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HomeMy WebLinkAbout20240731Staff 59-67 to IPC.pdf RECEIVED Wednesday, July 31, 2024 4.09.39 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 ) EIGHTH 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 WEDNESDAY,AUGUST 21, 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. EIGHTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 JULY 31, 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. 59: Please explain the accounting treatment applied to insurance settlements received for the recovery of the cost of repairs to Company assets that were damaged due to vehicle crashes or other human causes and how it impacts the customer rates. REQUEST NO. 60: In the Company's response to Staff Production Request No. 3, the Excel file titled"Attachment 9 -Response to Staff Request No. 3 -Application Attachment 3" included hardcoded numbers for the base and billed revenue numbers for each rate schedule. Please provide the workpapers used to calculate the base and billed revenue numbers for each rate schedule provided in Application Attachment No. 3. REQUEST NO. 61: Please provide the workpapers used to calculate the proposed rates included in the proposed tariffs for each rate schedule. REQUEST NO. 62: Please provide updates for the Larkin workpaper"Incremental Plant Determination" sections "Incremental Plant" and"Elec Plant In Service", which includes the latest actuals through the most current month available. Please provide calculations for the 13-month average of monthly averages using actuals for the latest 13 months. Please supplement this request as additional monthly ending balances become known. REQUEST NO. 63: Please provide updates for the Larkin workpaper"Depreciation and Amortization Expense" sections "Expense" and"Incremental", which includes the latest actuals through the most current month available. Please supplement this request as additional monthly ending balances become known. REQUEST NO. 64: Please explain why the Company used the February 2024 benefit percentage of 40.52%, instead of the 2023 benefit percentage of 35.88%when calculating the "Annualized December 2024 O&M ST w/Loading" in Larkin Workpaper 5, "Payroll-Source Page A"tab. EIGHTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JULY 31, 2024 REQUEST NO. 65: Please reconcile the $179,712,486 which is the total 2023 O&M labor from the"Labor Development"tab, and the $348,650,681 which is the 2023 actual labor from the"2023 Actual Payroll—Source Pg1" tab of Larkin Workpaper#5 —O&M labor. REQUEST NO. 66: Please update the 2024 payroll table through the month of June in the Larkin Workpaper 5, "Labor Development" tab. REQUEST NO. 67: Please explain the reason why January payroll 2024 increased by almost two million from December 2023? In the "Labor Development" tab of"Larkin Workpaper#5 —O&M Labor", December 2023 payroll totaled to $15,128,897, and January 2024 payroll totaled $17,043,196. DATED at Boise, Idaho, this 3 1"day of July 2024. b,v4 Chris Burdin Deputy Attorney General I:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#8.docx EIGHTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JULY 31, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS J l DAY OF JULY 2024, SERVED THE FOREGOING EIGHTH 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 83707-0070 E-MAIL: lnordstrom(cbidahopower.com E-MAIL: ttatum ctidahopower.com dwalker,c idahopower.com caschenbrennerL(6dahopower.com mgoicoecheaallen�c idahopower.com mlarkinLaidahopower.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(waegisinsi hg t.com E-MAIL: elo Lctechohawk.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_ct mindspring com E-MAIL: peter ctrichardsonadams.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.nykiel t)gmail.com E-MAIL: heusinkveldLaidahoconservation.or< PETER MEIER EMILY W MEDLYN US DEPT OF ENERGY US DEPT OF ENERGY 1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW WASHINGTON DC 20585 WASHINGTON DC 20585 E-MAIL: peter.meier(ct,,hq.doe.gov E-MAIL: hmily.medlyn�hq.doe.gov CERTIFICATE OF SERVICE JIM SWIER AUSTIN RUESCHHOFF MICRON TECHNOLOGY INC THORVALD A NELSON 8000 S FEDERAL WAY AUSTIN W JENSEN BOISE ID 83707 KRISTINE A.K. ROACH E-MAIL: jswier(�t'Lmicron.com HOLLAND &HART LLP 555 17TH ST STE 3200 DENVER CO 80202 E-MAIL: darueschhoff thollandhart_com tnelson c hollandhart.com awiensen c hollandhart.com karoach,c hollandhart.com aclee�,hollandhart.com mamcmi l lenLct ho l l andhart.com ED JEWELL STEVEN HUBBLE DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS BOISE CITY ATTORNEY'S PO BOX 500 PO BOX 500 BOISE ID 83701-0500 BOISE ID 83701-0500 E-MAIL: shubbleLctcitvofboise.org E-MAIL: ejewell���citvofboise.org boisecitvattornev�cLcitvofboise.org, PATRICIA JORDAN SECRETARY CERTIFICATE OF SERVICE