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HomeMy WebLinkAbout20241114FEA to ICIP 1-3.pdf RECEIVED Thursday, November 14, 2024 IDAHO PUBLIC UTILITIES COMMISSION Peter Meier Emily W. Medlyn U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 Phone: 240-578-3364 peter.meier@hq.doe.gov emily.medlyn@hq.doe.gov Attorneys for the Federal Executive Agencies BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07 OF IDAHO POWER COMPANY TO ) INCREASE RATES FOR ELECTRIC ) SERVICE TO RECOVER COSTS ) THE FEDERAL EXECUTIVE ASSOCIATED WITH INCREMENTAL ) AGENCIES' FIRST CAPITAL INVESTMENTS AND CERTAIN ) PRODUCTION REQUEST AND ONGOING OPERATIONS AND ) INTERROGATORIES TO MAINTENANCE EXPENSES ) INDUSTRIAL CUSTOMERS OF IDAHO POWER Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission, The Federal Executive Agencies ("FEA"),by and through its legal counsel, hereby submits its First Production Request and Interrogatories to Industrial Customers of Idaho Power. FEA requests that Industrial Customers of Idaho Power provide responses by November 25, 2024. These requests are continuing in nature and require supplemental answers within a reasonable time if additional documents or information would be responsive to these requests. The terms "document(s)" or"workpaper(s)" are used in their broadest sense to include, by way of illustration and not limitation, all written or graphic matter of every kind and description whether printed, produced or reproduced by any process whether visually, magnetically, mechanically, electronically or by hand, whether final or draft, original or reproduction, whether or not claimed to be privileged or otherwise excludable from discovery, and whether or not in l your actual or constructive possession, custody, or control. The terms including writings, correspondence, telegrams, memoranda, studies, reports, surveys, statistical compilations, notes calendars, tapes, computer disks, electronic storage of any type, data on computer drives, emails, cards, recordings, contracts, agreements, invoices, licenses, diaries,journals, accounts, pamphlets, books, ledgers, publications, microfilm, microfiche and any other data compilations from which information can be obtained and translated,by you if necessary, into reasonably usable form. "Document(s)"or"workpaper(s)" shall also include every copy of a document where the copy contains any commentary or notation of any kind that does not appear on the original or any other copy. The terms "and" and"or" shall be construed as either disjunctive or conjunctive as necessary to make the request inclusive rather than exclusive. "Each" shall be construed to include the word"every" and"every" shall be construed to include the word"each." "Any" shall be construed to include "all" and"all" shall be construed to include "any." The term "concerning" includes the following meanings: relating to; pertaining to; regarding; discussing; mentioning; containing; reflecting; evidencing; describing; showing; identifying; providing; disproving; consisting of; supporting; contradicting; in any way legally, logically, or factually connected with the matter to which the term refers; or having a tendency to prove or disprove the matter to which the term refers. The term "including"means and refers to "including but not limited to." Words used in the plural shall also be taken to mean and include the singular. Words used in the singular shall also be taken to mean and include the plural. The present tense shall be construed to include the past tense, and the past tense shall be construed to include the present tense. REQUEST NO. 1. On page 13, lines 8-11, of Dr. Reading's Direct Testimony, he states "...I recommend that the percentage difference between the overall rate increase and each individual rate class's rate increase be the same percentage difference that was used and approved by the commission in the last rate case." Please provide any examples from other rate cases in which Dr. Reading's recommendation has been used for the determination of revenue spread and any orders in which this approach has been adopted or approved. 2 REQUEST NO. 2. For the table on page 14 of Dr. Reading's Direct Testimony,please provide all workpapers used to produce this table in executable, electronic format. REQUEST NO. 3. Please provide all approaches for revenue spread considered by Dr. Reading in developing his recommended approach for revenue spread and fully explain why his recommended approach is preferable. Respectfully submitted, this 141h day of November 2024. FEDERAL EXECUTIVE AGENCIES BY THE U.S. DEPARTMENT OF ENERGY — at A- 411031 1 11�� - Emily W. Medlyn Attorney-Adviser Peter Meier Emily W. Medlyn U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 Phone: 240-578-3364 Fax: 202-586-4116 peter.meier(a?hq.doe.gov emily.medlyn@hg.doe.gov 3 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07 OF IDAHO POWER COMPANY TO ) INCREASE RATES FOR ELECTRIC ) SERVICE TO RECOVER COSTS ) CERTIFICATE OF SERVICE ASSOCIATED WITH INCREMENTAL ) CAPITAL INVESTMENTS AND CERTAIN ) ONGOING OPERATIONS AND ) MAINTENANCE EXPENSES ) I CERTIFY that on this date I sent by email a true and correct copy of THE FEDERAL EXECUTIVE AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES TO INDUSTRIAL CUSTOMERS OF IDAHO POWER on the parties of record to this proceeding. DATED November 14, 2024. 6.4..A- f1J. Emily W. Medlyn Attorney-Adviser U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 Phone: 240-578-3364 emily.medlyn@hq.doe.gov 4