20240725Staff 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
[phone]
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