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Home My WebLink About20240724IPC to Staff 8-16.pdf -UIQAW POWER, RECEIVED LISA D. NORDSTROM Wednesday, July 24, 2024 Lead Counsel IDAHO PUBLIC Inordstrom(Wjdahopower.com UTILITIES COMMISSION July 24, 2024 VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Response to the Third Production Request of the Commission Staff to Idaho Power Company. Due to the collectively voluminous confidential and non-confidential information provided in response to data requests in this case, the Company is posting the confidential attachments to this request to the secure FTP site to allow parties to view the requested information remotely unless otherwise noted in the response. Because certain attachments contain confidential information, the FTP site is divided between confidential and non-confidential information. The login information for the non-confidential portion of the FTP site has been provided to all parties that have intervened to date. The login information for the confidential portion of the FTP site will be provided to the parties that execute the Protective Agreement in this matter. If you have any questions about the attached filing, please do not hesitate to contact me. Very truly yours, Lisa D. Nordstrom LDN:sg Enclosures CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-24-07 Idaho Power Company's Application for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that all of the attachments in Idaho Power Company's Response to the Third Production Request of the Commission Staff dated July 24, 2024, contain information that Idaho Power Company and/or a third party claim are trade secrets, business records of a private enterprise required by law to be submitted to or inspected by a public agency, and/or public records exempt from disclosure by state or federal law as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 24' day of July 2024. LISA D. NORDSTROM Attorney for Idaho Power Company LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(aMdahopower.com dwalker idahopower.com mgoicoecheaallen(abidahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07 INCREASE RATES FOR ELECTRIC ) SERVICE TO RECOVER COSTS ) IDAHO POWER COMPANY'S ASSOCIATED WITH INCREMENTAL ) RESPONSE TO THE THIRD CAPITAL INVESTMENTS AND ) PRODUCTION REQUEST OF THE CERTAIN ONGOING OPERATIONS ) COMMISSION STAFF TO IDAHO AND MAINTENANCE EXPENSES. ) POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Third Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated July 3, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 1 REQUEST FOR PRODUCTION NO. 8: Regarding the Revenue Allocation Summary provided as Exhibit No. 4 in Tatum Direct Testimony, please respond to the following: a. Please provide a copy of Exhibit 4 in Excel format with all formulas intact and enabled; and b. Please explain how the second pass revenue allocation among customer classes is determined. RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Responses regarding the Revenue Allocation Summary provided as Exhibit No. 4 in Mr. Tatum's Direct Testimony are included below: a. Idaho Power's Class Cost-of-Service ("CCOS") Study used in the development of Mr. Tatum's Exhibit 4 is included in the file labeled "Attachment — Response to ICIP Request No. 2." The first tab on the left labeled "Exhibit No. 4" is a copy of the exhibit in electronic format. b. The file labeled "Attachment — Response to ICIP Request No. 2" and the tab labeled "Exhibit No. 4" includes the calculations for Mr. Tatum's Exhibit 4. Columns "K" through "M" (titled "Second Pass Revenue Allocation") allocate the First Pass Shortfall of$1.073 million that remains after applying the cap and floor percentage increases to each customer class in the First Pass Revenue Allocation (see columns "H" through "I"). Column "K" determines which customer classes First Pass Revenue Allocation was not at the cap or floor (shown with a "Y" to indicate the Second Pass Revenue Allocation applies to a given customer class). For all customer classes that the Second Pass Revenue Allocation applies, Column "L" IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2 allocates a percentage of the total Second Pass Revenue Allocation based on their percentage of 2024 Retail Sales in column "C" to then allocate the First Pass Shortfall of $1.073 million in column "M" of Exhibit 4. The response to this Request is sponsored by Timothy E. Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 9: Please provide internal and external audit reports from 2018-2024 regarding any aspects of employee compensation and benefits, including: wages, salaries, 401 K matching contributions, incentive payments, etc. RESPONSE TO REQUEST FOR PRODUCTION NO. 9: All audit reports related to employee compensation and benefits for Idaho Power Company for the period 2018 through 2024 are listed in the table below with corresponding page numbers to the supporting file "Confidential Attachment— Response to Staff Request No. 9." Please note that the Company has not specifically engaged external auditors to perform a review or audit on any aspects of employee compensation and benefits, except as part of the annual integrated audit of the Company's financial statements and internal controls over financial reporting performed by the Company's principal independent registered public accounting firm, Deloitte & Touche LLP. PDF Page Year Audit Type Audit Audit Name #'s Issued Number 1-3 2018 Operational 201719 IDACORP Incentive Plan 4-6 2018 Operational 201717 HRIS 7-9 2019 Operational 201811 IDACORP Incentive Plan 10-13 2020 Operational 201918 IDACORP Incentive Plan 14-17 2021 Operational 202009 Incentive Plans - IDACORP 18-20 2022 Operational 202115 Executive Perquisites Audit 21-23 2022 Operational 202116 Incentive Plans - IDACORP 24-25 2022 SOX PPPP Payroll Processing 26-28 2023 Operational 202203 Incentive Plans - IDACORP 29-33 2024 Operational 202305 Customer Research: Fuse 34-36 2024 Operational 202303 IDACORP Incentive Plan IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER -4 The Company's internal Audit Services performs audits of internal controls related to compensation and benefits on a rotational basis as part of complying with Sarbanes- Oxley ("SOX") requirements. Audit reports and management responses are only issued for SOX internal control audits in the event of a finding(s). No SOX testing has been completed in 2024 as of the date of this response. The related SOX processes are Payroll Processing ("PPPP"), Payroll Recording ("PRPR"), Benefit Plans — Post Retirement Health ("BPPH"), Benefit Plans — Pension Plans ("BPPP"), Benefit Plans — Security Plan ("BESP"), Benefit Plans — Post Employment ("BEPE"), Blue Shield Idaho Power Controls ("BSIP"), Financial Accounting Deferred Compensation ("FIDC"), Financial Accounting Incentive Accrual ("FIIA"), Financial Closing Process ("FCCP"), Entity-Wide Control Environment ("EWCE") and Entity-Wide Internal Controls ("EWIC"). Please note that the FIDC process was retired in 2019. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 5 REQUEST FOR PRODUCTION NO. 10: Please provide all relevant information, including compensation studies and surveys, used to determine employee general wage increases for 2023-2025. RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please see Confidential Attachments 1 and 2 — Response to Staff Request No.10 for information related to the determination of the 2023 and 2024 employee general wage adjustment. The 2025 general wage adjustment review and recommendation will be presented to the Board of Directors for approval in November 2024 and will become effective December 21, 2024, the beginning of the first pay period for 2025. While the more in-depth general wage adjustment review will not be presented until November, a review of current economic and peer contract data suggests a general wage adjustment of at least 3 percent for 2025 is prudent. The most recent Consumer Price Index ("CPI") publication showed inflation at 3 percent from June 2023-June 2024, the Federal Reserve Bank of Atlanta is reporting wage growth in the Mountain Region at 5.9 percent as of March 2024, and the northwest utility peer union increases for 2025 are projected to range from 2.5 to 4 percent. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 6 REQUEST FOR PRODUCTION NO. 11: Please provide a description of how the general wage increase is awarded to employees (i.e. across the board increase or allocated based on performance). Please also provide the most current list of criteria and other requirements employees must meet to receive the Company approved general wage increase. RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Except in limited circumstances, the general wage adjustment ("GWA") is an across the board increase for eligible employees, which excludes officers and senior managers. The only time an employee would not receive a GWA is if they move into a lower-graded position. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 7 REQUEST FOR PRODUCTION NO. 12: Please provide a list of all job titles and descriptions. Please include the number of employees who are currently employed for each job title. RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Please see the Excel file labeled "Confidential Attachment — Response to Staff Request No. 12" for a list of all job titles, descriptions, and employee count in each. Please note, Idaho Power does not maintain job descriptions for officer or senior manager jobs. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 8 REQUEST FOR PRODUCTION NO. 13: Please provide a list of all job openings in 2023 and 2024. Include the number of qualified candidates who applied for each position and how long each position was open. RESPONSE TO REQUEST FOR PRODUCTION NO. 13: Please see the Excel file attached labeled "Confidential Attachment — Response to Staff Request No. 13" for a list of all job openings in 2023 and 2024. The listing includes both internal and external job postings. The posting duration listed is the total number of days the job was posted and open for candidate applications, in some cases the job may have been posted multiple times. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 9 REQUEST FOR PRODUCTION NO. 14: Please provide a list of employment positions created or eliminated in 2023 and 2024. Please state the job title of such positions and justification of why each position was created or removed. RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Please see the Excel file attached labeled "Confidential Attachment — Response to Staff Request No. 14" for a list of positions created or removed in 2023 and 2024. Of note, once a position is closed in the Company's HRIS system, reporting information becomes very limited and is completely removed from the system after a short period of time. The listing of closed positions may be incomplete. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 10 REQUEST FOR PRODUCTION NO. 15: Please provide a list of employees, (ID # of employee acceptable instead of name) who received more than the Company approved general wage increase. Please provide reasonings for each increase. RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Pay increases, outside of GWA, may be granted based on various factors. Employees who are still progressing to the top of their pay grade (median of market) are eligible for Merit Salary Increases ("MSI"), which are granted based on performance, every six months until they reach top of grade. Employees may have an increase due to promotional opportunities, either through a competitive process or promotion within a job family, or due to a market evaluation that results in a grade increase. Employees can also experience a reduction in pay based on movement to a lower paying role, demotion based on performance, or when a market evaluation results in a grade decrease. Officer and Senior Manager increases are evaluated annually and determined based on budget, performance, internal equity, market positioning and placement within the salary structure. Please see the Excel file attached labeled "Confidential Attachment — Response to Staff Request No. 15" for a list of employees by employee ID and reason for increase. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 11 REQUEST FOR PRODUCTION NO. 16: Please provide a matrix identifying the major capital expenditure approval levels that includes the dollar level of authorization by job title and division. Please explain the dollar level at which the individual capital expenditures require approval by the Company's Board of Directors. RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the Excel file attached labeled "Confidential Attachment — Response to Staff Request No. 16" for a list of approval authority levels. Effective May 16, 2024, any individual project which meets either of the following criteria must be specifically approved by the Company's Board of Directors ("Board"). • will cost more than $6 million during the current budget year, or • has a total cost greater than $20 million including prior periods and will cost more than $6 million in total during the current and future budget years. Effective November 19, 2014, through May 15, 2024, any individual project which meets either of the following criteria must be specifically approved by the Board. • will cost more than $4 million during the current budget year, or • has a total cost greater than $15 million including prior periods and will cost more than $4 million in total during the current and future budget years. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 12 DATED at Boise, Idaho, this 24th day of July 2024. LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 13 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 24th day of July 2024, 1 served a true and correct copy of Idaho Power Company's Response to the Third Production Request of the Commission Staff to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Chris.Burdin(c�puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Industrial Customers of Idaho Power Hand Delivered Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27' Street FAX Boise, Idaho 83702 FTP Site X Email peterC@richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dreading(@mindspring.com Idaho Irrigation Pumpers Association, Hand Delivered Inc. U.S. Mail Eric L. Olsen Overnight Mail ECHO HAWK & OLSEN, PLLC FAX 505 Pershing Avenue, Suite 100 FTP Site P.O. Box 6119 X Email elo _echohawk.com Pocatello, Idaho 83205 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance aegisinsight.com IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 14 Idaho Conservation League Hand Delivered Matthew A. Nykiel U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email matthew.nykiel(Dgmail.com Brad Heusinkveld Hand Delivered Idaho Conservation League U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email bheusinkveld(a)idahoconservation.org Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach FTP Site Holland & Hart LLP X Email 555 17' Street, Suite 3200 darueschhoff(c)_hol land hart.com Denver, CO 80202 tnelson(a)-hol land hart.com awjensen _hol land hart.com karoach(Dhollandhart.com Jim Swier Hand Delivered Micron Technology, Inc. U.S. Mail 8000 South Federal Way Overnight Mail Boise, ID 83707 FAX FTP Site X Email iswier(a)micron.com City of Boise Hand Delivered Ed Jewell U.S. Mail Deputy City Attorney Overnight Mail Boise City Attorney's Office FAX 150 N. Capitol Blvd. FTP Site P.O. Box 500 X Email Boise, Idaho 83701 BoiseCityAttorneyCa�cityofboise.org ejewell cityofboise.org IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 15 Steven Hubble Hand Delivered Boise City Dept. of Public Works U.S. Mail 150 N. Capitol Blvd. Overnight Mail P.O. Box 500 FAX Boise, Idaho 83701-0500 FTP Site X Email sh u bbleCcDcityofboise.org Federal Executive Agencies Hand Delivered Peter Meier U.S. Mail Emily W. Medlyn Overnight Mail U.S. Department of Energy FAX 1000 Independence Ave., S.W. FTP Site Washington, DC 20585 X Email Pete r.meier(o-)hg.doe.gov emily.medlyn(a-),hg.doe.gov Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 16