20090226Staff 31-35 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
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innq FEB 25 PM 2: 00
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
SECOND 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,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company;
Idaho Power) provide the following documents and information on or before THURSDAY,
MARCH 19,2009.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementar responses, additional documents that it or any person acting
on its behalf may later obtain that wil 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
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 FEBRUARY 26,2009
holder and if different the witness who can sponsor the answer at hearing if need be. Reference
IDAP A 31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 31: Please provide a copy of the time and motion study relied on by
Idaho Power as the source for the labor component of the Compatible Units used by the
Company in preparing cost estimates for line extensions. In addition, please answer the
following:
a. When was the study completed?
b. Who performed the study?
c. From whom did Idaho Power purchase or obtain the study?
d. Has the study ever been updated? If so, when?
e. Has Idaho Power adjusted or supplemented results from the study for use in its own
cost estimation system?
f. Did the study contain labor time estimates for the entire list of Compatible Units
currently used by Idaho Power, or has the Company assigned labor time estimates to
some Compatible Units based on its own judgment?
REQUEST NO. 32: Please explain the basis for the "vehicles" or "equipment"
component of line extension cost estimates. What is the source for the assumptions of
vehicle/equipment requirements and costs associated with the Compatible Units used for
preparing cost estimates for line extensions? Have vehicle/equipment requirements and costs
been changed or updated since Idaho Power's last major Rule H case in 1995? If so, please
explain how and when these assumptions and costs have changed and the basis for those
changes.
REQUEST NO. 33: In Request No. 20, Idaho Power was asked to explain any
competitive process used for purchasing major materials such as poles, transformers and
conductor used in line extension construction. The Company's response briefly discussed a
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 FEBRUARY 26, 2009
"strategic sourcing methodology" using a "total cost of ownership model approach."
Unfortunately, the Company's response does not describe any competitive processes in a way
that is understandable or meaningful to Commission Staff. Please supplement the Company's
original answer using explanations and terminology that would be readily understandable by a
typical Idaho Power customer. In your response, please specifically discuss at least the
following:
a. Please identify those materials used for line extensions that are procured through a
competitive process.
b. Please describe the competitive process for each major material group identified in
part a above. Describe specifically whether requests for proposals (RFPs) are used,
whether bids are required, the number of suppliers who bid on each major material
group, the frequency of RFP and bid processes (annual, biannual, etc.), the length of
any materials supply agreements, and any other process or practice that the Company
believescould provide assurance to customers that materials costs are reasonable.
REQUEST NO. 34: Please explain any process used by Idaho Power to reconcile
whether the actual line extension costs biled to customers are higher or lower than the actual
costs incurred by the Company, either for individual line extensions based ona sampling of jobs
or collectively over the course of a year. In other words, has Idaho Power ever done any analysis
to determine whether the practice of biling customers based on pre-construction estimates leads
to a systematic over-collection or under-collection of actual costs? If so, please provide a copy
of that analysis.
REQUEST NO. 35: Are the travel time assumptions used in preparing line extension
cost estimates specific to each job based on a customer's location and distance from a service
center, or are travel time assumptions standard for all customers and instead based on compatible
unit codes?
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 FEBRUARY 26, 2009
Dated at Boise, Idaho, this 2'r1 day of February 2009.
1i~a. ~d!t~Ašsser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce08.22ksrps pr 2.doc
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 FEBRUARY 26,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF FEBRUARY 2009,
SERVED THE FOREGOING SECOND 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: lnordstrom(iidahopower.com
bkline(ii dahopower .com
SCOTT SPARKS
GREGORY SAID
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: ssparks(iidahopower.com
gsaid(iidahopower .com
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: mcc(igivenspursley.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(iwhitepeterson.com
dvandervelde(iwhitepeterson.com
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurtz(iBKLlawfirm.com
kboehm(iBKLlawfirm.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(ienergystrat.com
~.KM,
SECRETARY
CERTIFICATE OF SERVICE