20190116Staff Correspondence.pdf

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1. ArticleAddrcssedto:
Israel Ray
Atlanta Power Company'
11140 Chicken Dinner Road
Caldwell ldaho 83607
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Brandon Karpen'8 DeputyAttorneyGeneral6 Idaho Public Utilities Commission
4T2WWashington Street
Boise,ldaho 83702
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t - Israel RaY
Atlanta Power ComPanY
11140 Chicken Dinner Road
Caldwell Idaho 83607
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STATE OF IDAHO
OFFICE OF THE ATTORNEY GENERAL
LAWBENCE G. WASDEN
VIA CERTIFIED MAIL
August 6,2018
Israel Ray
Atlanta Power Company
I I140 Chicken Dinner Rd.
Caldwell, ID 83607
Re: Notice of Possible Legal Action
Dear Mr. Ray:
In January 2018, an Atlanta Power customer filed a formal complaint against the Company. Additionally,
on February 20, 2018, the Idaho Public Utilities Commission directed Commission Staff to conduct a
general investigation into the operations of the Company. The Commission ordered the Company to file a
written response to the formal complaint of Mary Drake, and respond to any inquiries, such as production
requests and written interrogatories. You are the sole owner and official operator of Atlanta Power
Company and the only person able to officially speak for Atlanta Power Company.
The Office of the Attomey General for the State of ldaho is aware that the Company has failed to respond
to the formal complaint or StafPs production request. Idaho Code $ 6l-406 provides that every public
utility "shall obey and comply with each and every requirement of every order, decision, direction, rule
or regulation made or prescribed by the commission ...." As indicated by the attached documents, on
February 20, 2018, the Commission directed the Company to respond to the formal complaint and any
inquires made by Commission Staff. On March 16, 2018, Staff provided the Company with several
production requests, which have gone unanswered.
Due to the Company's failure to respond to the complaint and Staff informational requests, the
Commission is authorizedby ldaho Code $ 61-701-712Ato commence an action to collect civil penalties
up to $200,000. The Commission also may consider cancelling the Company's Certificate of Public
Convenience and Necessity. To avoid Commission proceedings and any court action, the Company must
respond in writing to the formal complaint and Staffls production request by August 3 l, 2018.
lo
Attorney General
Enclosures
Contracts & Administrative Law Division, ldaho Public Utilities Commission
P.O. Box 83720, Boise, ldaho 83720-0074, Telephone: [phone], FAX: [phone], Email: [e-mail]
Localed at 472 West Washington St., Boise, ldaho 33702
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Otficc of the Secrelary
Service Date
Fcbruary 20,2018
BEFORE THE IDAHO PUBLIC I-ITILITIES COMMISSION
IN THE N,IA'I'I'ER O}'TI{E INVESTIGAI'ION
OF- ATI",AN'I'A POWEIT COMPANY
SERVICE AND CUSTOMER RELATIONS
CASE NO. i\TL-E-18-01
NOTICE OF INVIISTIGATION
ol{DER NO. 33988
In the spring o{ 2017. Conrmission StalT rcceived a number of complaints from
residents of Atlanta, ldaho, olrtlining concerns related to electric service being provided by
Atlanta Power Company. fhe customers stated that the Clompany's hydroelectric turbine w&s no
longer working and the Ceimpany was using a diesel generator to provide electric service. [t was
reported that the gcnerator was regularly running out of llel and electric seruice outages were
occurring fiequently tbr significant periods ol' tinre. Stafl' rcceived several complaints
throughout 2017 about inadequate service and outagcs. and thc inability of customersto contact
anyone Iiom the Company. On January 2,2018. Atlanta Power customer Mary Drake tiled a
Fornral Complaint against Atlanta Power Conrpany claiming the Cornpany is violating
Comnrission Order No. 31085 and ldaho C'odc $ 61-302 by lailing to maintain adequatc service.
On January 22, 2A18, Stafl'requestcd that thc Clomrnission direct the Company to
respond to the l'ormal Cornplaint of Mary Drake. and to open a lbrmal investigation into the
Conrpany. StalT recommendcd that the investigation focus on servicc reliahility, maintenancc
and operation ol- (he Company's facilities, and customer service. As part ol'its investigation,
Sta{Twill rcview the Company's cor:npliancc rvith past ordcrs, inspcct generation and distritrution
lacilities, and confur with customers.
The Conrmission approvcd Stal'l's rccommendation that a summons bc issucd regarding
the Feirmal Complaint ol'Mary l)rake, and also ordered that Staffconduct an invesligation under
thc samc dockct. l'hc Commission dircctcd Stall'to work with thc Company and its customcrs to
investigate reliability and customer serl,ice issues, identify possible solutions and provide a
report detailing Stafl's findings within six months.
Accordingly, we direct Atlanta Power to address thc Formal Customer Complaint of
Mary Drake, to make itsell'available to Staff for any audit and/or inspection, and respond to any
and all questions posed by Staff. Responses should bc by formal written answer in this case.
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oRI)HR N0.33e88 I
Orrce StalIcompletes its investigatiorr, or at the appropriate tirne, it shail report its findings and
make recommendations to the Commission.
ORDER
IT IS IIEREBY ORDtsl{ED that Clommission Staff shall conduct an investigation
into the service reliability" maintenance and operations. and customer relations of Atlanta Power
C-'ompany. Staff shall provide a repoft and recommendations to the Clommission lbr funher
action no later than July 31, 2018.
IT IS FLIRTI'IER ORDERED that the Company respond to the Formal Complaint of
Mary Drake, as directed in the summons issucd lry the Comrnission.
I'f IS FURI'HER ORDERED that Atlanta Porver Company respond to any inquiries.
Commission Staff is directed to issue production requests, u,ritten interrogatories or other forms
of discovery as rvell as pursue its statutory right to examine and audit lhe records.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this Z
day of February 20 I 8.
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IONER
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ERIC ANDERSON, COMMISSIONER
A]"|EST:
Diane M. Hanian
Commission Secretary
I J.egal,LORDIRS A'l'l-El80l,bk,lnve!rigntion Ords doc
2ORDIIR N0. 33988
PAUI, K.I NI,I,ANI)I]R. PRESIDENT
BRANDON KARPEN
DEPUTY ATTORNSY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX U?2A
BOISE,IDAHO N72A-AA74
(?08) 334-03s7
IDAHO BAR NO. 7956
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?{ii$ i:l&fi I 5 ll$ l}r I ?
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Street Address for Express Mail:
472 W. WASHINGTON
BOIST, IDAHO 83702-5918
Attorneys for the Commission Staff
BETORE THE, IT}AHO PUBLIC UTILITIES COMMISSION
IN THtr MATTER OT THtr INVESTIGATION
OT ATLANTA TOWER COMPANY SERYICE
AN} CUSTOMER RTLATIONS
CASE NO. ATL.E*T8.01
rIRST TRODUCTION
RTQUEST Or THp
COMMISSIOX $TAPT
TO ATLANTA TOWER
COMPANY
The Staffof the ldaho Public Utilities Commission requests that Rocky Mountain Power
provide the following documents and information as soon as possible, but no later than
tr'RIDAY, APRIL 6,2018.
This Production Request is to be considered continuing, and Atlanta Power is requesled
to provide, by way clf supplemenlery responsesi additional docurnents that it or any person acting
on its behalf may later obtain that will augment the documents or infarmation produced.
Please provide answers 1o 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 dr:cuments. Please identify the name, job title, location and telephone
number of the record holder.
In addition to lhe written copies provided as response to the requests, please provide all
Excel and electronic files on CD with furmulas activated.
FIRST PRODUCTION REQUES'T
TO ATLANTA POWER 1 MARCH 16,2018
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REQUEST NO. l: Please provide a list with the names and job functions of all Atlanta
Porver employees or contractors.
REQUEST NO. 2: Please provide a breakdown of customers taking senice under each
distinct rate schedule including the total number of current customers.
REQUEST NO.3: Please provide the names and addresses for all customers currently
connected to the Atlanta Power system. Please include the names and addresses of seasonal
customers that have had service at any tirne since January 1.2017 .
REQUEST NO.4: Please provide the following information regarding outages that
occurred in2Al7:
a. the total number of outages;
b. the duration of each outage;
c. the total number of outages that lasted more than 24 hours;
d. the cause ofeach outaget
e. rvhere each outage occurred (danr, turbine, generator, distribution, etc.); andl. how each outage was fixed and which Atlanta Power employees or contractors helped
resolve each outage.
REQUEST NO. 5: Please detail any and all repairs made to the hydroelectric turbine
since January 1,2016. Please provide a description ofeach repairjob and the associated cost.
REQUEST NO. 6: Please provide the following inlbrmation regarding operation of the
diesel generator in 2017 :
&. the total hours the generator was operated in 2017;
b. the total gallons of luel consumed; and
c. all repairs made to the generator and controls in 2017 and cost of each repair.
REQUEST NO. 7: Please provide a list of alldicsel fuclpurchases since January l,
2016. Please include receipts for each purchase.
REQUEST NO.8: What is the total capacity of the Company's diesel fuel tank? When
the Company lills the tank, is it frlled to capacity? It'not, why'l
FIRST PRODUCI'ION REQUEST
TO ATLANTN POWER ,)MARCI-I I6,20I8
REQUEST NO. 9: Please explain all restrictions lbr diesel fuel deliveries.
REQUEST NO. l0: What upgrades or improvements has the Company made to the
distribution system in 2016 and2017? What was the associated cost?
REQUEST NO. t l: Please provide an inventory of all equipment purehased by the
Company since January l, 2016.
REQUEST NO. l2: Please provide all generating equipment specification data by unit.
This data u,ould include, but is not limited to:
a. Equipment tYPe;
b. Manufacturer;
c. Model number;
d. Year of manufhcture; and
e. Rated output
REQUEST NO. l3: Please provide a system nrap identilying the Company's generation
and distribution lacilities.
REQUEST NO. l4: Please explain what the Company's intentions are moving forward.
Does the Company intend lo maintain and operate tl,e system ur:der current ownership? If not, is
thc Company considering se lling the system or transfbrring orvnership to another entity such as a
cooperative?
FIRST PRODUCTtON RI]QUI]ST
TO ATLANTA POWER MARC]H I6,2OI83
DATE, at Boise, Idaho, this {l/3 auyof March 2018.
General
Technical Staff: Johnathan Farley
Kevin Keyt
Brad lverson-Long
Rick Keller
Michael Illdred
i:urnisc:prodr*q/atle I &. I bkjf prnd req I
FIRST PRODUCTION RTQUEST
TO ATLANTA POWER 4 MARCH I6,2OI8
CERTITICATE OF SERVICE
I HEREBY CERTIFY T}{AT I I-IAVE ]'HIS I6III DAY OF MARCH 2018,
SIRVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ATLANTA POWER COMPANY, IN CASE NO.
ATL-I].l8-01, BY MAILING A COPY TIJE,REOF, POSTACI] PREPAID, TO TI'IE
FOLLOWING:
ISRAEL RAY
ATLANTA POWER COMPANY
I I140 CHICKEN DINNER RD
CALDWELL ID 83607
-J, /'knAsrc[rfedY--
CERTIFICATE OF SERVICE