20160414ICIP 1-8 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Greg Adams (ISB 7454)
Richardson Adams, PLLC
515 N. 27n Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone]
Fa:r: [phone]
Peter@richardsorr*dol.*r. to*
Attorneys for the Industrial Customers of Idaho Power
ftECEIVED
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BEFORE TTM,
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO TRANSFER TITLE OF iMOBILE MANOR MOBILE HOME PARK i
CASENO. IPC-E-16-07
FIRST PRODUCTION REQUEST OF
THE INDUSTzuAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
METER PEDESTALS.//
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Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The lndustrial Customers of Ida]ro Power (*ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idatro Power Company
("Company") provide the following documents.
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 produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
ICIP First Production Request - IPC-E-I6-07
[phone]; Fax: (208) 3 84- I 5 I I ; [e-mail]
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
If some of the following requests include disclosures deerned by Idatro Power to be
confidential, the ICIP has already entered into ldaho Power's standard confidentiality agreement.
REOUEST FOR PRODUCTION NO. 1
Please provide all of the Company's discovery responses to all other parties regardless of
whether said requests for discovery were formal or informal.
REOUEST FOR PRODUCTION NO. 2
Rule Ml governs Idatro Power's arangements for the ownership, maintenance, cost
responsibility and transfer of Company owned facilities beyond the Point of Delivery for just
Schedule 9 and 19 customers. Please provide a copy of the Cornpany's policy, taritr,
understanding or other documentation of the arrangements for the ownership, maintenance, cost
responsibility and transfer of Company owned facilities beyond the Point of Deliver for all of the
other Idaho Power customer classes.
RBOUEST FOR PRODUCTION NO. 3
Please calculate the sales price for the transfer of Company owned assets Beyond the
Point of Delivery to the Mobile Manor using the same methodology used to calculate the sales
price to the FBI of Company owned assets Beyond the Point of Delivery used by the Company
in Docket No. IPC-E-15-26. Please provide copies of all calculations, workpapers and
documentation of said calculations.
t I.P.U.C No. 29, Tariff 101, Original Sheets No. M-l - M3.
ICIP First Production Request - IPC-E-l 6-07.
REOUEST FOR PRODUCTION NO. 4
Please provide a list, sorted by customer class, and include original cost and current net
book value, of all assets owned by the Company Beyond the Point of Delivery used to serve all
classes of customers including Schedules 9 and 19. For each class please quantify the revenue
received from each class of customer from Company owned facilities beyond the point of
delivery. Please provide a copy, or describe if not available in writing, of the Company's
policies for the arrangements for the ownership, maintenance, cost responsibility and transfer of
said assets. If the policies differ for different classes of customers please so state, and identify
which policy applies to each class of customers. tf the policies differ for different classes of
customers please provide documentation to the source of each policy and of the authority upon
which the Company relies to differentiate said policies by customer class.
REOUEST FOR PRODUCTION NO. 5
The Company's Application at page 3 provides, "Lastly, the property will no longer be
maintained in the public service." Please describe what is meant by the phrase "maintained in
the public service."
Please reconcile the statement that "the property will no longer be maintained in the
public service," with the statutory requirement, quoted on the same page of the Application, that
"[T]he applicant for such acquisition or transfer has the bona fide intent and financial ability to
operate and maintain said property in the public service."
REOUEST FOR PRODUCTION NO.6
The Company's Application at page 3 provides, "Upon approval of this transaction,
Mobile Manor's meter pedestals will become customer-owned, receiving similar treatment as
other customers." Please explain, in detail, how Mobile Manor is, in its proposed acquisition of
ICIP First Production Request - IPC-E-16-07
Idaho Power owned assets Beyond the Point of Delivery, is receiving similar treatment as do
Schedule 9 and 19 customers who acquire or seek to acquire ownership of ldatro Power owned
assets Beyond the Point of Delivery.
REOUEST FOR PRODUCTION NO. 7
The Company, in its Application at page 4, requests the Commission to process its
Application "by written submissions rather than by hearing." Please explain, and document, the
basis for the Company's understanding that the Commission may ignore the quoted portion of
the ldatro Code; to wit "the Commission 'shall conduct a public hearing on the application.' "
Is it Idatro Power's position that compliance with the quoted Idatro Code provision is
optional or subject to waiver by order of the Commission? Please explain.
REOUEST OF PRODUCTION NO. 8
Please reconcile the assertion in the Company's Application at page 3 that, "Mobile
Manor has significant financial interest in maintaining and operating the property," with the
requirement in the quoted section of the Idatro Code that, "The applicant . . . has the bona fide
intent and financial abilitv to operate and maintain said property..."2
Please explain whether, and if so on what basis, it is Idatro Power's understanding that
the having a "financial interest in maintaining" the property is equivalent to having the "financial
ability" to operate and maintain the property.
DATED this l4th day of April20l6.
2 Emphasis provided.
ICIP First Production Request - IPC-E-16-07
Richardson Adams, PLLC
Industrial Customers of tdaho Power
ICIP First Production Request - IPC-E-16-07.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l4th day of April,2016, a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER, iN DOCKET NO. IPC-E-I6-07 WAS
served as indicated below to:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P O Box 83720
Boise ID 83720-0074
Julia Hilton
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise,Idatro 83707
j [e-mail]
dockets@idahopower. com
Matt Larkin
Idaho Power Company
1221 West ldaho Steet
P.O. Box 70
Boise,Idaho 83707
mlarkin@ idahopower. com
X Hand Delivery
_ U.S. Mail, postage pre-paid
_ Facsimile
X_ Electronic Mail
_X Hand Delivery
_ U.S. Mail, postage pre-paid
_ Facsimile
_L Electronic Mail
X_ Hand Deliver
_U.S. Mail, postage pre-paid
FacsimileLElectronic Mail
6
Nina Curtis
Administrative Assistant
ICIP First Production Request - IPC-E-16-07