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Home My WebLink About20110912ICIP to IPC 64-73.pdfPet J. Richaon ISB # 3195 Grgory M. Adam ISB # 7454 RICHASON & O'LEARY PLLC 515 N. 27th Stret Boise, Idaho 83702 Telephone: (208) 938-2236 Fax: (208) 938-7904 peterrgcharsonandolear.com grgtächardsnadolear.com RECEIVED lOll SEP 12 PM 2: l 0 Attrneys for the Indusal Cuomer of Idao Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTR OF THE APPLICATION OF IDAHO POWER CONWANY FOR AUTHORITY TO INCRESE ITS RATES AND CHAGES FOR ELECTRIC SERVICE TO ITS CUSTOMES IN THE STATE OF IDAHO ) CASE NO. IPC-E-11-l8 ) ) SEVENTH REQUESTS FOR ) PRODUCTION OF THE ) INDUSTRIAL CUSTOMERS OF ) IDAHO POWER Puuat to Rule 225 of the Rules of Procedur of the Idaho Public Utilties Commssion (the "Commssion"), the Indusal Cusomer of Idao Power ("ICIP") herby request tht Idao Power Compay ("Idao Power" or the "Compay") provide responses to th followig with supprtg documents, where applicable. The response to ths prouction request is due on or before September 28,2011. Ths prouction request is to be COnsidered as continui, and Idao Power is reuested to provide by way of supplementa respnses additional documents that it or any person acting on its behaf may later obta tht will augent the responses or documents produced. Pleae provide electronic copies, or if unavailable a physical copy, to Mr. Richan and Mr. Ada at the addss noted above, and to Dr. Don Readg at: 6070 Hil Road, Boise, Idao 83703, Tel: (208) 342-1700; Fax: (208) 384-151 1; drading~dspring.com. For each item, pleae indicate the name of the persn(s) preparg the answer, along with the job title of such pen(s) and the witness at heag who can sponsor the answer. Some of the followig request may include disclosurs deemed by Idao Power to be confdential. Counsel and the expert witness for the Indusal Customers of Idao Power have executed the protective agreement to obta and us such materials accordg the te of tht ageement. SEVENTH REQUESTS FOR PRODUCTION OF TH ICIP IPC-E-l i -08 PAGE 2 REQUEST FQR PRODUCTION NO. 64 Refernce the Compay's Response to ICIP Request No. 45. (a) Please provide the Compay's records demonstig that the facilties chage ha been inplace since 1995 for Schedule 9, 1976 for Schedule 19, and 1964 for Schedule 29/Special Contrt. (b) Pleae explai how the Compay chaged customers for distbution facilties beyond the point of delivery prior to these dates for each schedule. REQUEST FQR PRODUCTION NO. 65 Refernce the Company's Respnse to ICIP Request No. 45, stting that the facilties chage has been in place since 1995 for Schedule 9, 1976 for Schedule 19, and 1964 for Schedule 29/Special Contrt. Plea reconcile ths sttement with Compy's Respnse to ICIP Request No. 25(b), stting that the oldest piece of equipment insled for Schedule 9 wa inled in 1969, for Schedule 19 wa instaled in 1945, and Compay's Response to ICIP Request No. 25(c), sttig that the Compay is stll calculating the monthy facilties charge by multiplying the monthy facilties charge pecentage by the intial investent for these pieces of equipment. For equipment alredy in the Company's possession at the time of commencement of thefacilties charge, did the Company use the value of the initial investment or the depreiated value of the equipment at the time of commencement of the facilties chage? Plea provide supportng evidence for the explantion. REQUEST FOR PRODUCTION NO. 66 With regar to the equipment discussed in Request No. 65, did the Company began charging the customer in Schedule 9 a facilties charge in 1995 based upon the intial investent in a piece of equipment instled in 1969, or did the Compay us the depreciated value of the 1969 piece ofequipment in 1995? Wht value did the Company us and baed on what depreiation schedule? REOUEST FOR PRODUCTION NO. 67 With regard to the equipment discussed in Request No. 65: (a) Did the Company began chargig the cusomer in Schedule 19 a facilties chage in 1976 baed upon the initial investent in a piece of equipment instled in 1945, or did the Company use the depreciated value of the 1969 piece of equipment in 1995? (b) What value did the Compay use and based on what depreciation schedule? Wht value is the Company using for ths piece of equipment today, the value at instalation in 1945, or the depreciated value when the charge commenced in 1976? SEVETH REQUESTS FOR PRODUCTION OF THE IClP IPC-E-II-08 PAGE 3 (c) Please explai why ths piece of equipment was not fuly depreciated at the time the Company initiated the facilties chage 3 i year af the equipment was intially instaled. (d) Pleae explai how the Compay ha not over-reover for ths fuly depreciated asset from the Schedule i 9 cusme since 1976? REQUEST FOR PRODUCTION NO. 68 Reference the Company's Response to ICIP Request Nos. 9, 10, 11, and 51. Pleae confrm despite the responses to these questons tht it is not the Compay's policy to sell distbuton facilties to cusomer, tht in Cas No. IPC-E-05-16 the Company sold distbuton facilties to the Sun Valley Company/Sinclai Oil Co. at depreciate bok value. Wht is the Company's policy? Pleae explain why the Company will sell facilties to one cusmer at book value but refus to sell to other customer at book value. REQUEST FOR PRODUCTION NO. 69 Referece the Company's Respons to ICIP Request No. 47(c), statig tht all cost for facilities instaled beyond the point of delivery ar included in the assoiated cusomer classes' revenue requiment, and when the facilties chage revenue is applied as a credit or offset, the associated cusomer classes' revenue requiment is reduced. (a) When the Compay includes the cost for distbution facilties beyond the point of delivery in the revenue requiment, does the Compay use a depreciation schedule as it mus for distrbution facilties on the Compay's side of the meter included in the revenue reuiement? Pleae explai how depreciation is consider when facilties beyond the point of delivery are included in the revenue requiment prior to the point tht the Company credits facilties chage revenue back to the cusomer class's revenue requirement. (b) If the amount of the revenue requirement decrees over tie to acunt for depreciation, but the principal amount of the facì1ties chage to the individua customer does not deceae over time, please explain how the individua facilties chage customer is not subsidizing the rest of the customer class. (c) If the amount of the revenue requiement does not decreas over time to account for depreciation of distbuton facì1ties beyond the point of delivery, pleae explain how the Compay is not over-reoverg for depreciate assets. REQUEST FOR PRODUCTION NO. 70 Please adt or deny th in meetings with reresentatives of the iCIP in the fall and witer of 2010 regarding the facilties charge, Idao Power reresentatives stted that the reaon the SEVENTH REQUESTS FOR PRODUCTION OF THE ICIP IPC-E-II-08 PAGE 4 Company does not apply a depreciation schedule to the initial investment in facilties chage equipment is that Idaho Power taes on the risk that it will have to replace a piece of failed equipment prior to expiration of its depreiation schedule. Pleae also adt or deny that Idao Power stated that its insurce policy would not cover replacement of such equipment. REQUEST FOR PRODUCTION NO. 71 Reference the Company's Response to ICIP Request No. 53(c), statig that the Compay reovers cost associated with unnsu amounts related to failed facilties chage equipment by booking those cost as expenses and including them in cusomer rates. In light of ths response~please explai the basis for not allowing for the facilities charge equipment's initial value to decrease over time as the piece of equipment depreciates. Please explai why the Compay includes depreciation as a positive component to the facilties charge tht will incree the amount the customer pays, rather th decreae it. REQUEST FOR PRODUCTION NO. 72 Reference the Company's Response to ICIP Request No. 57. Plea provide the "Servce Request Form." Pleae conf that the form is not provided to or signed by existig facilties charge customer, except with regar to new equipment instled at their premises. REQUEST FOR PRODUCTION NO. 73 Reference the Company's Response to ICIP Request No. 58. Please confrm that the Compay would recover the unsur cost of such equipment failing prior to expirtion of its 31-year depreiation schedule in the maner discusse in the Compay's Response to ICIP Request No. 53. Than you for your prompt attention to ths Seventh Request for Production. ly your, OJ ory Adas RICHASON & O'LEARY, PLLC SEVENTH REQUESTS FOR PRODUCTION OF THE ICLP IPC-E-I1-08 PAGE 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 7th day of September, 2011, a tre and corrt copy of thewithin and foregoing SEVENTH REQUESTS FOR PRODUCTION OF THE INDUSTRL CUSTOMERS OF IDAHO POWER IN CASE NO.IPC-E-11-08 was served in the maer shown to: Ms. Jean JewellCommsion Se Idao Public Utiities Commssion POBox 83720 Boise, il 83720-0074 _ Hand Delivery x. U.S. Mai, postage pre-pad Facsimile X Electrnic Mail Lisa D Nordstrm Jason B Willams Idaho Power Company POBox 70 Boise, Idaho 83707-0070 lnordtromcæidahopower.com i willamscæidahopower.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -Ã Electrnic Mail Donovan Walker Grg Said Idaho Power Company POBox 70 Boise, Idaho 83707-0070 dwalkeriglidaopower.com gsadcæidahopower.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile JLEleetnic Mail Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chaered P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 elo($cinelaw.net _Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electrnic Mail Anthony Yanel 29814 Lae Roa Bay Vilage, Ohio 44140 tony~yanei.net Hand Delivery _U.S. Mail, postge pre-pad Facsimle Ã- Electrnic Mail . l ~ It Donald L Howell, II Karl Klein Idaho Public Utilties Commssion 472 W Washigton Boise iD 83702 don.howell(ipuc.idaho.gov karl.kleìnißuc.idaho.gov _ Hand Delivery __ U.S. Mail, postage pre-paid Facsimile Ã- Electonic Mail Arur Perr Bruder US Deparent of Energy 1000 Independence Ave SW Washigton DC 20585 Artur .bruderWtq.doe.gov _ Hand Delivery __ U.S. Mail, postae pre-paid Facsimile X Electnic Mail Dwght Etheridge Exeter Associates, Inc. 5565 Sterrtt Place Ste 310 Columbia MD 2 i 044 detheridge(iexeterasociates.com _ Hand Delivery __ U.S. Mail, postge pre-paid Facsimile .- Electrnic Mail Steven A Porter Electrcity & Fossil Energy US Deparent of Energy steven.porteriß.doe.gov (email only) _ Hand Delivery __ U.S. Mail, postage pre-paid Facsimile .- Electrnic Mail John R Hamond Jr Batt Fisher Pusch & Alderman LLP PO Box 1308 Boise ID 83701 jrhW2battsher.com _ Hand Delivery __ U.S. Mail, postge pre-paid Facsimle .- Electrnic Mail KurJ Boehm Boehm Kur & Lowery 36 E Seventh St Ste 1510 Cincinati OH 45202 kboehm(ibkllawfrm.com _ Hand Delivery __ U.S. Mail, postage pre-paid Facsimle .- Electrnic Mail Brad M Purdy CAPA 2019 N 17th St Boise ID 83702 bmpury(ghotmaiL.com _ Hand Delivery __ U.S. Mail, postage pre-pad Facsimile x. Electonic Mail Richard E Malmgrn Micron Technology Inc 800 South Federa Way Boise ID 83716 re.inalmgrentImicron.com _ Hand Delivery __ U.S. Mail, poste pre-paid Facsimle X Electrnic Mail .. . ~ ,. Mar V York ThorvaldA Nelson Mark A Davidson Holland & Har 6380 Fiddlers Green Circle Ste 500 Greenwood Vilage CO 80111 myork~ollandhar.com tnelson~ollandhar.com madavidsonaghollandhar.com _ Hand Delivery _ U.S. Mail, postge pre-paid Facsimile X Electrnic Mail Benjamin Oto Idaho Conservation League POBox 844 Boise ID 83701 bottoagidaoconservation.org _ Hand Delivery _ U.S. Mail, poste pre-paid Facsimile X Electrnic Mail Ken Miler Snake River Alliance POBox 1731 Boise ID 83701 kmileragsnakerverliance.org _ Hand Delivery _ U.S. Mail, postge pre-paid Facsimile lectrnic Mail~ ory Adams