20241119ICIP to FEA 1-3.pdf

RECEIVED
Tuesday, November 19, 2024
IDAHO PUBLIC
I Peter Richardson, ISB # 3195 UTILITIES COMMISSION
RICHARDSON ADAMS, PLLC
2 515 N. 27"' Street
3 Boise, Idaho 83702
pcicr iirichardsonadai-ns.com
4 - -
5 BEFORE THE IDAHO
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PUBLIC UTILITIES COMMISSION
7
IN THE MATTER OF THE APPLICATION Case No.: IPC-E-24-07
8 OF IDAHO POWER COMPANY TO
9 INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS THE INDUSTRIAL CUSTOMERS OF
10 ASSOCIATED WITH INCREMENTAL IDAHO POWER'S RESPONSE TO THE
CAPITAL INVESTMENTS AND CERTAIN FEDERAL EXECUTIVE AGENCIES' FIRST
I I ONGOING OPERATIONS AND
PRODUCTION REQUEST AND
12 MAINTENANCE EXPENSES INTERROGATORIES
13
The Industrial Customers of Idaho Power hereby respond to the Federal Executive
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IS Agencies' First Production Request and Interrogatories. All responses herein were prepared by
16 Dr. Reading in consultation with counsel. Dr. Reading will be able to answer questions about
17 and/or sponsor these responses at hearing
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28 THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSE TO THE FEDERAL EXECUTIVE
AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES- I

I REQUEST NO. 1. On page 13, lines 8-11 of Dr. Reading's Direct Testimony, he states "...I
2 recommend that the percentage difference between the overall rate increase and each individual
3
rate class's rate increase be the same percentage difference that was used and approved by the
4
5 commission in the last rate case." Please provide any examples from other rate cases in which
6 Dr. Reading's recommendation has been used for the determination of revenue spread and any
7 orders in which this approval has been adopted or approved.
8 RESPONSE TO REQUEST NO. 1. There are no other examples from other rate cases in
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which Dr. Reading's recommendation in this case has been recommended or adopted for the
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II development of revenue spread. This is the first partial rate case in which Dr. Reading has
12 participated in which the rate spread among customer classes was based on a previous rate case
13 along with its class cost-of-service study.
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25 REQUEST NO. 2. For the table on page 14 of Dr. Reading's Direct Testimony, please provide
26 all workpapers used to produce this table in executable electronic format.
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28 THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSE TO THE FEDERAL EXECUTIVE
AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES- 2

I RESPONSE TO REQUEST NO. 2. Please see the attached excel spreadsheet labeled,
2 "Discovery Response 2."
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28 THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSE TO THE FEDERAL EXECUTIVE
AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES-3

I REQUEST NO. 3. Please provide all approaches for revenue spread considered by Dr. Reading
2 in developing his recommended approach for revenue spread and fully explain why his
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recommended approach is preferable.
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5 RESPONSE TO REQUEST NO. 3. There were no other formal revenue-spread approaches
6 developed or considered by Dr. Reading. Dr. Reading's testimony responds to the fact that the
7 rate spread approach used by the Company did not consider a rate spread recommendation for
8 only Schedule 19 customers, rather it included, in addition Schedule 19 customers, three new
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special contract customers. Because the Company, inappropriately in Dr. Reading's opinion,
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II included the three new special contract customers into its Schedule 19 rate spread
12 recommendation, Dr. Reading believes that the fairest way to spread the overall incremental
13 revenue requirement was to mirror the rate spread method approved by the Commission in the
14 2023 general rate case. This was the approach recommended and explained in Dr. Reading's
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Direct Testimony.
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Dated this 19"' day of November 2024.18 V�V&01
19 Peter Richardson, ISB # 3195
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28 THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSE TO THE FEDERAL EXECUTIVE
AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES -4

I CERTIFICATE OF SERVICE
2 I hereby certify that on this 19"' day of November 2024, I caused to be delivered via
3 electronic mail only the foregoing INDUSTRIAL CUSTOMERS OF IDAHO POWER'S
RESPONSE TO THE FEDERAL EXECUTIVE AGENCIES' FIRST PRODUCTION
4 REQUEST AND INTERROGATORIES in Docket No. IPC-E-07-24 on the following parties:
5 IDAHO PUBLIC UTILITIES COMMISSION
6
Monica Barrios-Sanchez, secretary
7 menica.barriossanchei iquc._i_dal o.gov
8 secretary�kpuc.idaho.gov
9 Chris Burdin, Deputy Attorney General
chris.burdin�(�,puc.idaho.gov
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11 IDAHO POWER COMPANY
12
Lisa D. Nordstrom
13 Donovan E. Walker
Megan Goicoechea Allen
14 Iordstrom c�idahopower.com
15 dwalk Didahopowcr.com
mgoicoecheaallen�(i),idahopower.com
16
Tim Tatum
17 Connie Aschenbrenner
18 Matt Larkin
ttg,Wrn �idahopower.com
19 caschcnhrenner(i)idahopower.com
mlarkin(�idahopower.com
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21
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
22
Eric L. Olson
23 Lance Kaufman
24 elo c�echohawk.com
lance(r��tegi-sin sight.cem
25 ---- _.
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28 THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSE TO THE FEDERAL EXECUTIVE
AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES - 5

I IDAHO CONSERVATION LEAGUE
2 Matthew Nykiel
3 Brad Heusinkveld
matthew. kiel�c�gmail.com
4 bheusinkveld(u,)i(lahoconscrvation.org
5 FEDERAL EXECUTIVE AGENCIES
6
Peter Meier
7 Emily W. Medlyn
peter.meier a lu.doe. ov
8 emil [e-mail]. ov
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MICRON TECHNOLOGY, INC.
10
Austin Rueshhoff
I I Thorvald A. Nelson
12 Austin W. Jensen
Kristine A.K. Roach
13 darueschho.l.'l;ti�liolltuicihat*t.coin
tnelson((#ol landhart.com
14 `i\�jcii,icii,u,hollandhart_com
15 aclee u,hollandhart.com
mamemi l len(&hollandhart.com
16
CITY OF BOISE
17
18 Ed Jewell
Steven Hubble
19 dwe�ofboise.prg
Loisecity�ittoi-iiey@eity(i-fboise.org
20 shubble c cit otboise.or
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23 Peter J. Richard -W, ISB#3195
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28 THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSE TO THE FEDERAL EXECUTIVE
AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES-6