20240731Staff 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
[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 ) 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