960112.docx

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE,  IDAHO  83720-0074
[phone]
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO  83702-5983
Attorney for the Commission Staff
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION

IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR APPROVAL OF NEW TARIFF PROVISIONS RELATING TO NEW SERVICE ATTACHMENTS AND DISTRIBUTION LINE INSTALLMENTS OR ALTERATIONS.
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CASE NO. IPC-E-95-18
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER
COMPANY

The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company provide the following documents and information on or before FRIDAY, JANUARY 19, 1996.
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 produced.
For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing.
1.Provide a list of all line extensions made in 1994 and 1995.  For each line extension, include the following:
a.actual cost of the line extension;
b.amount of allowances and refunds granted by the Company to the Applicant as part of the extension;
c.net amount paid by the Applicant to the Company for the line extension;
d.description of the Applicant, such as Res. Subdivision, Single Residence, Duplex, Triplex, Fourplex, Single Commercial, Industrial, Irrigation, etc.;
e.customer class;
f.voltage, phase and length of the line extension, and
g.whether the line extension was overhead or underground.
2.Provide a list of service attachments made for Schedule 7, 9, and 24 customers for each of the years 1994 and 1995.  For each service attachment, include at least the following:
a.actual cost of the service attachment;
b.connected load in kW;
c.whether service cable was underground or overhead;
d.whether conduit was installed;
e.whether transformer was installed, number and rating of transformers;
f.if transformer installed, was it overhead or pad mounted;
g.whether single or three phase;
h.length of service cable;
i.meter type and cost, and
j.cost of other incidental equipment.
3.Provide a summary of service attachments made for Schedule 1 customers for each of the years 1994 and 1995.  In the summary, include at least the following:
a.average actual cost for all service extensions;
b.number of underground and overhead service cable installations;
c.number of installations in which conduit was installed;
d.number of transformers installed, whether pad mounted or overhead, and  their size rating;
e.average number of customers per transformer;
f.number of single and three phase installations;
g.average length of service cable;
h.number of meters by meter type and cost, and
i.average cost of other incidental equipment.
4.Provide a table of current costs for overhead and pad-mounted transformers for sizes typically used for Schedule 1, 7, 9, and 24 customers.
5.Has the Company calculated the embedded costs by customer class for transformers, meters, services, and new line extensions?  If so, provide all workpapers showing these calculations.
6.Provide a summary of any unit cost estimates the Company currently uses in preparing Work Order cost estimates for either new service attachments or line extensions for years 1990 through 1995.
7.Explain the rationale the Company used in determining that services (transformers, meters, service cable, etc.) can no longer be provided without charge.
8.Explain what the Base Installation Charge is intended to cover.
9.Explain the rationale for the method used in calculating the Vested Interest Charge.
10.If the proposed Rule H is adopted and implemented, how would the Company's annual revenue requirement be affected?
11.How is the Estimated Demand determined?  Is it based on nameplate capacity of the customer's equipment?  For customers with multiple equipment loads, is the Estimated Demand based on coincident or non-coincident demand?
12.Explain the rationale for changing from 5 years to 10 years the period for which Vested Interest Refunds are allowed.
13.Provide workpapers if available, or otherwise provide an explanation, showing the basis for calculating Vested Interest Charges  in Section III, D, 1.
14.Explain the rationale for refunding the Supplemental Installation Charge but not the Service Attachment Charge or the Base Installation Charge.
15.Explain how Work Order Cost Estimates are made.  How do they relate or compare to actual costs?  Would the cost attributable to unusual conditions as defined under the existing tariff be included in the Work Order Cost Estimate?  If Work Order Cost Estimates are different from actual costs, would customers be obligated to pay the Work Order Cost Estimate regardless of whether the actual costs are more or less than the Work Order Cost Estimate?
16.What items are furnished by the Company in exchange for the Service Attachment Charge?  (Transformers?  Meters?  Services?)
17.Explain the rationale for discontinuing line extension allowances.
18.What is the basis for selecting 70 feet as the distance at which footage charges begin?  Why is the footage limitation in Section IV, E, 2 equal to 100 feet when the limit is 70 feet in other sections of the tariff?
19.Explain the rationale for limiting Company Betterment improvements to only those cases where the estimated demand is less than 100 kW.  Why was 100 kW chosen as the cutoff?
20.To what accounts would costs for work considered Company Betterment improvements be booked?  Would these costs be booked to separate accounts from costs for work that is not Company Betterment?
21.Provide a summary listing the accounts to which the costs of new service attachments are  booked.  For each account, describe which cost items are included.
22.Provide a summary listing the accounts to which the costs of new line extensions are  booked.  For each account, describe which cost items are included.  Are other costs not associated with new line extensions also booked to the same accounts?
23.Provide workpapers or other information showing the basis for the footage charges for distances over 70 feet for Schedule 1, 7, 9, and 24 customers.  Include a breakdown for individual cost items such as trenching, backfilling, conduit, conductors, labor, etc.
24.Can Schedule 7, 9, and 24 customers provide trenching, backfilling and conduit themselves?  If so, would the service attachment charges be reduced as it is for Schedule 1 customers?  How much would the charges be reduced?  Can customers provide only trenching and backfilling but not conduit?
25.Provide workpapers or other information showing how the costs in Section IV, E, 1 & 2 were determined.
26.Provide workpapers or other information showing how the costs in Section III, A were determined.
27.Provide workpapers or other information showing how the costs in Section III, B were determined.
28.During preliminary meetings on this case, the Company provided a series of examples to show how the proposed Rule H would be implemented.  Please show, using the same examples, what the effect would be, in terms of costs to the various applicants, under the current Rule H.
29.Explain how engineering costs would be determined for prepayment for line extensions, and/or relocations, pursuant to Section IV, B of the proposed Rule H.
30.Relative to one of the workpapers titled “Idaho Applicant Payments (Charges)” that details the computations underlying the proposed charges for Overhead Service, Underground Service, Underground Service from Overhead, etc., please present any workpapers or data indicating the degree to which the illustrated costs have changed since 1990.
31.Please present any workpapers or data indicating the degree to which the mix of line extension types has changed over the past five years, i.e., to what extent are line extensions longer or shorter and how much?  To what extent has the percentage of underground line extensions increased or decreased?
DATED  at Boise, Idaho, this            day of January 1996.
______________________________________
Weldon B. Stutzman
Deputy Attorney General
umisc\prdreq\ipce9518.sw