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Home My WebLink About200504224th staff production request to PAC.pdf-- r... ,... " ''!. l- '-' '- '~L f"lL:.Ji 1""'""" ----i,SCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 :- iI. EO ::005 ilPR 22 Prt 2:1 I '" " ' '" ..,.., "" "'" U i U;,Jl,.I\..' fONu 1 LI I t CUt' :,). " ' 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 ACIFICORP DBA UTAH POWER & LIGHT COMP ANY FOR AUTHORITY TO INCREASE ITS RATES FOR ELECTRIC SERVICE TO ELECTRIC CUSTOMERS IN THE STATE OF IDAHO. CASE NO. PAC-05- FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO ACIFICORP The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that PacifiCorp (PacifiCorp; Company) provide the following documents and infonnation on or before FRIDAY, MAY 6, 2005. This Production Request is to be considered as continuing, and PacifiCorp 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. Please provide answers to each question; supporting workpapers that provide detail or are the source of infonnation used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. FOURTH PRODUCTION REQUEST TO ACIFICORP APRIL 22, 2005 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. Reference IDAP A 31.01.01.228. For documents provided please include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder. For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.), CDs with all underlying formulas intact in Excel 2000 compatible language. REQUEST NO. 50: In PacifiCorp s response to Staff Production Request No. 47 , it is confinned that meters are typically left on between occupants unless at the next meter reading/billing date there is no new occupant and usage has crossed the threshold of 400 kWh. PacifiCorp has stated that at that point, the meter is disconnected. Who is billed for the electricity between the time that the meter is read for the occupant who closed the account and the point at which the meter is disconnected after crossing the 400 kWh threshold? REQUEST NO. 51: During 2004, how many meters fall in this category where the occupant has closed the account but the meter is not disconnected? REQUEST NO. 52: Chronologically, what is the process after the 400 kWh threshold is detennined to have been crossed? Does the meter reader turn the meter off? Is a separate order generated and a different employee dispatched to turn off the meter? REQUEST NO. 53: How is unbilled revenue booked? REQUEST NO. 54: During 2004, how many meters were disconnected after crossing the 400 kWh threshold? REQUEST NO. 55: Please provide a current valuation of the three ancillary services that Monsanto provides to PacifiCorp. Show them individually and provide associated workpapers. FOURTH PRODUCTION REQUEST TO ACIFICORP APRIL 22 , 2005 REQUEST NO. 56: In Case No. UPL-01-16 the Commission established Monsanto contract rates at what it deemed to be full cost of service. In that case Monsanto s full cost of service as an uninterrupted customer was calculated to be $43 971 090 based on a 1999 test year. In the current case, the Company calculates Monsanto s full cost of service to be $53 885 831. A number of things have changed that have led to the cost of service difference. They are: Test year accounting data was 1999 and now is 2004. Jurisdictional and class allocators were based on 1999 data and now are based on 2004 data. Jurisdictional allocation methodology was "rolled-" and now is "revised protocol" . Please provide a series of jurisdictional allocation and cost of service model runs that capture the differences caused by each of these factors individually. If there are other factors that the Company believes to be significant in defining the change in cost of service, model runs that establish their value should also be provided. The model runs that capture the jurisdictional allocation methodology difference should be run last. REQUEST NO. 57: Please provide the cost of meter reading and billing for each of the rate schedules. REQUEST NO. 58: Please provide any analysis justifYing the proposed increase in the monthly minimum bill Customer Service Charge for each of the schedules. REQUEST NO. 59: Please provide the analysis that supports the seasonal price differential in Schedule No.1. Include justification for the specific months included in each season and the specific rates as proposed. REQUEST NO. 60: Please provide an analysis that supports the time of use rate differentials on Schedule 36. Include justification for the time periods chosen and the specific rates proposed. FOURTH PRODUCTION REQUEST TO ACIFICORP APRIL 22, 2005 REQUEST NO. 61: Please provide the analysis that supports the seasonal price differential in Schedule Nos. 6, 6A, 8, 9, 10, 23 and 23A. Include justification for the specific months included in each season and the specific rates as proposed. REQUEST NO. 62: Please provide an analysis that supports the time of use rate differentials on Schedule Nos. 35 and 35A. Include justification for the time periods chosen and the specific rates proposed. REQUEST NO. 63: Please provide a bill frequency analysis for Service Schedules and 36 for each month with incremental blocks of 100 kWh for usage from 0 to 1200 kWh; then 1200 to 1500 kWh; 1500 to 2000 kWh; 2000 to 2500 kWh; 2500 to 3000 kWh; 3000 to 4000 kWh; 4000 to 5000 kWh and over 5000 kWh. Include both numbers of bills in that block and energy use the block. Please provide this in Excel 2000 fonnat. Dated at Boise, Idaho, this d~ day of April 2005. Scott Woodbury Deputy Attorney General Technical Staff: Marilyn Parker Keith Hessing Dave Schunke i:umisc:prodreq/pace05.lsw pr 3 mp 50-54 kh 55-56 des 57- FOURTH PRODUCTION REQUEST TO ACIFICORP APRIL 22, 2005 CERTIFICA TE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF APRIL 2005 SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP IN CASE NO. PAC-05-, BY 'MAILING A COpy THEREOF POSTAGE PREPAID, TO THE FOLLOWING: JOHN STEWART ACIFICORP 201 S MAIN ST., SUITE 2300 SALT LAKE CITY, UT 84140 MAIL: john.stewart2~pacificorp.com JAMES M. VAN NOSTRAND STOEL RIVES LLP 900 S W FIFTH AVE SUITE 2600 PORTLAND OR 97204 MAIL: imvannostrand~stoe1.com DATA REQUEST RESPONSE CENTER ACIFICORP 825 NE MUL TNOMAH SUITE 800 PORTLAND OR 97232 MAIL: datarequest~pacificorp.com ERIC L OLSEN RACINE OLSON NYE BUDGE & BAILEY, CHARTERED PO BOX 1391 POCATELLO ID 83204-1391 E- MAIL: e1o~racinelaw .net ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 MAIL: tony~yanke1.com RANDALL C. BUDGE RACINE OLSON NYE BUDGE & BAILEY, CHARTERED PO BOX 1391 POCATELLO ID 83204-1391 MAIL: rcb~racinelaw .net JAMES R SMITH MONSANTO COMPANY PO BOX 816 SODA SPRINGS ID 83276 MAIL: jim.smith~monsanto.conl CONLEY E WARD GIVENS PURSLEY LLP 601 W BANNOCK ST PO BOX 2720 BOISE ID 83701-2720 MAIL: cew~givenspursley.com DENNIS E PESEAU UTILITY RESOURCES INC 1500 LIBERTY ST SE SUITE 250 SALEM OR 97302 MAIL: dpeseau~excite.com BRAD M. PURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 MAIL: bmpurdy~hotmai1.com CERTIFICATE OF SERVICE R. SCOTT PASLEY ASSIST ANT GENERAL COUNSEL J R SIMPLOT COMPANY 999 MAIN ST (83702) PO BOX 27 BOISE ID 83707 MAIL: spasley~simplot.com DAVID HAWK, DIRECTOR ENERGY NATURAL RESOURCES J R SIMPLOT COMPANY 999 MAIN ST (83702) PO BOX 27 BOISE ID 83707 MAIL: dhawk~simplot.com TIM OTHY J SHURTZ 411 SMAIN FIRTH ID 83236 MAIL: tiln~idahosupreme.com SECRET ARY CERTIFICATE OF SERVICE