HomeMy WebLinkAbout20240927IPC to Staff 5 - Fourth Supplemental.pdf —�IQAFIO Re
MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallen(aD_idahopower.com RECEIVED
Friday, September 27, 2024
IDAHO PUBLIC
September 27, 2024 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 Fourth
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,
Megan Goicoechea Allen
MGA:cd
Attachments
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 attachments to Idaho Power Company's Fourth Supplemental Response
to the Second Production Request of the Commission Staff dated September 27, 2024,
contains information that Idaho Power Company and a third party claim are confidential
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 September 2024.
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Megan Goicoechea Allen
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 ) FOURTH 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
information:
IDAHO POWER COMPANY'S FOURTH 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).
FOURTH SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 5: Please see the Fourth Supplemental Response to Request for Production No. 5
— Confidential Attachment 1 for a list of all capital projects that have been placed in-
IDAHO POWER COMPANY'S FOURTH SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2
service during the January 1 , 2024, through August 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 Fourth Supplemental Response to Request for
Production No. 5 — Confidential Attachment 2 for the 2024 plant closings tracker,
comparing the forecasted plant closings through August 2024 used to develop the 2024
test year in this case, to the actual closings through August 2024.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S FOURTH SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3
DATED at Boise, Idaho, this 27th day of September 2024.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
LISA D. NORDSTROM
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S FOURTH 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 September 2024, 1 served a true and
correct copy of Idaho Power Company's Fourth 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 FOURTH 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
C9 >- -
Christy Davenport
Legal Administrative Assistant
IDAHO POWER COMPANY'S FOURTH SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 6