20240708Staff 1-10 to IPC.pdf

RECEIVED
Monday, July 8, 2024 12:38:49 PM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S COMPLIANCE FILING TO ) CASE NO. IPC-E-24-22
UPDATE THE CUSTOMER SURCHARGE TO )
COLLECT INCREMENTAL COSTS OF )
DISTRIBUTION UNDERGROUNDING OF ) FIRST PRODUCTION
THE NEW 138 KV TRANSMISSION LINE IN ) REQUEST OF THE
THE WOOD RIVER VALLEY AND ) COMMISSION STAFF
ESTABLISH NECESSARY REGULATORY ) TO IDAHO POWER COMPANY
ACCOUNTING TREATMENT )
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Idaho Power Company("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY,JULY 29, 2024.
This Production Request is to be considered as continuing, and the 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 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 also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 8, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide a detailed breakdown of the $19,994,550 actual
project cost for the distribution project, similar to the breakdown shown in the Overhead
Distribution Alternative Cost Summary in Attachment 3 of the Application. Please provide it in
Excel format with formula intact. Also please provide the following for the breakdown:
a. A short description for each of the costs in the breakdown;
b. How much of each cost item is known, and how much is estimated; and
c. Data for all individual costs, in Excel format, separated into the categories listed on
Attachment 3. For each expense,please provide: the date, invoice number, total
amount, description, and all other useful information.
REQUEST NO. 2: Please provide an explanation and workpapers in Excel format
showing how the overhead and Allowance for Funds Used During Construction ("AFUDC")
percentages were calculated in Attachment 3. Please show this for both the actual project
expenses and for the "2017 CPCN"baseline expenses.
REQUEST NO. 3: Please provide a breakdown of the $2 million"Reduced costs from
underground construction" shown on line 34 in Attachment 3 of the Application by the cause for
the reduction in cost(i.e. shorter transmission poles/less steel, fewer foundations, shallower
holes) in Excel format with formula intact. For each cause category,please provide the basis for
each of these cost reductions with a further breakdown by material, labor,purchased services,
overhead, and AFUDC, etc.
REQUEST NO. 4: Please explain why the Company believes it should apply the $2
million credit for avoided transmission tower costs to the present project, and not to the future
transmission project, since the costs have not truly been avoided yet.
REQUEST NO. 5: Please explain how the Company calculated the 20-year Blaine
County surcharge and provide all detailed workpapers used to derive the calculation of the
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 8, 2024

surcharge in Excel format with all formulas intact. Please provide the customer data(e.g. billing
information) which reflects the up-to-date customer counts.
REQUEST NO. 6: Please provide workpapers in Excel format, for each month, which
total the surcharges that will be collected over the entire 20 years.
REQUEST NO. 7: Please explain how the Company will address over-collected or
under-collected amounts received from the surcharge after 20 years.
REQUEST NO. 8: Please explain how the Company will address mismatches in the
depreciation expense and the surcharge collection from an accounting perspective. Please
provide hypothetical journal entries.
REQUEST NO. 9: Please provide customer counts by customer schedule (Schedules 1,
3, 5, 6, etc.) over the last ten years (2012-2023) for customer schedules affected by the Blaine
County surcharge.
REQUEST NO. 10: Please describe the likely impacts if the Commission denies the
Company's request to split the surcharge and requires the Company to complete both the
distribution and transmission work before allowing the surcharge to be implemented.
DATED at Boise, Idaho, this 8 h day of July 2024.
4A-1-11_]ZW
r Michael Duval
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-22 PR#l.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JULY 8, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS F DAY OF JULY 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-22,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER ALISON WILLIAMS
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalker(c�,idahopower.com E-MAIL: awilliamskidahopower.com
docketsgidahopower.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE