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May 16, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-16-07
Transfer of Mobile Manor Mobile Home Park Meter Pedestals - ldaho Power
Company's Response to the First Production Request of the lndustrial
Customers of ldaho Power
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an originaland three (3) copies of
ldaho Power Company's Response to the First Production Request of the Industrial
Customers of ldaho Power.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to the lndustrial Customers of ldaho Power's production requests.
Very truly yours,
a4rL97^/-t-',*
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho 5t. (83702)
P.O. Box 70
Boise, lD 83707
JULIA A. HILTON (lSB No. 7740)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
i h i lton@ ida hopower. com
I no rd strom @ ida h opowe r. com
Attorneys for ldaho Power Company
!N THE MATTER OF IDAHO POWER
COMPANY'S REQUEST TO TRANSFER
TITLE OF MOBILE MANOR MOBILE
HOME PARK METER PEDESTALS
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-16-07
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE I NDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, Idaho Power Company ("ldaho Powed' or "Company"), and in
response to the First Production Request of the lndustrial Customers of Idaho Power to
ldaho Power Company dated April 14, 2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: To date, ldaho Power
has not provided any responses to discovery in this case. As a matter of course, copies
of ldaho Power's responses to all parties' discovery requests in this case will be
provided to the lndustrial Customers of ldaho Power.
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 2: Rule M1 governs ldaho Power's
arrangements 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 Company's policy, tariff, 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 ldaho Power customer classes.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: ldaho Power does not
have any policies or tariffs in place for the ownership, maintenance, cost responsibility,
and transfer of Company-owned facilities beyond the point of delivery other than
Rule M.
The response to this Request is sponsored by Zach Harris, Regulatory Analyst,
ldaho Power Company.
' l.P.U.C No. 29, Tariff 101, Original Sheets No. M-l- M3.
IDAHO POWER COMPANY'S RESPONSE TO THE F]RST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER.3
REQUEST 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: ldaho Power believes it
is important to note two incorrect assumptions contained in the premise of this Request.
First, the assets being transferred are not being transferred to the Mobile Manor mobile
home park ("Mobile Manor"); they are being transferred to Kathleen Parrish ("Parrish"),
who owns several lots within the park. And second, the assets being transferred are not
assets beyond the point of delivery; the assets are the point of delivery.
It is not possible to calculate the sales price for the transfer of Company-owned
assets to Kathleen Parrish in a manner consistent with the methodology used to
calculate the sales price to the Federal Bureau of lnvestigation ("FBl") of Company-
owned assets beyond the point of delivery. The assets that are to be transferred to
Parrish are not under a facilities charge arrangement; therefore, various components of
the FB! sale methodology, such as a true-up of the levelized return component, are
impossible to compute.
The response to this Request is sponsored by Zach Harris, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER .4
REQUEST 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. lf the policies differ for different classes of
customers please so state, and identify which policy applies to each class of customers.
lf 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the
Distribution Facilities Report for April 2016 provided on the enclosed CD (Attachment 1).
The net book value is not provided because it is not readily available and would require
an extraordinary amount of time to produce.
Please see the spreadsheet provided on the enclosed CD (Attachment 2) that
quantifies the revenue received from each class of customer from Company-owned
facilities beyond the point of delivery.
As explained in the Company's response to the lndustrial Customers of ldaho
Power's Request for Production No. 2, the Company does not sell and transfer
Company-owned facilities beyond the point of delivery for classes other than customers
subject to Rule M. Rule M applies to customers taking Primary or Transmission Service
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
under Schedules 9, 19, or Special Contract, or Transmission Service under Schedule
24. Section 3 of Rule M describes the provisions that must be met for the sale of
Company-owned facilities installed beyond the point of delivery. The Company's Rule
M is available via the following !ink:
https://www.idahopower.com/AboutUs/RatesRequlatory/Tariffs/tariffPDF.cfm?id=303.
The response to this Request is sponsored by Zach Harris, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST 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."
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: One of the
requirements of ldaho Code S 61-328 is that before authorizing the transfer of
ownership of property used in the generation, transmission, distribution, or supply of
electric power and energy to the public, the ldaho Public Utilities Commission
("Commission") shall find that the applicant for the transfer has the bona fide intent and
financial ability to operate and maintain the property in the public service. Because the
meter pedestals included in the transfer agreement predate 1981, the Company
currently owns the meter pedestals and Mobile Manor lot owners rely on ldaho Power to
perform repairs and manufacture replacement parts to keep the pedestals operational.
Therefore, ldaho Power currently maintains the meter pedestals in the public service.
The transfer of title of the meter pedestals will allow Parrish, as the owner of the lots,
the ability to operate and maintain the meter pedestals herself for her tenants. The
Company stated in the Application that "the property will no longer be maintained in the
public service" because Idaho Power will no longer be maintaining the meter pedestals;
instead, Parrish will maintain the meters for her tenants, or in the public service.
The response to this Request is sponsored by Courtney Waites, Senior
Regulatory Analyst, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 6: The Company's Application at page 3
provides, "Upon approva! of this transaction, Mobile Manor's meter pedestals will
become customer-owned, receiving similar treatment as other customers." Please
explain, in detai!, how Mobile Manor is, in its proposed acquisition of ldaho 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 ldaho Power
owned assets Beyond the Point of Delivery.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The referenced portion
of the Application compared Mobile Manor's meter pedestals and the meters of other
residential customers. There is no comparison between the transfer of title for the
meter pedestals to Parrish and Schedule 9 and 19 customers who seek to acquire
ownership of ldaho Power assets beyond the point of delivery.
The response to this Request is sponsored by Courtney Waites, Senior
Regulatory Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER. S
REQUEST 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 ldaho Code; to
wit "the Commission 'shall conduct a public hearing on the application.' "
ls it ldaho Power's position that compliance with the quoted ldaho Code provision
is optional or subject to waiver by order of the Commission? Please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: As stated in the
Application, ldaho Power stands ready to present testimony and support the Application
in a hearing should the Commission determine a technical hearing is required. lt is not
ldaho Power's position that compliance with the above-quoted ldaho Code provision is
optional or subject to waiver by order of the Commission.
The response to this Request is sponsored by Courtney Waites, Senior
Regulatory Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUGTION NO. 8: Please reconcile the assertion in the
Company's Application at page 3 that, "Mobile Manor has significant financial interest in
maintaininq and operating the property," with the requirement in the quoted section of
the ldaho Code that, "The applicant . . . has the bona fide intent and financial abilitv to
operate and maintain said property. . ."'
Please explain whether, and if so on what basis, it is ldaho 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: ldaho Power's
assertion in the Company's Application at page 3 that "Mobile Manor has significant
financial interest in maintaining and operating the property" is related to Parrish's bona
fide intent to operate and maintain the meter pedestals, not her financial ability to
operate and maintain the meter pedestals.
The response to this Request is sponsored by Courtney Waites, Senior
Regulatory Analyst, ldaho Power Company.
DATED at Boise, ldaho, this 16th day of May 2016.
2 Emphasis provided.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1O
Attorney for Idaho Power Company
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 16th day of May 2016 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Dep uty Attorney General
ldaho Public Utilities Commission
47 2 W est Wash ington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Mobile Manor Mobile Home Park
Craig W. Parrish
PARRISH LAW OFFICE
239 North 8th Avenue
P.O. Box 4321
Pocatello, ldaho 83205
lndustrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
X Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email daphne. huanq@puc. idaho.oov
Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
Overnight Mail
FAXX Email [e-mail]
g reo@ richard sonadams. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAX
Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11