Loading...
HomeMy WebLinkAbout20240725Staff 34-50 to IPC.pdf RECEIVED Thursday, July 25, 2024 2:31:49 PM IDAHO PUBLIC UTILITIES COMMISSION CHRIS BURDIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 IDAHO BAR NO. 9810 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 THE APPLICATION ) OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07 INCREASE RATES FOR ELECTRIC ) SERVICE TO RECOVER COSTS ) ASSOCIATED WITH INCREMENTAL ) SIXTH PRODUCTION CAPITAL INVESTMENTS AND CERTAIN ) REQUEST OF THE ONGOING OPERATIONS AND ) COMMISSION STAFF MAINTENANCE EXPENSES ) TO IDAHO POWER COMPANY Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company") provide the following documents and information as soon as possible, but no later than THURSDAY,AUGUST 15, 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. SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 JULY 25, 2024 In addition to the written copies provided as response to the requests,please provide all Excel spreadsheets and electronic files with formulae intact and enabled. REQUEST NO. 34: Please provide a detailed description of the Company's revenue normalization method including the process for weather normalization. In the description, please identify any changes in the method from Case No. IPC-E-23-11. Please provide any workpapers and models supporting the revenue and weather normalization methods, in electronic format with links intact and formulae enabled. In addition,please provide all model outputs including model coefficients, statistics, and residuals. REQUEST NO. 35: Please provide a detailed description of the Company's method for forecasting energy sales and revenue in 2024. In the description,please identify any changes in the method for forecasting load growth from Case No. IPC-E-23-11. Please provide any workpapers or models supporting the forecasting method, in electronic format with links intact and formulae enabled. In addition,please provide all model outputs including model coefficients, statistics, and residuals. REQUEST NO. 36: Please provide normalized 2024 actual retail sales revenue and billing determinants for the months of January through June 2024. Please provide all workpapers used to determine the normalized 2024 actual retail sales revenue and billing determinants, in electronic format with links intact and formulae enabled. REQUEST NO. 37: Please explain and reconcile the $5,442,401 difference between the $9,954,229 January adjusted closing amount contained in cell k:84, Tab: `Elec Plant In Service," and the sum of amount $9,951,314 in cell c:44, Tab: "Capital WO Closings< $8M" and the amount$5,445,316 in cell G:19, Tab: "Capital WO Closing> $8M,"having a total of $15,396,630, all of which are contained in workpaper"Staff No. 3 Attachment 3 —Larkin Workpaper 3 —Incremental Plant Determination.xlsx." Please provide any documents or workpapers to explain the difference. REQUEST NO. 38: In Larkin's direct testimony,page 13, he states, "the intent of the incremental revenue requirement request is to determine the amount of incremental revenue SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JULY 25, 2024 necessary to account for increases to capital and O&M Labor between the results of the 2023 Stipulation and expectation for 2024." Please reconcile the starting point for incremental 2024 capital between the 2023 GRC Settled amount of$6,323,823,741 contained in cell C:78, Tab "Incremental Plant," and the $6,571,067,568 amount contained in cell G:84, Tab: "Elec Plant In Service" in workpaper"Staff No. 3 Attachment 3 —Larkin Workpaper 3 —Incremental Plant Determination.xlsx." Please include any documents or workpapers to illustrate your explanations. REQUEST NO. 39: Regarding the Company's determination of incremental 2024 capital, Company Witness Larkin states, "The Company then estimated 2024 capital closings utilizing the same general method applied in the 2023 GRC (i.e, by bifurcating expected plant closing into projects above and below$8 million) ...." Larkin Direct at 14 (emphasis added). Please explain why and when the Company selected the $8 million threshold for tracking individual projects. The $8 million threshold captures approximately $323 million of the forecasted$860 million of incremental plant in service. Please estimate the project dollar threshold that would be necessary to capture 80 percent of the highest cost projects (i.e. approximately $688 million) out of the incremental plant in service being sought for recovery in this case. Please provide a worksheet with formulae intact showing how this was estimated. REQUEST NO. 40: Company Witness Larkin describes the method the Company used to forecast the 2024 plant closing for projects less than $8 million. Larkin Direct at 15. Please provide the worksheets (with formulae enabled)the Company used to calculate this forecast. REQUEST NO. 41: Please provide a detailed comparison of actual plant closings for projects to forecasted plant closings for 2023 by projectibudget ID. For each project, please include: (a)budget ID or project unique identifier; (b)project name; (c)project description; (d) project type; (e)planned and actual in-service dates; (f)budgeted cost vs actual cost, and whether the project was completed by Company or Contractor. SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JULY 25, 2024 REQUEST NO. 42: Please provide a detailed description of the Company's method for developing, managing, executing, and completing Capital Projects that ensures that the projects are procured or built in a least cost manner. Please provide a copy of the Company's policies and procedures documenting the process. REQUEST NO. 43: Please provide a table of each Idaho program category for Wildfire Mitigation("WM") operational and maintenance expenses for 2023 through 2024 similar to the Company's 2024 Wildfire Mitigation Plan("WMP") - Table No. 7. For 2023 and 2024, please provide the forecasted costs and actual cost of each program category. Please identify any proforma adjustments for 2024 and any amount deferred. Additionally, please explain any discrepancies between the forecasted costs estimate and the actual expenses. REQUEST NO. 44: Please provide a table of each Idaho program category for all WM capital expenses for 2023 through 2024. For 2023 and 2024, please provide the forecasted cost and actual cost of each program category. Please identify any proforma adjustments for 2024. Additionally,please explain any discrepancies between the forecasted cost estimate and the actual expenses. REQUEST NO. 45: Please provide all funding sources that the Company has explored and received for its WM capital projects since the last rate case. Please provide supporting documentation including applications, funding award notifications, disbursement, and demonstrate where funds were applied to in this rate case. REQUEST NO. 46: Please describe any occurrences where the Company undergrounded any transmission and/or Idaho distribution lines for WM since the last rate case. Please answer the following: a. Please provide the Company's undergrounding project guidelines; b. Please explain the location selection process for undergrounding; and c. For any completed undergrounding project,please provide a supporting worksheet detailing the initial budget, the actual cost, project start date, date in- SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 JULY 25, 2024 service, location(inside or outside of a Red Risk Zone), and a cost-benefit analysis. REQUEST NO. 47: Please describe any occurrences where the Company installed covered conductor lines for WM in Idaho. Please answer the following: a. Please provide the Company's covered conductor project guidelines; b. Please explain the location selection process for installing covered conductor; and c. For any completed covered conductor projects, please explain the need, location installed (inside or outside of a Red Risk Zone), the need, the actual cost, the total miles installed, and any cost-benefit analysis completed prior to installation. REQUEST NO. 48: On page 23 of the 2024 WMP, the Company stated it issued a RFP in 2023 for a wildfire detection camera pilot project. Please explain if the Company has awarded the RFP to a bidder to date. If so, please provide the following: a. A copy of the selected bid; b. The status of the wildfire detection cameras pilot; c. A total number of cameras installed; and d. The total costs of installation. REQUEST NO. 49: How does the Company rate contractors based on past experience? REQUEST NO. 50: What is the Company's criteria for rating contractors? DATED at Boise, Idaho, this 251h day of July 2024. "A� Chris Burdin Deputy Attorney General I:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#6.docx SIXTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 JULY 25, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS -6- DAY OF JULY 2024, SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-07, BY E-MAILING A COPY THEREOF TO THE FOLLOWING: LISA D. NORDSTROM TIMOTHY TATUM DONOVAN E WALKER CONNIE ASCHENBRENNER MEGAN GOICOECHEA ALLEN MATT LARKIN IDAHO POWER COMPANY IDAHO POWER COMPANY PO BOX 70 PO BOX 70 BOISE ID 83707-0070 BOISE ID 81707-0070 E-MAIL: lnordstromt vidahopower.com E-MAIL: ttatumLcyidahopower.com dwalker c idahopower.com caschenbrennerLidahopower.com mgoicoecheaallen c idahopower.com mlarkin.c idahopower.com dockets c idahopower.com ERIC L OLSEN LANCE KAUFMAN PhD ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE PO BOX 6119 CORVALLIS OR 97330 POCATELLO ID 83205 E-MAIL: lance Lae isg insi t.com E-MAIL: eloL6t echohawk.com PETER J RICHARDSON DR DON READING RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY 515 N 27TH STREET EAGLE ID 83616 BOISE ID 83702 E-MAIL: dreading Lctmindspring.com E-MAIL: peter(Arichardsgnadams.com MATTHEW NYKIEL BRAD HEUSINKVELD ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE 710 N 6TH STREET 710 N 6TH STREET BOISE ID 83702 BOISE ID 83702 E-MAIL: matthew.nvkiehgmail.com E-MAIL: heusinkveldLc't,idahoconservation.org PATRICIA JORDAN, S CRETARY CERTIFICATE OF SERVICE