20160518IPC to Staff 1-22.pdf

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JULIAA. HILTON
Senior Counsel
[e-mail]
May 18,2016
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
Transferof Mobile Manor Mobile Home Park Meter Pedestals-ldaho Power
Company's Response to the First Production Request of the Commission
Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Staffs production requests.
JAH:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
Very truly yours,
Jdia A. Hilton
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 ilton@ idahopower. com
I n ord strom @ ida h opowe r. com
Attorneys for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S REQUEST TO TRANSFER
TITLE OF MOBILE MANOR MOBILE
HOME PARK METER PEDESTALS
i:tECEIVED
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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 COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated May 4,2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: lndividua! 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. lf not, list those pedestals within the Mobile Manor Mobile Home Park
which are currently owned by:
i. Mobile Manor Mobile Home Park
ii. ldaho Power
iii. A third party customer of ldaho Power (i.e. not owned by Mobile
Manor Mobile Home Park)
RESPONSE TO REQUEST NO. 1:
a. No. Lots within Mobile Manor mobile home park ("Mobile Manor") can be
owned by individuals. The Application represents all lots owned by Kathleen C. Parrish
("Parrish").
b. Currently, all meter pedestals within Mobile Manor are owned by ldaho
Power.
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 COMMISSION STAFF - 2
REQUEST NO. 2: lf pedestals within the Mobile Manor Mobile Home Park are
currently owned by Mobile Manor Mobile Home Park or a third party customer of ldaho
Power, how was title to these pedestals conveyed?
RESPONSE TO REQUEST NO. 2: Currently, all meter pedestals within Mobile
Manor are owned by ldaho Power.
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 COMMISSION STAFF - 3
REQUEST NO. 3: How many of the meter pedestals within the Mobile Manor
Mobile Home Park have been installed after March 31, 1981?
RESPONSE TO REQUEST NO. 3: No meter pedestals within Mobile Manor
have been installed after March 31, 1981.
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 COMMISSION STAFF - 4
REQUEST NO. 4: Comparing the general condition of the meter pedestals
within the Mobile Manor Mobile Home Park, have some been previously
updated/upgraded?
RESPONSE TO REQUEST NO. 4: ldaho Power has not replaced any of the
meter pedestals within Mobile Manor since they were installed, but normal maintenance
may have occurred.
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 COMMISSION STAFF - 5
REQUEST NO. 5: After transfer of these 18 pedestals will ldaho Power retain
ownership of any remaining pedestals within the Mobile Manor Mobile Home Park?
RESPONSE TO REQUEST NO. 5: Yes. ldaho Power will retain ownership of
approximately 114 meter pedestals within Mobile Manor after the transfer of the 18
meter pedestals to Parrish because some of the lots within Mobile Manor are owned by
different individuals.
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 COMMISSION STAFF - 6
REQUEST NO. 6: Who will complete the update/upgrade work?
RESPONSE TO REQUEST NO. 6: ldaho Power will complete the
update/upgrade work.
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 REOUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 7: Will the completed work be inspected by a local building
official?
RESPONSE TO REQUEST NO. 7: The completed work will be inspected by a
loca! electrical inspector.
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 COMMISSION STAFF - 8
REQUEST NO. 8: ls there a protective circuit breaker associated with each of
the meter pedestals?
RESPONSE TO REQUEST NO. 8: Yes, each pedestal has its own circuit
breaker.
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 COMMISSION STAFF - 9
REQUEST NO. 9: Provide a cosUbenefit 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
replacemenUupgrade costs, depreciation, and maintenance expense. For any excel
files, please also include within your response electronic files with formulas intact.
RESPONSE TO REQUEST NO. 9: A cosUbenefit or other financial analysis was
not performed for the specific transfer of title of meter pedestals within Mobile Manor to
Parrish. ln transferring meter pedestals to customers, ldaho Power relies upon the
analyses performed by the Company prior to filing its application in Case No.
IPC-E-93-19. Prior to filing the application in that case, the Company was spending at
least $41,000 annually in labor and vehicle charges to maintain these pre-1981 meter
pedestals. This is primarily due to the difficulty of finding replacement parts necessary
to maintain these older pedestals.
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 COMMISSION STAFF - 1O
REQUEST NO. 10: Was the cost for the origina! installation of these meter
pedestals charged to the mobile home park? Please explain.
RESPONSE TO REQUEST NO. 10: No.
The response to this Request is sponsored by Courtney Waites,
Regulatory Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. 11: ln the prior case filing IPC-E-93-19, ldaho Power requested
authority to institute a customer owned pedestal program that was Iater dismissed
without prejudice, ldaho 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 ldaho Power's approach to the current case?
RESPONSE TO REQUEST NO. 11: At the time Case No. !PC-E-93-19 was
filed, ldaho Power was proposing a pedestal conversion program that would have
resulted in the Company upgrading all associated meter pedestals upon Idaho Public
Utilities Commission ("Commission") approval, with the customers responsible for the
cost of the pedestal upgrades.
ldaho Power's current approach to transfer title of meter pedestals is to update
the pedestals prior to the transfer when the opportunity arises through the normal
course of business.
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 COMMISSION STAFF - 12
REQUEST NO. 12: ln the prior case filing IPC-E-93-19, ldaho Power indicated
that in July 1993, approximately 8,949 mobile home pedestals were owned and
maintained by ldaho Power. Currently, how many mobile home pedestals are owned
and maintained by ldaho Power?
RESPONSE TO REQUEST NO. 12: ldaho Power's asset records indicate a
total of 8,833 Company-owned meter pedestals.
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 COMMISSION STAFF - 13
REQUEST NO. ,l3: What criteria does ldaho Power's use to determine whether
a meter pedestal owned and maintained by the Company should be transferred to the
customer?
RESPONSE TO REQUEST NO. 13: ldaho Power seeks to transfer title of
Company-owned pedestals to customers when the opportunity arises through the
normal course of business. This occurs most often when mobile home park owners
request to upgrade 100 amp pedestals to 200 amp pedestals to meet newer standards.
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 COMMISSION STAFF - 14
REQUEST NO. 14: What plan does ldaho Power have in transferring title of any
remaining Company owned and maintained meter pedestals to the customer?
RESPONSE TO REQUEST NO. 14: The Company plans to continue its practice
of proposing the transfer of title of meter pedestals to customers as the opportunity
arises in the normal course of business, as detailed in the Company's response to
Commission Staffs ("Staff') Request No. 13.
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 REOUEST OF THE COMMISSION STAFF. 15
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.
RESPONSE TO REQUEST NO. 15: ldaho Power does not maintain property
accounting records at the detailed level requested. However, please see the
Company's response to Staffs Request No. 20 for a schedule identifoing all meter
pedestals with a vintage year of 1981 or earlier, including original cost, current book
value, current depreciation expense, and accumulated depreciation.
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 COMMISSION STAFF - 16
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.
RESPONSE TO REQUEST NO. 16: The following proposed entries will record
the removal, upgrade, and transfer of the meter pedestals and associated equipment to
Parrish. To estimate the retirement amount associated with Parrish's existing meter
pedestals, ldaho Power multiplied the unit cost of the vintage year 1980 meter
pedestals by 18, for an estimated retirement of $1,848.93. Final dollar amounts for the
remaining entries cannot be determined untilthe work is complete.
108000 Accumulated Provision for Depreciation $1,848.93
101000 Electric Plant in Service $1,848.93
To record the retirement of old meter pedestals and associated equipment.
108000 Accumulated Provision for Depreciation $XXX
131201 Cash $XXX
To record costs to remove old meter pedestals and associated equipment.
107000 Construction Work in Progress $XXX131201 Cash $XXX
To record costs to install new meter pedestals and associated equipment.
101000 Electric Plant in Service $XXX107000 Construction Work in Progress $XXX
Close work order costs to plant for new meter pedestals and associated
equipment.
108000 Accumulated Provision for Depreciation $XXX101000 Electric Plant in Service $XXX
To record meter pedestals transferred/retired to Parrish.
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 COMMISSION STAFF - 17
REQUEST NO. 17: Please provide a detailed description and related
documentation (such as work orders, detailed estimates, or the like) that detail the costs
ldaho 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.
RESPONSE TO REQUEST NO. 17: Please see the document provided on the
enclosed CD for a detailed description of the expected upgrade costs. ldaho Power's
estimate of total costs associated with the meter pedestal upgrades that the Company
expects to incur is approximately $1,700 per meter pedestal. The only item within the
document for which ldaho Power proposes to transfer title is the meter pedestal
described as F/MFG'D HOME 200A MT with an estimated cost of $454.45. The other
estimated costs include labor charges and upgrades to other Company-owned items
associated with the upgrades to the meter pedestals. The following is an explanation of
the Detailed Cost Elements (DCEs) identified in the cost estimate:
o 111 - Straiqht time payroll (includinq flexible time ofR. An employee's
normal wage based upon job classification.
. 211 - Materials issued from inventorv. lnventory issues and returns that*e ,*d in tf* construction or maintenance of the Company's
physical plant.
o 521- Company vehicles and equipment. The costs of using a Company-
owned vehicle or piece of equipment.
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 COMMISSION STAFF. 18
REQUEST NO. 18: Please provide the accounting treatment and proposed
accounting entries recording the upgrades and any other related costs associated with
this transfer.
RESPONSE TO REQUEST NO. 18: Please see the Company's response to
Staff's Request No. 16 for the proposed accounting entries to record the upgrades
associated with the transfer of the meter pedestals.
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 COMMISSION STAFF - 19
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.
RESPONSE TO REQUEST NO. 19: ldaho Power does not track the operations
and maintenance ("O&M') specifically associated with meter pedestals by location.
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 COMMISSION STAFF - 20
REQUEST NO. 20: PIease 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.
RESPONSE TO REQUEST NO. 20: Please see the Excel file provided on the
enclosed CD for a schedule showing the original cost, accumulated depreciation,
current book value, and depreciation expense associated with meter pedestals that
predate 1982. Please note, the Company does not track vintage year by month so
ldaho Power has included all meter pedestals with a vintage year 1981. Also, vintage
year 1980 includes 1954 through 1980 because data conversions within the Company's
accounting software consolidated all distribution line equipment with those vintage
years.
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 COMMISSION STAFF - 21
REQUEST NO. 21: Please identify the amount included in rates for the costs to
maintain the meter pedestals that pre-date the March 31, 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 ldaho Power. Please
include within your response electronic files with formulas intact.
RESPONSE TO REQUEST NO. 21: Idaho Power does not track the O&M
specifically associated with meter pedestals. O&M related to meter pedestals is
charged to a generalfeeder maintenance work order.
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 COMMISSION STAFF - 22
REQUEST NO. 22: Please provide the analyses performed and documentation
obtained to demonstrate and insure that Mobile Manor has the "financia! ability to
operate and maintain said property in the public service" as required by ldaho Code
s 61-328(3).
RESPONSE TO REQUEST NO. 22: ldaho Power did not perform an analysis to
demonstrate that Parrish has the financial ability to operate and maintain the pedestals
in the public service. The transfer of title will allow Parrish, as owner of the lots, the
ability to operate and maintain the meter pedestals herself for her tenants. The meter
pedestals wil! no longer be maintained by ldaho Power in the public service and will be
treated in a manner similar to meter bases for other residential customers.
Once upgraded, these new meter pedestals are expected to have a 60-year life
span with minimal maintenance expected over the life of the asset, resulting in minimal
costs to Parrish for ownership of the pedestals. Because of the anticipated immaterial
maintenance costs and Parrish's financial interest in maintaining the meter pedestals,
ldaho Power presumes Parrish wil! have the financial ability to operate and maintain the
Mobile Manor pedestals for her tenants, or in the public service.
The response to this Request is sponsored by Courtney Waites, Senior
Regulatory Analyst, ldaho Power Company.
DATED at Boise, tdaho, this 18th day of May 2016.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 23
for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of May 2016 t served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash ington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Kathleen C. Parrish
Craig W. Parrish
PARRISH LAW OFFICE
239 North 8th Avenue
P.O. Box 4321
Pocatello, ldaho 83205
lndustrial Customers of Idaho 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
X Email [e-mail]
Hand DeliveredX U.S. Mail
Overnight Mail
FAX
Email cra iqwpa rrish@ lawyer. com
Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
q req@richardsonadams. com
Hand Delivered
U.S. Mai!
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.24
Ghrista Bebrry, Legal