20161118Staff 1-7 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR AUTHORITY TO MODIFY )
ELECTRIC SERVICE REGULATION NO. 12 )
RELATED TO LINE EXTENSION )
ALLOWANCES. )
)
) ___________________ )
CASE NO. PAC-E-16-13
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
DECEMBER 9, 2016.
This Production Request is to be considered as continuing, and Rocky Mountain Power 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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 NOVEMBER 18, 2016
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: On page 4 of Robert Stewart's testimony, he states: "The Company
is proposing to lower Facilities Charges to an average rounded value of 0.6 percent for facilities
installed at customer expense and 1.3 percent for facilities installed at the Company expense."
Please explain how these percentages were calculated and provide the executable electronic
workpapers supporting the calculations.
REQUEST NO. 2: On page 5 of Robert Stewart's testimony, he states: "Idaho is the
only Rocky Mountain Power jurisdiction in which the Company lists the extension advances in
Schedule 300." Please describe how extension advances are managed in other Rocky Mountain
Power jurisdictions and include copies of applicable tariffs.
REQUEST NO. 3: On page 9 of Robert Stewart 's testimony, he states: "If the Company
fails to include the refund as part of the amount to be collected from the new (additional)
customer, it becomes uncollectable by the Company." Please describe how this scenario
contributes to overall uncollected expenses as a percentage for the last five years. Please include
a supporting executable electronic workpaper.
REQUEST NO. 4: On page 11 of Robert Stewart's testimony, he states: "The Company
proposes this change in order to align Idaho 's line extension allowance with PacifiCorp's other
retail jurisdictions." Please explain why Idaho's line extension allowance should be aligned with
PacifiCorp's other retail jurisdictions, particularly given the unique characteristics ofldaho 's
service territory. Furthermore, please explain differences between the current and proposed line
extension allowances in Idaho and line extension requirements in PacifiCorp's other
jurisdictions.
REQUEST NO. 5: On page 12 of Robert Stewart's testimony, he states: "The $550 is
the cost of an 80 foot service plus the meter. Services vary greatly in length but an 80 foot
service will cover most residences building within a development." Please provide data showing
actual residential service lengths within developments for the last five years.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 18, 2016
REQUEST NO. 6: On page 24 of Robert Stewart's testimony, he states: "The line could
become overloaded within the contracted capacities, and an upgrade would not be charged to the
customer causing the upgrade but would be a Company expense." Please provide the number of
times this scenario has occurred in Idaho each year over the last five years. Please also include
the Company's costs for each occurrence.
REQUEST NO. 7: On page 26 of Robert Stewart's testimony, he states:" ... its position
of not making a development line extension unless there is reasonable assurance of actual
applicants for service within five years." Please describe how the Company defines reasonable
assurance including all associated policies, procedures, and work instructions.
DATED at Boise, Idaho, this (~-day of November 2016.
Technical Staff: Kevin Keyt
i:umisc:prodreq/pace l 6. l 3bkksk prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 18, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF NOVEMBER 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-16-13, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
[e-mail]
DAT A REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
SEC~-
CERTIFICATE OF SERVICE