20110901Staff to IPC 184-195.pdf

DONALD L. HOWELL, II
KARL T. KLEIN
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NOS. 3366/5156
RECE~!VFDJJ ....1,-
1011 SEP -I PH 3: 26
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 INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE IN IDAHO. )
)
)
)
CASE NO. IPC-E-11-8
THIRTEENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Donald L. Howell, II and Karl T. Klein, Deputy Attorneys General, requests that Idaho
Power Company (Company; IPC) provide the following documents and information as soon as
possible, but no later than THURSDAY, SEPTEMBER 22, 2011.
This Production Request is to be considered as continuing, and the 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, and the name, job title and telephone number of
the person preparng the documents. Please identify the name, job title, location and telephone
number of the record holder.
THIRTEENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 SEPTEMBER 1, 2011
In addition to the wrtten copies provided as response to the requests, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 184: In response to Staffs Production Request No. 89 d, BLM rate
increase-land rents, the Company states "amounts are based on the new Federal rent schedules
and the Zone schedule changes. The many different grants included in this total have contracts
at various stages of completion." Please provide a copy of the schedules and contracts referred
to in this response.
REQUEST NO. 185: In reference to Company witness Jones' Exhibit No. 15, pages
2 - 3 of 10, please provide the workpapers supporting this exhibit. Specifically, for each item
listed under contributions and memberships, please provide the backup detail for each
transaction that makes up each line number. For example, line 73 has a lump sum amount of
$12,403 under the heading, "Chamber of Commerce Donations/Contributions/Sponsorship."
Please provide a list with the individual transactions with dates, organization, description, and
the corresponding dollar amounts that totals the $12,403 for this line. Please provide this level of
detail for all items in Exhibit No. 15, pages 2-3 of 10.
REQUEST NO. 186: Please explain how the P-card transactions are spread to the
FERC accounts.
REQUEST NO. 187: Please explain why P-card transactions are posting to Account
No. 108, accumulated depreciation.
REQUEST NO. 188: Please provide a schedule showing all items in P-card purchases
for pary activities, celebrations, gifts, rewards, dues, donations and political activities. Show
where these are moved below-the-line.
REQUEST NO. 189: Please provide a schedule calculating the proposed 22% Overhead
Rate for Rule H as discussed in the testimony of Scott Sparks. Please also provide supporting
workpapers and documents.
THIRTEENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 SEPTEMBER 1,2011
REQUEST NO. 190: Please provide a schedule breaking out the Low Income
Weatherization amounts by account by month for 2005 through 2011 to date.
REQUEST NO. 191: Please document the customer benefits and all leverage obtained
by amounts paid to Civic Organizations.
REQUEST NO. 192: In response to Staffs Production Request No. 68, the Company
has stated that 157 accounts were rebiled in 2010. How many of those customers were rebiled
for additional dollars due to an underbiling - and how many were refuded dollars due to an
overbillng? Please provide this information by the number of months for which the customer
was rebiled, the dollar amount of the rebiling (noting whether the customer was debited or
credited) and the rate class for those rebiled accounts.
REQUEST NO. 193: In response to Staffs Production Request No. 73, the Company
stated that a $49 fee was collected from customers who requested an energy audit as part of the
Boise Home Audit project. Who receives this $49 payment: Idaho Power, Boise City or the
contractor who performs the energy audit?
REQUEST NO. 194: Please explain and quantify the increase in expenses since the
Company's last general rate case as booked in Account No. 903, Customer Records and
Collections.
REQUEST NO. 195: Please explain and quantify the increase in uncollectable accounts
since the Company's last general rate case as booked in Account No. 904, uncollectable
accounts. Please describe steps taken by the Company to address and reduce uncollectables.
Please provide a breakdown of the 2010 and 2011 YTD uncollectable expense by rate schedule.
THIRTEENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 SEPTEMBER 1,2011
DATED at Boise, Idaho, this L 6~ day of September 2011.
(l ,; 'JL
Karl T. Klein
Deputy Attorney General
Technical Staff: Shelby Baker/184
Kathy Stockton/185 - 187
Terri Carlock/188 - 191
Marilyn Parker/192 - 193
Beverly Barker/194 - 195
i:umisc:prodreq/ipcel 1 .8dhkk prod req 13
THIRTEENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 SEPTEMBER 1, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF SEPTEMBER 2011,
SERVED THE FOREGOING THIRTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-I1-08, BY
E-MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
DONOV AN E WALKER
JASON B WILLIAMS
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: lnordstromtiidahopower.com
dwalkertiidahopower .com
jwillamstiidahopower .com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: petertirichardsonandolear.com
gregtirichardsonandoleary.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elotiracinelaw.net
ARTHUR PERRY BRUDER
ATTORNEY -ADVISOR
US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: Arhur.brudertihq.doe.gov
GREGORY W SAID
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: gsaidtiidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadingtimindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tonytiyaneI.net
DWIGHT ETHERIDGE
EXETER ASSOCIATES
10480 LITTLE PATUZENT PKWY
STE 300
COLUMBIA MD 21044
E-MAIL: detheridgetiexeterassociates.com
CERTIFICATE OF SERVICE
E-MAIL ONLY:
STEVE A PORTER
US DEPT OF ENERGY
E-MAIL: steven.porteriihq.doe.gov
KURT JBOEHM
BOEHM KURTZ & LOWERY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: kboehmiibkllawfrm.com
E-MAIL ONLY:
RICHARD E MALMGREN
SR ASST GENERAL COUNSEL
MICRON TECHNOLOGY INC
E-MAIL: remalmgreniimicron.com
E-MAIL ONLY:
THORV ALD A NELSON
MARK A DAVIDSON
FRED SCHMIDT
HOLLAND & HART LLP
E-MAIL: tnelsoniihollandhar.com
madavidsoniihollandhar.com
fschmidtiihollandhar.com
lnbuchananiihollandhar.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: bottoiiidahoconservation.org
NANCY HIRSH
POLICY DIRECTOR
NW ENERGY COALITION
811 1ST AVE., SUITE 305
SEATTLE WA 98104
E-MAIL: nancyiinwenergy.org
E-MAIL ONLY:
JOHN R HAMMOND JR
BATT FISHER PUSCH
& ALDERMAN LLP
E-MAIL: jrhiibattfisher.com
KEVIN HIGGINS
ENERGY STRATEGIES
215 S. STATE ST SUITE 200
SALT LAKE CITY UT 84111
E-MAIL: khigginsiienergystrat.com
ELECTRONIC/ CD/ PAPER SERVICE
MARY V YORK
HOLLAND & HART LLP
101 S. CAPITAL BLVD., SUITE 1400
BOISE,ID 83702
E-MAIL: myorkiihollandhar.com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyiihotmaiI.com
KEN MILLER
SNAKE RIVER ALLIANCE
BOX 1731
BOISE ID 83701
E-MAIL: kmileriisnakeriverallance.org
MARY V YORK
HOLLAND & HART LLP
10 1 S CAPITAL BLVD
STE 1400
BOISE ID 83702
E-MAIL: myorkiihollandhar.com
CERTIFICATE OF SERVICE
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joeiimcdevitt-miler.com
heatheriimcdevitt -miler .com
SCOTT PAUL CEO
HOKU MATERIALS INC
ONE HOKU WAY
POCATELLO ID 83204
E-MAIL: spauliihokucorp.com
03~.)(ak
SECRETARY
CERTIFICATE OF SERVICE