HomeMy WebLinkAbout20241021IPC to Staff 62-63 Second Supplemental.pdf 0-10AM POWER.
MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaal len(aDidahopower.com
RECEIVED
Monday, October 21, 2024
October 21, 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 Second
Supplemental 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.
Sincerely,
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Megan Goicoechea Allen
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Attachments
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707
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 in response to Request Nos. 62 and 63 to Idaho
Power Company's Second Supplemental Response to the Eighth Production Request
of the Commission Staff dated October 21, 2024, contains information that Idaho Power
Company claims 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 21 st day of October 2024.
�-%r T i
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(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 ) CASE NO. IPC-E-24-07
COMPANY TO INCREASE RATES FOR )
ELECTRIC SERVICE TO RECOVER ) IDAHO POWER COMPANY'S
COSTS ASSOCIATED WITH ) SECOND SUPPLEMENTAL
INCREMENTAL CAPITAL ) RESPONSE TO THE EIGHTH
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 Eighth Production Request of the Commission Staff ("Commission" or
"Staff")to Idaho Power Company dated July 31, 2024, herewith supplements the following
information:
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 1
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.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 62: Please see the file labeled "Second Supplemental Response to Staff Request
No. 62 — Confidential Attachment" for actual Electric Plant In Service balances through
the most current month available, September 2024.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 2
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.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 63: Please see the file labeled "Second Supplemental Response to Staff Request
No. 63 — Confidential Attachment" for actual 2024 Depreciation Expense and
Accumulated Reserve balances through the most current month available, September
2024.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 3
DATED at Boise, Idaho, this 21St day of October 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 SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 21st day of October 2024, 1 served a true and
correct copy of Idaho Power Company's Second Supplemental 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 SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 5
Idaho Conservation League Hand Delivered
Brad Heusinkveld U.S. Mail
710 N. 6t" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email
bheusinkveld(b-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-hol land hart.com
Denver, CO 80202 tnelson(a)-hol land hart.com
awjensen(d0ollandhart.com
karoach(cbhol land hart.com
aclee(o)-hollandhart.com
mamcmillen(a)hol land hart.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(q)_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
ejewell(a-)-cityofboise.org
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTH
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 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 SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 7