20190910IPC to Staff 1-13.pdf

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September 10,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-19-26
Golden Hills Mobile Home Park Meter Pedestals
ldaho Power Company's Response to the First Production Request of the
Commission Staff
Dear Ms. Hanian
Enclosed for filing are an original and three (3) copies of ldaho Power Company's
Response to the First Production Request of the Commission Staff.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
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Enclosures
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RECEIVED
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Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ ida hopowe r. com
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Attorney for ldaho Power Company
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.
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CASE NO. tPC-E-19-26
!DAHO 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 August 21,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: Please describe the followin g 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. lf not, list those pedestals within the Golden Hills Mobile Home Park which
are currently owned by:
i. The mobile home park
ii. ldaho Power Company
iii. A third party customer of ldaho Power (i.e. not owned by the mobile
home park).
RESPONSE TO REQUEST NO. 1:
a. No. The Application represents all pedestals owned by ldaho Power for
lots in the Golden Hills Mobile Home Park owned by J.L.P. Trust and JCS Properties
(collectively "the Trust").
b. Please see approximate ownership count below:
i. The Trust owns approximately 14 pedestals
ii. ldaho Power Company owns 170 pedestals
iii. No third-party owned pedestals
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: How many meter pedestals within the Golden Hills Mobile
Home Park have been installed since March 31, 1981?
RESPONSE TO REQUEST NO. 2: No additional meter pedestal installations
within Golden Hills Mobile Home Park occurred after March 31, 1981.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.3
REQUEST NO. 3: Have any of the meter pedestals within the Golden Hills
Mobile Home Park been previously updated or upgraded?
RESPONSE TO REQUEST NO. 3: The Company replaced/upgraded two
pedestals in 2019 due to failure. Additionally, the Company replaced 22 pedestals in
2018 as part of the first Transfer of Title Agreement referenced on page 3 of the
Application.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
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?
RESPONSE TO REQUEST NO. 4: No, the Company will not retain ownership of
any pedestals within the Golden Hills Mobile Home Park after the transfer of the 170
pedestals.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 5: Please 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 Golden Hills Mobile Home Park. This analysis would likely include
replacemenUupgrade costs, depreciation, and maintenance expense. For any Excel
files, please also include in your response electronic files with formulas intact and
enabled.
RESPONSE TO REQUEST NO. 5: A cosUbenefit or other financial analysis was
not performed for the specific transfer of title of meter pedestals within Golden Hills
Mobile Home Park to the Trust. 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. Because labor and vehicle expenses
associated with maintaining these pedestals have generally increased since the last
analysis was completed, ldaho Power expects costs associated with pedestal
maintenance would be higher.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.6
REQUEST NO. 6: Please describe the followin g 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. lnspections 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?
RESPONSE TO REQUEST NO. 6:
a. ldaho Power completed the update/upgrade work.
b. Please see the confidential attachment provided for a detailed description
of the upgrades completed in 2018 for 22 pedestals within the Golden Hills Mobile
Home Park on two work orders. ldaho Power anticipates total costs associated with the
remaining meter pedestal upgrades will be similar to the cost of the upgrades completed
in 2018 - approximately $1,300 per meter pedestal. The only item within the work order
for which ldaho Power proposes to transfer title is the meter pedestal described as
PEDESTAL 1-PC 200A 50A RE with an average unit cost of $467.82. The other costs
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
include labor charges and upgrades to other Company-owned items associated with the
upgrades to the meter pedestals. The confidential attachment will only be provided to
those parties who have signed the Protective Agreement in this matter.
c. Yes, each pedestal has its own circuit breaker.
d. The completed work will be inspected by a local electrical inspector.
e. The local electrical inspector will ensure each installation passes
installation requirements and local electric codes.
f. All inspections will be conducted by the local electrical inspector as the
meter pedestals are installed.
g. Per the Company's most recent depreciation study for the underground
distribution account, the survivor curve indicates an average asset life of approximately
65 years.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, !daho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
REQUEST NO. 7: Was the cost for the original installation of these meter
pedestals charged to the mobile home park? Please explain.
RESPONSE TO REQUEST NO. 7: No, the original installation of these meter
pedestals was not charged to the mobile home park.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST NO. 8: In the prior case filing !PC-E-16-07, the Company indicated
that approximately 8,833 mobile home pedestals were owned and maintained by ldaho
Power. lf 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?
RESPONSE TO REQUEST NO. 8: ldaho Power's asset records indicate a total
of 8,744 Company-owned meter pedestals. ldaho Power does not track the operations
and maintenance specifically associated with meter pedestals.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
REQUEST NO. 9: What criteria does ldaho Power use to determine whether a
meter pedestal owned and maintained by the Company should be transferred to the
customer?
RESPONSE TO REQUEST NO. 9: 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 Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. 10: Does ldaho Power have any plans regarding transferring
title of any remaining Company-owned and maintained meter pedestals to customers?
Please explain.
RESPONSE TO REQUEST NO. 10: 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 the
ldaho Public Utilities Commission Staff's Request No. 9.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 12
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.
RESPONSE TO REQUEST NO. 11: Please see the Excel file in response to this
request. ldaho Power does not maintain property accounting records at the detailed
level requested. However, the Company has provided a schedule identifying all meter
pedestals with a vintage year of 1981 or earlier, including original cost, estimated book
value, current depreciation expense, and estimated accumulated depreciation. Please
note, vintage year 1980 includes meter pedestals installed from 1954 through 1980 due
to historical data conversions within the Company's accounting software, as all
distribution line equipment with those vintage years have been consolidated.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
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.
RESPONSE TO REQUEST NO. 12: ldaho Power does not track the operations
and maintenance specifically associated with meter pedestals by location.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
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 ldaho Code 561-328(3).
RESPONSE TO REQUEST NO. 13: ldaho Power did not perform an analysis to
demonstrate that the Trust has the financial ability to operate and maintain the
pedestals in the public service. The transfer of title will allow the Trust, as owner of the
lots, the ability to operate and maintain the meter pedestals itself for its tenants. The
meter pedestals will 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 minimal
maintenance over the life of the asset, resulting in minimal costs to the Trust for
ownership of the pedestals. Because of the anticipated immaterial maintenance costs
and the Trust's financial interest in maintaining the meter pedestals, ldaho Power
presumes the Trust will have the financial ability to operate and maintain Golden Hills
Mobile Home Park pedestals for its tenants, or in the public service.
The response to this Request is sponsored by Grant Anderson, Regulatory
Analyst, ldaho Power Company.
DATED at Boise, ldaho, this 1Oth day of September 2019.
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trsA D. NoRDS(SoM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Oth day of September 20191 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
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
T utive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16