20190821Staff 1-13 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
REC EIVED
?019 AUG 2l Al{ ll:35
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO TRANSFER TITLE OF GOLDEN HILLS
MOBILE HOME PARK METER PEDESTALS.
CASE NO. IPC.E.19.26
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
SEPTEMBER I.I., 2019.
This Production Request is to be considered as continuing, and Idaho Power 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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I AUGUST 2I,2OI9
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please describe the following with respect to the various pedestals in
the adjacent area, even if they are not included within the application.
a. Does this application represent all lots/pedestals within the Golden Hills Mobile
Home Park?
b. If not, list those pedestals within the Golden Hills Mobile Home Park which are
currently owned by:
i. The mobile home park
ii. Idaho Power Company
iii. A third party customer of Idaho Power (i.e. not owned by the mobile home
park).
REQUEST NO.2: How many meter pedestals within the Golden Hills Mobile Home
Park have been installed since March 3 l, 1981?
REQUEST NO. 3: Have any of the meter pedestals within the Golden Hills Mobile
Home Park been previously updated or upgraded?
REQUEST NO. 4: After transfer of the 170 pedestals described in the Application, will
the Company retain ownership of any remaining pedestals within the Golden Hills Mobile Home
Park?
REQUEST NO. 5: Please 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 Golden
Hills Mobile Home Park. This analysis would likely include replacement/upgrade costs,
depreciation, and maintenance expense. For any Excel files, please also include in your response
electronic files with formulas intact and enabled.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 2I,2OI9
REQUEST NO. 6: Please describe the following related to meter pedestal
updates/upgrades within the Golden Hills Mobile Home Park:
a. Who performed the work?
b. A detailed description and related documentation (such as work orders, detailed
estimates, etc.) that detail Company costs incurred, or expected to be incurred for
the updates/upgrades.
c. Whether or not there will be a protective circuit breaker associated with each
meter pedestal?
d. Whether the completed updates/upgrades work will be inspected by a building
official associated with the jurisdiction.
e. Inspections that have or will take place. Please describe the criteria that will be
used to inspect updates/upgrades.
f. Results of the Trust's inspection described on page 3 of the Application.
g. What is the expected service life of the updated pedestals?
REQUEST NO. 7: Was the cost for the original installation of these meter pedestals
charged to the mobile home park? Please explain.
R-EQUEST NO. 8: In the prior case filing IPC-E-16-07, the Company indicated that
approximately 8,833 mobile home pedestals were owned and maintained by Idaho Power. If this
transfer is approved, how many remaining meter pedestals will be owned and maintained by the
Company? What is the annual cost of maintaining a meter pedestal?
REQUEST NO. 9: What criteria does Idaho Power use to determine whether a meter
pedestal owned and maintained by the Company should be transferred to the customer?
REQUEST NO. 10: Does Idaho Power have any plans regarding transferring title of
any remaining Company-owned and maintained meter pedestals to customers? Please explain.
FIRST PRODUCTION REQUEST
TO IDAHO POWER aJ AUGUST 2I,2OI9
REQUEST NO. 11: 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 Golden Hills Mobile Home Park
meter pedestals. Please include in your response electronic files with formulas intact and
enabled.
REQUEST NO. 12: Please provide the annual costs to operate and maintain the meter
pedestals the Company is planning to transfer under this Application. Please provide in your
response the documentation (work orders, invoices, etc.) used to calculate this amount including
allocation workpapers. Please include in your response electronic files with formulas intact and
enabled.
REQUEST NO. 13: Please provide the analyses performed and documentation obtained
to demonstrate and insure that Golden Hills Mobile Home Park has the "financial ability to
operate and maintain said property in the public service" as required by Idaho Code $61-328(3).
DATED at Boise, Idaho, thisZlfrday of August 2019.
Dayn Hardie
Deputy Attorney General
i : umisc:prodreq/ipce I 9.26dhrkblkk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER AUGUST 2I,2OT94
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF AUGUST 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO. IPC-E-19-26,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : lnordstrom@idahopower. com
dockets@ idahopower. com
CERTIFICATE OF SERVICE