20240613ICIP 1-8 to IPC .pdf

RECEIVED
Thursday, June 13, 2024 2:22:52 PM
IDAHO PUBLIC
UTILITIES COMMISSION
Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27"' Street
Boise, Idaho 83702
Telephone: [phone]
lietcr@richat(isonadams.com
richarclsgnadams.com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07
IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE RATES FOR ) FIRST PRODUCTION REQUEST OF THE
ELECTRIC SERVICE TO RECOVER COSTS ) INDUSTRIAL CUSTOMERS OF IDAHO
ASSOCIATED WITH INCREMENTAL ) POWER
CAPITAL INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industrial Customers of Idaho Power ("ICIP") by and through its
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
Power" or the "Company") provide responses to the following with supporting documents,
where applicable.
This production request is to be considered as continuing, and Idaho 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 responses or documents produced.
Please provide an additional electronic copy of your responses, or if unavailable, a
physical copy, to Dr. Don Reading at: 280 S Silverwood Way, Eagle, Idaho 83616, Tel: (208)
384-5565; dreadin mindspring.,com.
FIRST PRODUCTION REQUEST OF THE ICIP
IPC-E-24-07
PAGE 1

For each item, please indicate the name of the person(s) preparing the answer(s), along
with the job title of such person(s) and the identity of the witness at hearing who can sponsor the
answer.
REQUEST FOR PRODUCTION NO. 1
Please provide, in electronic format, with all formulae intact where possible, along with
workpapers and other documents used in the development Matthew Larkin's Workpaper 6.
REQUEST FOR PRODUCTION NO. 2
Please provide, in electronic format, all formulae intact where possible, along with workpapers
and other documents used in the development Timothy Tatum's Exhibit 4.
REQUEST FOR PRODUCTION NO. 3
At pages 21 and 22 of his direct testimony Mr. Tatum states that"In Idaho Power's 2008 general
rate case, IPC-E-08-10, the Commission approved the use of projected year-end plant balances
for projects having a cost more than $2 million. " In a footnote on page 22, Mr. Tatum quotes the
Commission's order approving said year-end plant balance rate making treatment. According to
that quoted order, the Commission required the company to "annualize" the year-end plant
balances. [See footnote 4.1 Please explain the ramifications both to ratepayers and the Company
of annualizing the year-end plant balances for ratemaking purposes. Is the Company proposing
to annualize its year-end plant balances in this current application? Please explain why, or why
not.
REQUEST FOR PRODUCTION NO. 4
At page 19 of Mr. Tatum's direct testimony, he references a"note from Standard and Poors
[that] indicated a downgrading of its liquidity assessment of the Company." The referenced note
FIRST PRODUCTION REQUEST OF THE ICIP
IPC-E-24-07
PAGE 2

is dated February 2023. Please provide copies of all Standard and Poor's
communications/discussions regarding Idaho Power dated after February 2023.
REQUEST FOR PRODUCTION NO. 5:
At page 29 of his Direct Testimony, Mr. Tatum addresses the Company's proposed rate spread
with a ceiling of 130 percent and a floor of 50 percent of the average 7.31 percent increase.
Please provide workpapers in electronic format with all formulae intact where possible, that were
used in calculating and applying the cap and floor for each customer class.
REQUEST FOR PRODUCTION NO. 6:
Please reference Mr. Tatum's Exhibit 4 at column "Q" (titled "COS Index"). Please explain how
the values in the column were calculated. Please explain how these values are used in
determining rate spread for customer classes.
REOEUST FOR PRODUCTION NO. 7:
Please reference Mr. Tatum's Exhibit 4 at columns "L" and "M" (titled "Shortfall Allocation").
Please explain how the Shortfall Allocations among the various customer classes were arrived at
and justified.
REOEUST FOR PRODUCTION NO. 8:
Please provide copies of all communications (inclusive of discovery requests and responses) the
Company has had with the Idaho PUC Staff(both formal and informal) regarding the substance
of this docket.
Dated this13th day of June 2024
Y-0 �,
"e&�-
ter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
FIRST PRODUCTION REQUEST OF THE ICIP
IPC-E-24-07
PAGE 3

I HEREBY CERTIFY that on the 131" day of June 2024, a true and correct copy of the within and
foregoing FIRST PRODUCTION REQUEST of the Industrial Customers of Idaho Power in
Case No. IPC-E-24-07 was served, by electronic copy only, to:
Lisa D, Nordstrom Monica Barrios-Sanchez
Donovan Walker Commission Secretary
Megan Goicoechea Allen Idaho Public Utilities Commission
Idaho Power Company Secretary trpuc.idaho.gov
lnordstrom&idahopower.com [e-mail]
[e-mail]
mp,[e-mail] Idaho Irrigation Pumpers Association
dockets(ir�,idahopoereom Eric L. Olsen
Lance Kaufman, Ph.D.
Tim Tatum [e-mail]
Connie Aschenbrenner [e-mail]
Matt Larkin
[e-mail] Idaho Conservation League
caschenbrenner(a)idahopower.com Matthew Nykiel
[e-mail] idahopower.com Brad Huesinkveld
matthew.nykiel@,tmail.com
bhuesinkveld(abidahoconservation.org
r
PeVer Richardson
ISB # 3195
FIRST PRODUCTION REQUEST OF THE ICIP
IPC-E-24-07
PAGE 4