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HomeMy WebLinkAbout20241119ICIP 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 6 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 14 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 18 19 20 21 22 23 24 25 26 27 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 9 which Dr. Reading's recommendation in this case has been recommended or adopted for the 10 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. 14 15 16 17 18 19 20 21 22 23 24 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. 27 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." 3 // 4 5 6 // 7 // 8 // 9 // 10 II // 12 13 14 15 16 17 18 19 20 // 21 // 22 // 23 24 25 26 27 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 3 recommended approach is preferable. 4 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 9 special contract customers. Because the Company, inappropriately in Dr. Reading's opinion, 10 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 15 Direct Testimony. 16 17 Dated this 19"' day of November 2024.18 V�V&01 19 Peter Richardson, ISB # 3195 20 21 22 23 24 25 26 27 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 10 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 20 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 ---- _. 26 27 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 -.-rTcdlyn@hq.doe. ov 9 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 21 22 23 Peter J. Richard -W, ISB#3195 24 25 26 27 28 THE INDUSTRIAL CUSTOMERS OF IDAHO POWER'S RESPONSE TO THE FEDERAL EXECUTIVE AGENCIES' FIRST PRODUCTION REQUEST AND INTERROGATORIES-6