tariff allows for single phase installations only.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 4
h. A sampling of service cable length has established an estimated average
of 85 feet for new underground services and 100 feet for overhead services.
i. The number of new Schedule 1 customers in 2006, 2007, and 2008 was
12,281; 7,198; and 3,116, respectively. Residential customers most typically use a
standard watt-hour meter. Idaho Power's current cost for a watt-hour meter is
approximately $25.00.
j. There is no other incidental equipment of a significant value.
The response to this Request was prepared under the supervision of Scott
Sparks, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 5
REQUEST NO.3: Please provide a list of service attachments made for
Schedule 7, 9, and 24 customers for 2008. For each service attachment, include at
least the following:
a. . Actual cost of the service attachment;
b. Connected load in kW;
c. Whether service cable was underground or overhead;
d. Whether conduit was installed;
e. Whether transformer was installed, number and rating of transformers;
f. If transformer installed, was it overhead or pad mounted;
g. Whether single or three phase;
h. Length of service cable;
i. Meter type and cost; and
j. Cost of other incidental equipment.
SUPPLEMENTAL RESPONSE TO REQUEST NO.3: The information
requested is contained in more than 1,300 work orders. Idaho Power does not maintain
service attachment information at this level in a computerized database. To summarize
what it could, the Company queried the information in its Passport database system but
the results were incomplete. The requested data exists in paper work orders, but it
would be burdensome for Idaho Power to manually extract the data at the level Staff
requests. If Staff wishes to view the actual paper work orders, Idaho Power wil make
them available for review.
a. The Company's Passport database does not collect the actual costs of
service attachments. Nevertheless, the actual cost to customers for service
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 6
attachments under Schedules 7 and 24 is relatively small because the Company
provides an allowance for terminal facilties and many times this covers the full cost of
the service attachment. Customers requesting Schedule 9 three phase service
attachments pay a charge equal to 20 percent of the terminal facilities.
b. The data collected in the Company's database for connected kW is
incomplete.
c. Of the 2008 service attachments for Schedules 7,9, and 24, 613 were for
underground service cable and 711 were for overhead service cable.
d. All underground installations require conduit. Please see above response
to letter c.
e. Specific information regarding service attachments in which transformers
were installed is not readily available and would require manually reviewing
approximately 1,300 work orders. Reliable data specific to installed transformers
cannot be extracted from the Passport database.
f. Specific information regarding service attachments in which transformers
were installed is' not readily available and would require manually reviewing
approximately 1,300 work orders. Data detailing the combined number of overhead and
underground transformers installed is provided in the Response to Request NO.1.
g. The data collected in the Company's Passport database for single phase
and three phase transformers is incomplete. Information detailing overhead and
underground transformer installations is provided in Response to Request NO.1.
h. The length of service cable is not available in the Company's Passport
database. This information is only available on individual work orders.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 7
i. The meter type and cost for Schedules 7, 9, and 24 is not available in the
Passport database. This information is only available on individual work orders.
j. There is no other incidental equipment of a significant value.
The response to this Request was prepared under the supervision of Scott
Sparks, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho this 13th day of February 2009.
~ i7~.~ ~
iš.NORDSTÒM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of February 2009 I served a true and
correct copy of IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Building Contractors Association of
Southwestern Idaho
Michael C. Creamer
GIVENS PURSLEY, LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
City of Nampa AND
Association of Canyon County
Highway Districts
Matthew A. Johnson
Davis F. VanderVelde
WHITE PETERSON GIGRA Y
ROSSMAN NYE & NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, Idaho 83687
Kroger Co.
Michael L. Kurt
KurtJ. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
-2Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-X Email kris.sasser(§puc.idaho.gov
Hand Delivered
~U.S.Mail
_ Overnight Mail
FAX
.l Email mcc(§givenspursley.com
Hand Delivered~U.S.Mail
_ Overnight Mail
FAX
.l Email mjohnson(§whitepeterson.com
dvandervelde(§whitepeterson.com
Hand Delivered~U.S.Mail
_ Overnight Mail
FAX
.l Email mkurtz(§BKLlawfirm.com
kboehm(§BKLlawfirm.com
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMiSSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 9
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, Utah 84111
Hand Delivered
~U.S.Mail
_ Overnight Mail
FAX
-2 Email khiggins(§energystrat.com
11~
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
COMMISSION STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 10