20241114FEA to IIPA 1-4.pdf

RECEIVED
Thursday, November 14, 2024
IDAHO PUBLIC
Peter Meier UTILITIES COMMISSION
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
[e-mail]
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 ) IDAHO IRRIGATION
PUMPERS ASSOCATION
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 Idaho Irrigation Pumpers Association. FEA
requests that Idaho Irrigation Pumpers Association 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
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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 2, lines 18-20, of Dr. Kaufman's Direct Testimony, he states "...it
may be appropriate to place greater weight on winter demand peaks because winter demand is
more costly to serve." Please provide all data, studies, analyses, and explanations to support this
statement.
REQUEST NO. 2. On page 3, lines 1-2, of Dr. Kaufinan's Written Testimony, he states "...all
customers within a margin of error of 5 percent should receive similar rate increases."
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a. Please explain what is meant by "margin of error" as used in Dr. Kaufman's
testimony.
b. Please provide all data, studies, calculations, statistical analysis, and explanations to
support the view that cost of service studies have a 5 percent margin of error.
c. Please provide any examples of where this measure of"margin of error"has been
used in a rate case proceeding and any orders in which it has been adopted or
approved.
REQUEST NO. 3. For Table 1 on page 4 of Dr. Kaufman's Written Testimony, please provide
all workpapers with source data and formulae used to produce this table in executable, electronic
format.
REQUEST NO. 4. Please provide any examples from other rate cases in which the "COS
Index" as calculated by Dr. Kaufman has been used for the determination of revenue spread and
any orders in which this approach has been adopted or approved.
Respectfully submitted, this 141h day of November 2024.
FEDERAL EXECUTIVE AGENCIES
BY THE U.S. DEPARTMENT OF ENERGY
CA A 41�"7�1� —
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: [phone]
Fax: [phone]
peter.meier&hq.doe.gov
[e-mail]
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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 IDAHO IRRIGATION PUMPERS ASSOCATION on the
parties of record to this proceeding.
DATED November 14, 2024.
atw
� _k e
Emily W. Medlyn
Attorney-Adviser
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
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