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Home My WebLink About20240821IPC to Staff 59-67.pdf 0-10AM POWER. RECEIVED LISA D. NORDSTROM Wednesday,August 21, 2024 Lead Counsel IDAHO PUBLIC Inordstrom(EDidahopower.com UTILITIES COMMISSION August 21, 2024 VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Response to the Eighth Production Request of the Commission Staff to Idaho Power Company. Due to the collectively voluminous confidential and non-confidential information provided in response to data requests in this case, the Company is posting the attachments to these requests to the secure FTP site to allow parties to view the requested information remotely unless otherwise noted in the response. Because certain attachments contain confidential information, the FTP site is divided between confidential and non-confidential information. The login information for the non-confidential portion of the FTP site has been provided to all parties that have intervened to date. The login information for the confidential portion of the FTP site will be provided to the parties that execute the Protective Agreement in this matter. If you have any questions about the attached filing, please do not hesitate to contact me. Very truly yours, �4k, D � Lisa D. Nordstrom LDN:sg Enclosures CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-24-07 Idaho Power Company's Application for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that some of the attachments to Request Nos. 62, 63, and 66 to Idaho Power Company's Response to the Eighth Production Request of the Commission Staff dated August 21, 2024, contains information that Idaho Power Company and/or a third party claim are trade secrets, business records of a private enterprise required by law to be submitted to or inspected by a public agency, and/or public records exempt from disclosure by state or federal law (material nonpublic information under U.S. Securities and Exchange Commission Regulation FD) as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 21 st day of August 2024. LISA D. NORDSTROM Attorney for Idaho Power Company LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(aMdahopower.com dwalker idahopower.com mgoicoecheaallenCabidahopower.com Attorneys for Idaho Power Company 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 ) IDAHO POWER COMPANY'S ASSOCIATED WITH INCREMENTAL ) RESPONSE TO THE EIGHTH CAPITAL INVESTMENTS AND ) PRODUCTION REQUEST OF THE CERTAIN ONGOING OPERATIONS ) COMMISSION STAFF TO IDAHO AND MAINTENANCE EXPENSES. ) POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Eighth Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated July 31, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 1 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 59: Insurance settlements received for repair of company assets due to damage from vehicle crashes or other human causes are applied as an offset against the total repair costs, reducing the amount of assets in electric plant in service. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 60: Please see the file labeled "Response to Staff Request Nos. 60-61 — Attachment - Rates and Revenue Calculation" for the workpaper used to calculate the base and billed revenue for each rate schedule provided in Application Attachment 3. The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 61: Please provide the workpapers used to calculate the proposed rates included in the proposed tariffs for each rate schedule. RESPONSE TO REQUEST FOR PRODUCTION NO. 61: Please see the file labeled "Response to Staff Request Nos. 60-61 — Attachment - Rates and Revenue Calculation" for the workpaper used to calculate the proposed rates included in the proposed tariffs for each rate schedule. The rounding function (Cell L2 on the `Rates' tab) must be turned "on" to tie to the rates included in the proposed tariffs for each rate schedule. The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER -4 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 62: Please see the file labeled "Response to Staff Request No. 62 — Confidential Attachment" for actual Electric Plant In Service balances through the most current month available, July 2024. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 5 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 63: Please see the file labeled "Response to Staff Request No. 63 — Confidential Attachment" for actual 2024 Depreciation Expense and Accumulated Reserve balances through the most current month available, July 2024. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 6 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 64: Idaho Power used the most current 2024 information available when calculating the annualizing adjustment. The February 2024 indirect benefit loading rate is higher than 2023 mostly driven by higher medical costs. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 7 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 65: Idaho Power respectfully notes that the 2023 actual labor from the "2023 Actual Payroll — Source Pg1" Tab of Larkin Workpaper#5 — Operations & Maintenance ("O&M") labor is $238,650,681, not $348,650,681. The values differ because the $238,650,681 represents straight time labor for all accounts (O&M, Capital, etc.) compared to the $179,712,486 which includes only O&M labor cost elements, excluding incentive and pension. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 8 REQUEST FOR PRODUCTION NO. 66: Please update the 2024 payroll table through the month of June in the Larkin Workpaper 5, "Labor Development" tab. RESPONSE TO REQUEST FOR PRODUCTION NO. 66: Please see Response to Staff Request No. 66 — Confidential Attachment. Idaho Power is providing updated 2024 O&M payroll through the month of July because it has recently become available. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 9 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 67: The variance between December 2023 O&M labor and January 2024 O&M labor is primarily due to the 2024 general wage adjustment and higher employer-paid taxes. Additionally, there were twenty-one workdays in January 2024 compared to twenty workdays in December 2023. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 10 DATED at Boise, Idaho, this 21 st day of August 2024. LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 21st day of August 2024, 1 served a true and correct copy of Idaho Power Company's Response to the Eighth Production Request of the Commission Staff to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Chris.Burdin(c�puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Industrial Customers of Idaho Power Hand Delivered Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27' Street FAX Boise, Idaho 83702 FTP Site X Email peterC@richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dreading(@mindspring.com Idaho Irrigation Pumpers Association, Hand Delivered Inc. U.S. Mail Eric L. Olsen Overnight Mail ECHO HAWK & OLSEN, PLLC FAX 505 Pershing Avenue, Suite 100 FTP Site P.O. Box 6119 X Email elo _echohawk.com Pocatello, Idaho 83205 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance aegisinsight.com IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 12 Idaho Conservation League Hand Delivered Matthew A. Nykiel U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email matthew.nykiel(Dgmail.com Brad Heusinkveld Hand Delivered Idaho Conservation League U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email bheusinkveld(a)idahoconservation.org Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach FTP Site Holland & Hart LLP X Email 555 17' Street, Suite 3200 darueschhoff(c)_hol land hart.com Denver, CO 80202 tnelson(a)-hol land hart.com awjensen _hol land hart.com karoach(a)hollandhart.com acleeC@hollandhart.com mamcmillen(a-),hollandhart.com Jim Swier Hand Delivered Micron Technology, Inc. U.S. Mail 8000 South Federal Way Overnight Mail Boise, ID 83707 FAX FTP Site X Email jswier micron.com City of Boise Hand Delivered Ed Jewell U.S. Mail Deputy City Attorney Overnight Mail Boise City Attorney's Office FAX 150 N. Capitol Blvd. FTP Site P.O. Box 500 X Email Boise, Idaho 83701 BoiseCityAttorney(a�-cityofboise.org e newel I6c)cityofboise.org IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 13 Steven Hubble Hand Delivered Boise City Dept. of Public Works U.S. Mail 150 N. Capitol Blvd. Overnight Mail P.O. Box 500 FAX Boise, Idaho 83701-0500 FTP Site X Email shubble cityofboise.org Federal Executive Agencies Hand Delivered Peter Meier U.S. Mail Emily W. Medlyn Overnight Mail U.S. Department of Energy FAX 1000 Independence Ave., S.W. FTP Site Washington, DC 20585 X Email Pete r.meier(a�hg.doe.gov emily.medlyn(o)_hg.doe.gov Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 14