20160504Staff 1-22 to IPC.pdf

DAPHNE HUANG F,.ECEIVED
DEPUTY ATTORNEY GENERAL
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IDAHO BAR NO. 8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S REQUEST TO TRANSFER TrTLE ) CASE NO. rpC-E-16-07
oF MOBTLE MANOR MOBILE HOME PARK )
METER PEDESTALS ) FIRST PRODUCTION
) REQUEST OF THE) coMMrssroN STAFF To
) rDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Idaho Power Company (Company; Idaho
Power) provide the following documents and information as soon as possible, by
WEDNESDAY, MAY 18, 2016. I
This Production Request is 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 answers to each question, 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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-03 18.
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 4,2016
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. IDAPA
31.01.01.228.
In addition to the wriffen copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Individual addresses for each lot listed within the Application are not
adjacent to one another, but are instead a patchwork of lots on five separate streets. Please
describe the following with respect to the various pedestals in the area even though they are not
included within the application:
a. Does this application represent all lots within the Mobile Manor Mobile Home
Park?
b. If not, list those pedestals within the Mobile Manor Mobile Home Park which are
currently owned by:
i. Mobile Manor Mobile Home Park
ii. Idaho Power
iii. A third party customer of Idaho Power (i.e. not owned by Mobile Manor
Mobile Home Park)
REQUEST NO.2: If pedestals within the Mobile Manor Mobile Home Park are
currently owned by Mobile Manor Mobile Home Park or a third party customer of Idaho Power,
how was title to these pedestals conveyed?
REQUEST NO. 3: How many of the meter pedestals within the Mobile Manor Mobile
Home Park have been installed after March 31, 1981?
REQUEST NO. 4: Comparing the general condition of the meter pedestals within the
Mobile Manor Mobile Home Park, have some been previously updated/upgraded?
REQUEST NO. 5: After transfer of these 18 pedestals will Idaho Power retain
ownership of any remaining pedestals within the Mobile Manor Mobile Home Park?
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 4,20t6
REQUEST NO. 6: Who will complete the update/upgrade work?
REQUEST NO. 7: Will the completed work be inspected by a local building official?
REQUEST NO. 8: Is there a protective circuit breaker associated with each of the meter
pedestals?
REQUEST NO. 9: Provide a cost/benefit analysis and any other financial analysis that
was, or can be, used as a basis to transfer title of the meter pedestals to the Mobile Manor mobile
home park. This analysis would likely include replacement/upgrade costs, depreciation, and
maintenance expense. For any excel files, please also include within your response electronic
files with formulas intact.
REQUEST NO. 10: Was the cost for the original installation of these meter pedestals
charged to the mobile home park? Please explain.
REQUEST NO. 11: In the prior case filing IPC-E-93-19, Idaho Power requested
authority to institute a customer owned pedestal program that was later dismissed without
prejudice, Idaho Power indicated within the application that the customer would directly pay for
the cost to replace the meter pedestal. How does this prior case differ from Idaho Power's
approach to the current case?
REQUEST NO. 12: In the prior case filing IPC-E-93-19, Idaho Power indicated that in
July 1993, approximately 8,949 mobile home pedestals were owned and maintained by Idaho
Power. Currently, how many mobile home pedestals are owned and maintained by Idaho
Power?
REQUEST NO. 13: What criteria does Idaho Power's use to determine whether a meter
pedestal owned and maintained by the Company should be transferred to the customer?
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 4,2016
REQUEST NO. 14: What plan does Idaho Power have in transferring title of any
remaining Company owned and maintained meter pedestals to the customer?
REQUEST NO. 15: Please provide a schedule showing the plant in service by specific
plant account, original cost, current book value, current depreciation expense (including
percentage applied), and accumulated depreciation for the Mobile Manor Mobile Home Park
Meter Pedestals. Please include within your response electronic files with formulas intact.
REQUEST NO. 16: Please provide the proposed accounting entries recording the
transfer of the meter pedestals to Mobile Manor. Please reconcile the amounts contained in these
entries with the schedule provided in response to the previous production request.
REQUEST NO. 17: Please provide a detailed description and related documentation
(such as work orders, detailed estimates, or the like) that detail the costs Idaho Power expects to
incur for the upgrades mentioned on page 2 of the Application. Please provide documentation
for the entirety of the upgrades (including completion timelines) and any other related costs
(including timing) associated with this transfer.
REQUEST NO. 18: Please provide the accounting treatment and proposed accounting
entries recording the upgrades and any other related costs associated with this transfer.
REQUEST NO. 19: Please provide the annual costs to maintain (O&M) the meter
pedestals the Company is planning to transfer under this Application. Please provide within your
response the documentation (work orders, invoices, or the like) used to calculate this amount.
REQUEST NO.20: Please provide a schedule showing the plant in service by specific
plant account, original cost, current book value, current depreciation expense (including
percentage applied), and accumulated depreciation for other mobile home courts' meter pedestals
that pre-date the March 31, 1981, Rule H General Provisions related to mobile home courts.
Please include within your response electronic files with formulas intact.
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 4,2016
REQUEST NO. 21: Please identify the amount included in rates for the costs to
maintain the meter pedestals that pre-date the March 3 1, 1981, Rule H General Provisions related
to mobile home courts. Please identify and include the source of the information and segregate
and/or allocate these costs between Mobile Manor pedestals and the remaining mobile home
courts' pedestals owned by Idaho Power. Please include within your response electronic files
with formulas intact.
REQUEST NO. 22: Please provide the analyses performed and documentation obtained
to demonstrate and insure that Mobile Manor has the "financial ability to operate and maintain
said property in the public service" as required by Idaho Code $ 6l-328(3).
,{9 day orMay 2016.Dated at Boise, Idaho, this
Technical Staff: Rick Kellerll-L4
Patricia Harmsll5-22
i :umisc:prodreq/ipce I 6.Tdjhrkph prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 4,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY oF MAY 2016, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER IN CASE NO. IPC-E-16-07, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A. HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
PETER J zuCHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail : peter@richardsonadams. com
sre s@.richardsonadams.com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
DR DON READINU
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
CERTIFICATE OF SERVICE