HomeMy WebLinkAbout20240827IPC to Staff Supplemental 5.pdf -�IQAFIO Re
LISA NORDSTROM
Lead Counsel
Inordstrom(cD_idahopower.com RECEIVED
Tuesday, August 27, 2024
August 27, 2024 IDAHO PUBLIC
UTILITIES COMMISSION
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 Third
Supplemental Response to the Second 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.
Sincerely,
Lisa Nordstrom
LN:cd
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 the attachment to Idaho Power Company's Third Supplemental Response
to the Second Production Request of the Commission Staff dated August 27, 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 27th 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(a)_idahopower.com
dwalker idahopower.com
mgoicoecheaallen(o)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07
COMPANY TO INCREASE RATES FOR )
ELECTRIC SERVICE TO RECOVER ) IDAHO POWER COMPANY'S
COSTS ASSOCIATED WITH ) THIRD SUPPLEMENTAL
INCREMENTAL CAPITAL ) RESPONSE TO THE SECOND
INVESTMENTS AND CERTAIN ) PRODUCTION REQUEST OF THE
ONGOING OPERATIONS AND ) COMMISSION STAFF TO IDAHO
MAINTENANCE EXPENSES. ) POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated June 21, 2023, herewith submits the following
supplemental information:
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 1
REQUEST FOR PRODUCTION NO. 5: Please provide an Excel spreadsheet with
formulas intact and enabled showing all capital projects that make up the $860,366,584
of Capital Project Cost the Company is proposing for recovery in this case. For each
project, please include the following:
a. Plant Account Description (Such as "Intangible Plant", "Hydro Production Plant",
etc. as shown in Larkin's Workpaper No. 3, page 1);
b. Project Type Description (As shown in Larkin's Workpaper No. 3, page 8— Column
2);
c. Project ID/Unique Project Identifier;
d. Project Name/Title;
e. Detailed Project Description;
f. Business Need;
g. Actual Project Start Date;
h. Anticipated/Actual In-Service Date;
i. Budgeted Cost by Year;
j. Annual Actual Project Cost to Date (Broken out by year);
k. Cost Benefit Analysis Completed (Yes/No);
I. Request for Proposal Completed (Yes/No);
m. Wildfire Mitigation Related (Yes/No); and
n. Grant Funding Awarded (Yes/No).
THIRD SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO.
5: Please see the Third Supplemental Response to Request for Production No. 5 —
Confidential Attachment 1 for a list of all capital projects that have been placed in-service
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 2
during the January 1 , 2024, through July 31, 2024, time period, with the inclusion on the
Work Orders by Plant Type — BID tab of the functional plant type. The column "Functional
Plant Type" indicates the category for each Budget ID listed in the "BUDGET_ID" column.
The numerical Project Type can be found in Excel Column B, "PROJECT TYPE,"
indicating the Project Type assigned to the Budget ID as a whole (i.e., the Project Type
that reflects the primary function of the Budget ID). A key that ties the numeric Project
Type to the Functional Plant Type can be found in the "Functional Plant Type" tab. In
addition, Idaho Power added to the Work Orders by Plant Type — BID tab an indicator to
identify the blanket Budget IDs. This can be found in Excel Column K, titled "BLANKET
BUDGET ID." Blanket Budget IDs are indicated by a "Yes" in this column, while the
column is blank for non-blanket Budget IDs. It should also be noted that the Company
has categorized programs (e.g., underground cable replacement) as blanket Budget IDs
for the purpose of this response.
In addition, please see the Third Supplemental Response to Request for
Production No. 5 — Confidential Attachment 2 for the 2024 plant closings tracker,
comparing the forecasted plant closings through July 2024 used to develop the 2024 test
year in this case, to the actual closings through July 2024.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 3
DATED at Boise, Idaho, this 27th 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 THIRD SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 27th day of August 2024, 1 served a true and
correct copy of Idaho Power Company's Third Supplemental Response to the Second
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(a-),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. 27t" Street FAX
Boise, Idaho 83702 FTP Site
X Email peter _richardsonadams.com
Dr. Don Reading Hand Delivered
280 Silverwood Way U.S. Mail
Eagle, Idaho 83616 Overnight Mail
FAX
FTP Site
X Email dread ing(@ 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(o)_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 THIRD SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 5
Idaho Conservation League Hand Delivered
Matthew Nykiel U.S. Mail
710 N. 6t" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email
Matthew.n kiel mail.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 17t" Street, Suite 3200 darueschhoff(a)_hollandhart.com
Denver, CO 80202 tnelson hollandhart.com
awiensen(o)-hollandhart.com
karoach(ahol land hart.com
aclee hollandhart.corn
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
iswier _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
eiewel I(d_)cityofboise.org
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 6
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(aD.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
peter.meier(o-)_hg.doe.gov
emily.medlyn(q-),hg.doe.gov
Christy Davenport
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S THIRD SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 7