20180518Staff 1-2 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.5156
IN THE MATTER OF THE PETITION OF THE )
IDAHO DEPARTMENT OF ADMINISTRATION )
FOR AN EXEMPTTON FROM THE rDAHO )
PUBLIC UTILITIES COMMISSION'S MASTER. )
METERING RULES FOR ELECTRIC )
UTILITIES AND THE IDAHO POWER )
MASTER.METERING STANDARDS. )
CASE NO. IPC.E.18-08
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, request that Idaho Power Company
(Idaho Power or Company) provide the following documents and information as soon as
possible, and no later than FRIDAY, JUNE 1,2018.1
Please provide answers to each question and supporting workpapers that detail, or are the
source of information used in, any calculations.
Besides the written copies provided as response to the questions, please provide all Excel
and electronic files on CD with formulas activated.
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 MAY 18,2018
These production requests and interrogatories are continuing. IDOA is requested to
provide, by way of supplementary responses, additional documents and information that it or any
person acting on its behalf may later obtain that will augment the documents and information
produced.
In preparing your responses, please restate in full each question asked, then state in full
your response to the question and the name and telephone number of the person(s) who prepared
the response and would be able to answer questions about it or sponsor it at hearing if needed.
See IDAPA 31.01.01.228.
REQUEST NO. 1: Staff understands that Idaho Power provides primary service to the
State of Idaho's Chinden Office Complex Campus through two primary meters, with the points
of delivery being at Idaho Power's substation next to the Campus on Cloverdale Road. Building
8, currently occupied by Sykes Enterprises, is served by one primary meter; the remaining
buildings on the Campus are served by the other primary meter. Idaho Power does not currently
own or maintain any electrical facilities or metering equipment beyond the point of delivery.
The service provided to Building 8 cannot be interconnected electrically to any other building on
the premises (Rule C of Idaho Power's Tariff). Is Staff s understanding correct? Please provide
an overview of how Idaho Power provides service to the Campus.
REQUEST NO. 2: Please explain what work IDOA has asked Idaho Power to do to
modify the Campus to meet Idaho Power's requirements to maintain the power distribution
system to each building or identified electrical meters on the Campus. To the extent available,
your explanation should include details like:
a. Scope ofSupply;
i. A description of the work;
ii. Schematic drawings representingthe requested/necessarymodifications;
iii. Physical plan and elevation drawings identifying the requested
modifications;
b. A detailed material estimate with itemized component pricing;
c. A detailed labor estimate by worker classification, hours, and rate;
d. A detailed support equipment estimate by type, hours, and rate;
FIRST PRODUCTION REQUEST
TO IDAHO POWER MAY 18, 20182
e. Detailed accounting of indirect costs;
f. Summary table of the subtotaled itemized costs; and
g. Anticipated duration and schedule.
DATED at Boise,Idaho, this $'82 day of May 2018.
4.or
Attorney General
Technical Staff: Beverly Barker (16)
Rick Keller (17)
umisc:prodreq/ipcel8.8kkrkrfbb prod req I to ipc
FIRST PRODUCTION REQUEST
TO IDAHO POWER J MAY 18, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l8th DAY OF MAY2O18, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-18-08, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIE K WEAVER
DEPUTY ATTORNEY GENERAL
DEPT OF ADMISTRATION
PO BOX 83720
BOISE rD 83720-0010
E-mail : i ulie.weaver@ag. idaho. gov
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : caschenbrenner@idahopower. com
CERTIFICATE OF SERVICE