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HomeMy WebLinkAbout20240906IPC to Micron 1-10.pdfLISA D. NORDSTROM Lead Counsel lnordstrom@idahopower.com September 6, 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 Micron Technology, Inc.’s First Production Request 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, Lisa D. Nordstrom LDN:sg Enclosures ' a1DA11> POWER . RECEIVED Friday, September 06, 2024 IDAHO PUBLIC UTILITIES COMMISSION 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 Request No. 1 to Idaho Power Company’s Response to Micron Technology, Inc.’s First Production Request to Idaho Power Company dated September 6, 2024, contains information that Idaho Power Company and/or a third party claim are trade secrets or 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 6th day of September 2024. LISA D. NORDSTROM Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 1 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 lnordstrom@idahopower.com dwalker@idahopower.com mgoicoecheaallen@idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY TO INCREASE RATES FOR ELECTRIC SERVICE TO RECOVER COSTS ASSOCIATED WITH INCREMENTAL CAPITAL INVESTMENTS AND CERTAIN ONGOING OPERATIONS AND MAINTENANCE EXPENSES. ) ) ) ) ) ) ) ) ) CASE NO. IPC-E-24-07 IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to Micron Technology, Inc.’s (“Micron”) First Production Requests to Idaho Power Company dated August 12, 2024, here with submits the following information: IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 2 REQUEST NO. 1: The Direct Testimony of the Company Witness Mr. Larkin at page 10, lines 18-21 states that the final step in determining the sufficiency of existing rates is to layer on increased costs and revenues associated with capital and Operation and Maintenance (“O&M”) Labor in 2024. a. Please explain whether the Company is aware of any costs that are expected to decrease in 2024. b. Please identify each O&M expense item the Company expects to decrease in 2024. c. For each item identified in subpart (b), please provide the amount of the expected cost reduction. Please provide this information in electronic spreadsheet format with all formulas and links intact. RESPONSE TO REQUEST NO. 1: Idaho Power does not possess and has not prepared the requested analysis. However, it is important to note that 2023 Operations & Maintenance (“O&M”) actuals were $346,812,692 compared to the 2024 O&M budget of $400,876,505. Please see Confidential Attachment - Response to Micron Request No. 1 for a comparison of 2023 actual and 2024 budget O&M labor, which is a component of the 2024 Limited Issue Rate Case (“2024 Rate Case”), and non-labor O&M, which is not a component of the 2024 Rate Case. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 3 REQUEST NO. 2: Please indicate whether there are any regulatory asset amortizations that were complete by year end 2023, or that will be complete in 2024. If the response is affirmative, please identify the regulatory asset, and provide the annual amortization expense. RESPONSE TO REQUEST NO. 2: Please see the table below, showing three Regulatory Asset amortizations that were either complete in 2023 or will be completed in 2024. It should be noted that none of these Oregon regulatory asset amortizations are included in Idaho rates. Regulatory Asset Amortization Completion Annual Amortization Expense 182304 - Oregon Arrearage Management Plan 5/31/2023 348,448.20 182305 - Oregon COVID Deferral 5/31/2023 152,965.80 182398 - Oregon Langley Deferral 10/31/2024 369,171.36 The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 4 REQUEST NO. 3: Please provide IPC’s actual 2024 employee headcount. RESPONSE TO REQUEST NO. 3: Employee headcount varies throughout the year. Below is Idaho Power’s 2024 employee headcount by month. 1/29/2024 2/29/2024 3/31/2024 4/30/2024 5/31/2024 6/30/2024 7/31/2024 8/31/2024 Regular Full Time 2057 2055 2057 2057 2063 2068 2068 2068 Regular Part Time 9 10 10 9 9 9 9 8 Temporary Full Time 41 40 36 33 38 36 41 37 Temporary Part Time 0 0 0 0 0 0 0 0 Seasonal Full Time 0 0 0 11 16 18 18 12 Seasonal Part Time 1 1 1 1 0 0 0 0 Total 2108 2106 2104 2111 2126 2131 2136 2125 The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 5 REQUEST NO. 4: Please identify the employee headcount assumed in the Company’s proposed revenue requirement. RESPONSE TO REQUEST NO. 4: The Company’s 2024 O&M labor forecast methodology was not based on an assumed employee headcount. As described in the direct testimony of Matthew Larkin (Larkin, DI 18), the Company developed the 2024 O&M labor forecast by first calculating a three-year history of the ratio between February year-to-date O&M labor expenses and full year O&M labor expenses. This ratio was then applied to month-end February 2024 year-to-date O&M labor to determine the expectation of full year 2024 O&M labor expenses. As noted in Response to Request No. 3 above, the employee headcount was 2,106 as of the end of February 2024. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 6 REQUEST NO. 5: Please explain whether the headcount identified in response to Question 4 includes any open/vacant positions. If the response is affirmative, please identify the number of open/vacant positions included in the proposed revenue requirement. RESPONSE TO REQUEST NO. 5: The headcount identified in response to Question No. 4 does not include any open/vacant positions. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 7 REQUEST NO. 6: Please indicate whether the Company has reflected annualized increased revenues associated with load growth as an offset to the proposed revenue requirement in this case. If not, please explain why not. If so, please provide the calculations of the additional revenue expected from load growth, and show how it was applied as an offset to the requested revenue requirement in this case. Please provide all calculations in electronic spreadsheet format with all formulas and links intact. RESPONSE TO REQUEST NO. 6: Yes, as described in pages 20-21 of the direct testimony of Mr. Larkin, the Company included the increased revenue collection due to sales growth between the 2023 General Rate Case (“GRC”) Stipulation and 2024 for the capital and O&M labor components embedded in retail rates as a result of the 2023 GRC. The calculation of the revenue offset was provided in Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company dated July 5, 2024, labeled “Attachment 7 – Response to Staff Request No. 3 – Larkin Workpaper 7 – Revenue Growth Offset.” The revenue offset was included in Table 4, row 357 in Larkin Exhibit 10 and is an offset to the total revenue requirement. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 8 REQUEST NO. 7: Please refer to page 16, lines 5-6 of Direct Testimony of Company Witness Mr. Larkin where he states accumulated depreciation was determined based on a mid-year convention. Please provide the amount of accumulated depreciation at the beginning of the year, the end of the year, and the mid-year average calculated by the Company. Please provide workpapers, in an electronic format with all formulas and links intact, to support the accumulated depreciation amounts. RESPONSE TO REQUEST NO. 7: The requested information is provided in the following table - Accumulated Depreciation 12/31/2023 (A) 12/31/2024 (B) Mid-Year ((A+B)/2) 2,146,074,331 2,202,464,827 2,174,269,579 The accumulated depreciation workpaper was provided in Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company dated July 5, 2024, labeled “Attachment 1 – Response to Staff Request No. 3 - Larkin Workpaper 1 – Accumulated Reserve.” The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 9 REQUEST NO. 8: Please refer to page 11, lines 1-2 of Direct Testimony of Company Witness Mr. Larkin where he states plant balances were estimated at year end. Please provide the plant balances at the beginning of the year, the end of the year, and a mid-year average. Please provide workpapers, in an electronic format with all formulas and links intact, to support the plant balances. RESPONSE TO REQUEST NO. 8: The requested information is provided in the following table - Plant Balances 12/31/2023 (A) 12/31/2024 (B) Mid-Year ((A+B)/2) 6,571,067,568 7,184,190,289 6,877,628,928 The plant workpaper was provided in Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company dated July 5, 2024, labeled “Attachment 3 – Response to Staff Request No. 3 - Larkin Workpaper 3 – Incremental Plant Determination.” The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 10 REQUEST NO. 9: Please explain why the Company is forecasting plant balances at year-end but calculating accumulated depreciation using a mid-year convention. Please provide workpapers calculating the Company’s revenue requirement if plant balances were also forecasted using a mid-year approach as the Company has proposed for accumulated depreciation. Please also provide workpapers calculating the Company’s revenue requirement if accumulated depreciation is forecasted at year-end as the Company has proposed for plant balances. RESPONSE TO REQUEST NO. 9: The Company used the mid-year convention for accumulated depreciation because it assumes that assets are acquired and placed into service evenly throughout the year, rather than assuming all assets are placed in service at the beginning of the test year. The Excel workpaper labeled “Attachment 1 – Response to Micron’s Request No. 9_2024 JSS Scenarios” contains two tabs labeled “2024 – Year-End Accum Depr,” and “2024 – Mid Year Plant” which contains the requested revenue requirement scenarios. Attachments 2 and 3 are the accompanying workpapers calculating the incremental year- end Accumulated Depreciation and the incremental 2024 mid-year plant values used in the revenue requirement scenarios. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 11 REQUEST NO. 10: Please provide electronic versions of Mr. Larkin’s exhibits, with all formulas and links intact. RESPONSE TO REQUEST NO. 10: Please see the following attachments to Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company dated July 5, 2024.  Attachment No. 11 – Response to Staff Request No. 3 – Larkin Exhibit No. 6 – Results of Operations;  Attachment No. 12 – Response to Staff Request No. 3 – Larkin Exhibit No. 7 – Incremental Plant Determination;  Attachment No. 13 – Response to Staff Request No. 3 – Larkin Exhibit No. 8 – Incremental Labor Determination;  Attachment No. 14 – Response to Staff Request No. 3 – Larkin Exhibit No. 9 – Revenue Growth Offset; and  Attachment No. 15 – Response to Staff Request No. 3 – Larkin Exhibit No. 10 – 2024 JSS. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 12 REQUEST NO. 11: Please refer to page 20, lines 17-24 of Direct Testimony of Company Witness Larkin where he states, that to “determine the appropriate level of revenue growth to apply as an offset…[f]irst, Idaho Power determined an estimated cents- per-kilowatt-hour (“kWh”) rate of cost recovery for capital-related items and O&M Labor that is currently embedded in retail rates as a result of the 2023 GRC.” Please provide workpapers supporting this estimated kWh rate. RESPONSE TO REQUEST NO. 11: The calculation of the estimated kWh rate was provided in Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company dated July 5, 2024, labeled ‘Attachment No. 14 – Response to Staff Request No. 3 – Larkin Exhibit No. 9 – Revenue Growth Offset.” The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 13 DATED at Boise, Idaho, this 6th day of September 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 MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 14 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 6th day of September 2024, I served a true and correct copy of Idaho Power Company’s Response to Micron Technology, Inc.’s First Production Requests to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Chris Burdin Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8 Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email Chris.Burdin@puc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Richardson Adams, PLLC 515 N. 27th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter@richardsonadams.com Dr. Don Reading 280 Silverwood Way Eagle, Idaho 83616 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email dreading@mindspring.com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, Idaho 83205 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email elo@echohawk.com Lance Kaufman, Ph.D. 2623 NW Bluebell Place Corvallis, OR 97330 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email lance@aegisinsight.com IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 15 Idaho Conservation League Brad Heusinkveld 710 N. 6th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email bheusinkveld@idahoconservation.org Micron Technology, Inc. Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen Kristine A.K. Roach Holland & Hart LLP 555 17th Street, Suite 3200 Denver, CO 80202 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com karoach@hollandhart.com aclee@hollandhart.com mamcmillen@hollandhart.com Jim Swier Micron Technology, Inc. 8000 South Federal Way Boise, ID 83707 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email jswier@micron.com City of Boise Ed Jewell Deputy City Attorney Boise City Attorney’s Office 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email BoiseCityAttorney@cityofboise.org ejewell@cityofboise.org IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION REQUESTS TO IDAHO POWER - 16 Steven Hubble Boise City Dept. of Public Works 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email shubble@cityofboise.org Federal Executive Agencies Peter Meier Emily W. Medlyn U.S. Department of Energy 1000 Independence Ave., S.W. Washington, DC 20585 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter.meier@hq.doe.gov emily.medlyn@hq.doe.gov Stacy Gust Regulatory Administrative Assistant ~ ~