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Home My WebLink About20090121Staff 1-30 to IPC.pdfKRISTINE A. SASSER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0357 BARNO. 6618 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorneys for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) AUTHORITY TO MODIFY ITS RULE H LINE ) EXTENSION TARIFF RELATED TO NEW ) SERVICE ATTACHMENTS AND ) DISTRIBUTION LINE INSTALLATIONS. ) ) CASE NO. IPC-E-08-22 FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilties Commission, by and though its attorney of record, Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company; Idaho Power) provide the following documents and information on or before WEDNESDAY, FEBRUARY 11, 2009. This Production Request is to be considered as continuing, and Idaho Power 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 produced. Please provide answers to each question and any supporting workpapers that provide detail or are the source of information used in calculations. The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name, location and phone number of the record FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 JANUARY 21,2009 holder and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228. In addition to the wrtten copies provided as response to the questions, please provide all Excel and electronic fies on CD with formulas activated. 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. REQUEST NO.2: Please provide a summar of service attchments made for Schedule 1 customers for each of the years 2006 - 2008. In the sumar, 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; 1. Number of meters by meter tye and cost; and J . Average cost of other incidental equipment. REQUEST NO.3: Please provide a list of service attachments made for Schedule 7, 9, and 24 customers for 2008. For each service attchment, include at least the following: a. Actul 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; 1. Meter type and cost; and J. Cost of other incidental equipment. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JANUARY 21,2009 REQUEST NO.4: Please provide an analysis for the cost of the Company's engineering fee. REQUEST NO.5: Please provide an analysis for the cost of temporary service attachment charge for underground and overhead, and for each service: a. How the Company determines the appropriate size of the crew for each type of service attachment; b. How the Company determines the amount of trip time; c. How the Company calculated the labor cost and what is included in that cost for each type of service attachment; d. If applicable, please provide the cost of each required material for each type of service attachment; e. A breakdown of costs showing how much of that price is travel cost, labor cost, material cost, or any other costs that contribute to the final proposed cost. REQUEST NO.6: Please provide an analysis for the cost of temporar retur trip charge and: a. How the Company determines the appropriate size of the crew for each type of service attachment; b. How the Company determines the amount of trip time; c. How the Company calculated the labor cost and what is included in that cost for each type of service attachment; d. If applicable, please provide the cost of each required material for each type of service attachment; e. A breakdown of costs showing how much of that price is travel cost, labor cost, material cost, or any other costs that contribute to the final proposed cost. REQUEST NO.7: Please provide an analysis for the cost of the underground retur trip charge and: a. How the Company determines the appropriate size of the crew for each type of service attchment; b. How the Company determines the amount of trip time; c. How the Company calculated the labor cost and what is included in that cost for each type of service attachment; d. If applicable, please provide the cost of each required material for each type of service attachment; e. A breakdown of costs showing how much of that price is travel cost, labor cost, material cost, or any other costs that contrbute to the final proposed cost. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JANUARY 21, 2009 REQUEST NO.8: Please provide an analysis for the cost of the underground service attachment charge's base charge from underground, overhead including 2" riser, and overhead including 3" riser, and for each service: a. How the Company determines the appropriate size of the crew for each type of service attchment; b. How the Company determines the amount of trip time; c. How the Company calculated the labor cost and what is included in that cost for each tye of service attchment; d. If applicable, please provide the cost of each required material for each tye of service attchment; e. A breakdown of costs showing how much of that price is travel cost, labor cost, material cost, or any other costs that contribute to the final proposed cost. REQUEST NO.9: Please provide an analysis for the cost of the distance charge (per foot) for Company installed facilties with 1/0 underground cable, 4/0 underground cable, and 350 underground cable, and for each service: a. How the Company determines the appropriate size of the crew for each type of service attchment; b. How the Company determines the amount of trp time; c. How the Company calculated the labor cost and what is included in that cost for each type of service attachment; d. If applicable, please provide the cost of each required material for each type of service attachment; e. A breakdown of costs showing how much of that price is travel cost, labor cost, material cost, or any other costs that contribute to the final proposed cost. REQUEST NO. 10: Please provide an analysis for the cost of the distance charge (per foot) for customer provided trench and conduit with 1/0 underground cable, 4/0 underground cable, and 350 underground cable, and for each service: a. How the Company determines the appropriate size of the crew for each type of service attachment; b. How the Company determines the amount of trip time; c. How the Company calculated the labor cost and what is included in that cost for each type of service attachment; d. If applicable, please provide the cost of each required material for each type of service attachment; e. A breakdown of costs showing how much of that price is travel cost, labor cost, material cost, or any other costs that contribute to the final proposed cost. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 JANUARY 21,2009 REQUEST NO. 11: Please provide data showing the number of vested interest refuds made during years 1,2,3,4, and 5 for 2007 and 2008. REQUEST NO. 12: Please describe what is meant by "administrative burden" as stated on p. 9, lines 20 - 21 of the testimony of Scott Sparks. REQUEST NO. 13: Please explain the process used by Idaho Power to qualify construction contractors who perform line extension construction work for the Company. In addition, please provide a list of contractors used by Idaho Power to perform line extension work. REQUEST NO. 14: For line extension construction work performed by contractors, please explain any competitive processes employed by the Company to insure that the costs to construct line extensions is minimized. REQUEST NO. 15: Please explain how Idaho Power determines whether a contractor or its own construction crews will be used for specific jobs. What percentage of construction jobs are completed by contractors in typical years? REQUEST NO. 16: In instances where a contractor constructs a line extension, are materials procured and provided by the contractor or by Idaho Power? Please explain. REQUEST NO. 17: In instances where a contractor constructs a line extension, are the overhead rates charged by Idaho Power different than if the work was completed by Idaho Power's own crews? Please explain. REQUEST NO. 18: Please explain any criteria or circumstaces under which Idaho Power solicits competitive bids for individual line extension jobs. Similarly, explain any criteria or circumstaces under which Idaho Power does not solicit competitive bids for individual line FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 JANUARY 21, 2009 extension jobs. Are there circumstances in which the same contractor is retained to perform multiple jobs without bidding on each job individually? REQUEST NO. 19: Are customers requesting new line extensions biled an amount based on a pre-construction estimate or based on a post-construction tabulation of the actual costs incured? If customers are biled based on estimates and there is a difference between the estimate and the cost actually incured, how is the difference reconciled, either for each customer individually or for all customers collectively? Explain any circumstaces in which costs charged to the customer are adjusted based on the actul costs incured by the Company. REQUEST NO. 20: Please explain any competitive process used by Idaho Power for purchasing major materials such as poles, transformers and conductor used in line extension construction. REQUEST NO. 21: Please discuss how Idaho Power can reassure customers that the costs charged to customers for line extensions are fair and reasonable. Discuss any competitive procurement practices, bidding practices, contractor selection methods, or other practices and processes that are employed by the Company. REQUEST NO. 22: If lot refuds in subdivisions are discontinued, please explain whether Idaho Power believes it will be at risk for recovering the cost of facilties installed in the subdivision if the subdivision does not fully build out. REQUEST NO. 23: Please provide a cost breakdown of$I,780 Standard Terminal Facilities allowance for single phase line installations and service attachments showing how much of that cost is the transformer, service conductor, etc. REQUEST NO. 24: Similarly, please provide a cost breakdown of $3,803 Standard Terminal Facilties allowance for three phase installations and service attchments showing how much of that cost is the transformer, service conductor, etc. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 6 JANUARY 21, 2009 REQUEST NO. 25: In the past, Idaho Power has used "time and motion" studies as the basis for establishing some of the costs used in preparng line extension estimates. Does Idaho Power stil use time and motion studies? If so, when was the last study prepared that the Company is using as a basis for cost estimates? Please provide a copy of pertinent sections of the study currently being used by Idaho Power. REQUEST NO. 26: Please provide a detailed explanation of the method used to determine the 15.75 percent charge for general overheads. Please provide any formulas, allocation factors and expenses used to calculate this percent. For expenses, please provide the associated FERC account numbers. REQUEST NO. 27: Please explain how general overheads are curently recovered. REQUEST NO. 28: When would Rule H overheads be expensed? REQUEST NO. 29: How are engineers' wages for Rule H projects recorded? Which FERC accounts are used? Which accounts are expensed or capitalized? REQUEST NO. 30: On a prior audit, Staff was told that some wood poles might be reused as temporary service poles. How are these poles accounted for in inventory? What is the charge for these poles under Rule H? Dated at Boise, Idaho, this il1! day of Januay 2009. ~~o..~'sthieASasser Deputy Attorney General Technical Staff: Rick Sterling TJ. Golo Daniel Klein John Nobbs i:umisc:prodreq/ipce08.22ksrpstjdk pr I.doc FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 7 JANUARY 21, 2009 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF JANUARY 2009, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-08-22, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: LISA D NORDSTROM BARTON L KLINE IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: Inordstrom(fidahopower.com bkline(fidahopower .com SCOTT SPARKS GREGORY SAID IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: ssparks(fidahopower.com gsaid(fidahopower .com JASON RISCH RISCH PISCA PLLC LAW AND POLICY 407 W JEFFERSON ST BOISE ID 83702 E-MAIL: irisch(frischpisca.com MATTHEW A JOHNSON DAVIS F VANDERVELDE WHITE PETERSON GIGRA Y ROSSMAN NYE & NICHOLS P.A. SUITE 200 5700 E FRANKLIN RD NAMPA ID 83687 E-MAIL: mjohnson(fwhitepeterson.com dvandervelde(fwhitepeterson.com MICHAEL L KURTZ ESQ KURT J BOEHM ESQ BOEHM KURTZ & LOWRY 36 E SEVENTH ST STE 1510 CINCINATI OH 45202 E-MAIL: mkurz(fBKLlawfrm.com kboehm(fBKLlawfirm.com KEVIN HIGGINS ENERGY STRATEGIES LLC PARKSIDE TOWERS 215 S STATE ST STE 200 SALT LAKE CITY UT 84111 E-MAIL: khiggins(fenergystrat.com ~.kt SECRETARY CERTIFICATE OF SERVICE