20240815Staff 11-17 to IPC.pdf

RECEIVED
Thursday, August 15, 2024 12:07:09 PM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
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 IDAHO POWER )
COMPANY'S COMPLIANCE FILING TO ) CASE NO. IPC-E-24-22
UPDATE THE CUSTOMER SURCHARGE TO )
COLLECT INCREMENTAL COSTS OF ) SECOND PRODUCTION
DISTRIBUTION UNDERGROUNDING OF ) REQUEST OF THE
THE NEW 138 KV TRANSMISSION LINE IN ) COMMISSION STAFF
THE WOOD RIVER VALLEY AND ) TO IDAHO POWER COMPANY
ESTABLISH NECESSARY REGULATORY )
ACCOUNTING TREATMENT )
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Idaho Power Company("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY, SEPTEMBER 5, 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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 15, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 11: Paragraphs 31 and 32 of the Company's Filing explain the method
used to estimate the incremental costs of the hypothetical distribution line approved in the 2017
CPCN. Filing at 12. Please explain the following:
a. Please explain why the Company removed"most of the distribution poles,"rather
than all the poles; and
b. Please explain why the Company added the following two items:
i. The replacement of a portion of the existing wood poles with taller, steel
poles; and
ii. Distribution intersect poles.
REQUEST NO. 12: In Attachment 1 of the Company's response to Production Request
No. 1,please explain why transmission costs, like labor for"[Transmission and Distribution
("T&D")] Reliability Engineering," "Transmission Line Design," "Transmission Line
Maintenance," and"T&D Line Operations," are included in the distribution project cost estimate
($19,994,550). Additionally,
a. If transmission costs are also included in other categories, please provide only the
distribution-related project cost, removing any transmission cost from the actual cost.
b. Please provide any documents such as service agreements, and invoices to match total
cost of each cost category in Response to Production Request No. 1 Attachment 1,
including the work description and scope.
REQUEST NO. 13: Please explain why the base year is 2023 for the Net Present Value
("NPV") calculation of the 20-year surcharge collection, although the in-service year and
surcharge collection year are 2024, as shown in the attachment in the Company's Response to
Production Request No. 5.
REQUEST NO. 14: In the attachment included in Response to Production Request No.
5, the administration fee is included in the NPV calculation of the annual surcharge collection
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 15, 2024

($6,553,200), even though the Company noted the fee is excluded in the Response to Production
Request No. 5. Please provide a detailed explanation of this discrepancy and make any
corrections to the Company's responses through an amendment.
REQUEST NO. 15: For the actual underground distribution project underway in Blaine
County please provide the following:
a. Please provide the initial project management Gantt chart at the start of construction.
It should show the major elements of work, their expected duration and dependencies,
and the work-in-place monetary values assigned to each element; and
b. Please provide the most current project management Gantt chart showing the actual
work completed and the remaining work schedule.
REQUEST NO. 16: The Company's Response to Production Request No. 5 assumes a
discount rate of 8.91%. Please explain the Company's reasons for selecting this value and
provide worksheets for any related calculations.
REQUEST NO. 17: The Company's Response to Production Request No. 9 provided
historical customer data for Blaine County. The average year-over-year change between 2012
and 2023 is 0.2 percent. Please explain why the Company assumes 1.0 percent customer growth
for the next 20 years in its calculation of the surcharge.
DATED at Boise, Idaho, this 151h day of August 2024.
Michael Duval
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-22 PR#2.docx
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 15, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS JODAY OF AUGUST 2024,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-22,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER ALISON WILLIAMS
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalkergidahopower.com E-MAIL: awilliamsgidahopower.com
dockets(kidahopower.com
2� � 1)laaw o
PATRICIA JORDAN
CERTIFICATE OF SERVICE