20241125Staff to IIPA 1-2.pdf

RECEIVED
2024 November 25
IDAHO PUBLIC
CHRIS BURDIN UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS )
ASSOCIATED WITH INCREMENTAL ) COMMISSION STAFF'S
CAPITAL INVESTMENTS AND CERTAIN ) RESPONSE TO THE FIRST
ONGOING OPERATIONS AND ) PRODUCTION REQUESTS OF
MAINTENANCE EXPENSES ) IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, responds as follows to Idaho Irrigation Pumpers
Association, Inc.'s ("Company") First Production Request to Commission Staff.
REQUEST NO. IIPA 1-1: Please refer to the Direct Testimony of Michael Eldred page
4 lines 11 to 13.
a. Please provide all data and workpapers used to determine that sales increased by
1.04% in January to August 2024 compared to 2023.
b. Please refer to IPC's response to IIPA Data Request 2-24 part £ Does Staff s
recommended revenue adjustment account for the differences in growth rates and
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
IRRIGATION PUMPERS ASSN, INC. 1 NOVEMBER 25, 2024

revenue per kWh across schedules? If no, why not? If yes,please explain how this is
accounted for.
STAFF RESPONSE NO. IIPA 1-1:
a. Please see ATTACHMENT 1, IPC-E-24-07_Staff Response to IIPA No. 1-
1-Revenue Growth Calculation. It contains the calculation for the 1.04% sales
increase. Cells C2 and C3 in this file include detailed notes referencing the source for
how these values were determined. The Company's Idaho January through August
2024 Normalized Actuals kWh Sales value in Cell C2 used information from the file
named"First Supplemental Response to Request for Production No. 112 -
Confidential Attachment 1"provided by the Company in the First Supplemental
Response to Staff s Production Request No. 112. Because it is confidential and IIPA
has access to this file as part of this case, this file is not provided in this response.
The Idaho January through August 2023 GRC Settlement kWh Sales value in Cell C3
used information from file, "Brady Workpaper 1 - Revenue Forecast Workbook,"to
determine the value (ATTACHMENT 2). This file was provided with the
Company's Application in Case No. IPC-E-23-11 and was the basis for the 2023
GRC Settlement kWh Sales. This file is included as part of Staffs response.
b. Staffs recommended revenue adjustment does not directly account for differences in
growth rates and revenue across schedules because the adjustment is a total Idaho
revenue value.
However, the billing determinant method discussed on pages 6-7 of Eldred's
Direct testimony would capture some of the differences in growth rates and revenue
between schedules because it is based on eight months of 2024 Idaho normalized
actual kWh sales that are broken out by the Company's different schedules.
Comparing the eight months of actual sales and revenue to the 2023 GRC Settlement
values for the different schedules could be used to determine the change in growth
rates and revenue.
The method used to extrapolate an additional four months of billing
determinants to match Staffs revenue adjustment would also impact the extent to
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
IRRIGATION PUMPERS ASSN, INC. 2 NOVEMBER 25, 2024

which growth rates and revenue between schedules are captured. The potential
method discussed on pages 6-7 of Eldred's Direct testimony uses the change in
normalized actual January through August 2024 billing determinants compared to the
same billing determinants used in the 2023 GRC Settlement to extrapolate the billing
determinants for all schedules for an additional four months. This method would
maintain the percent change from the eight months of actuals for the entire 12-month
period. Using a uniform 1.04% sales increase to extrapolate the billing determinants
for all schedules for an additional four months would drive all schedules toward the
total Idaho 1.04% average sales increase but would still incorporate the differences in
growth rates and revenue from eight months of actuals.
REQUEST NO.IIPA 1-2: Please refer to the Direct Testimony of Michael Louis page
4 line 17. a.
a. Please provide the data and workpapers used to make this calculation.
b. Please provide Staff's estimate of IPC's plant in service and accumulated
depreciation by month from January 1, 2024 to December 31, 2024.
STAFF RESPONSE NO. IIPA 1-2:
a. Please refer to CONFIDENTIAL ATTACHMENT 3, Staff August 31 AMA
Calculation. The worksheet labeled"Revenue Requirement"provides the calculation
of the $74.7 million adjustment, with detailed calculations in the other worksheets.
b. As detailed in Staff Witness Louis' testimony, Staff used a cutoff date of August 31,
2024 for rate base. Staff has not had adequate time to audit beyond this date for
accuracy or prudence of expenditures. Staff does not speculate on plant balances
between September 1, 2024, and December 31, 2024, and cannot provide estimates.
Staff used Company calculated balances provided in Production Request No. 62
Supplemental Response No. 1 to determine total plant in service amounts through
August 31, 2024. Staff used the Company calculated values in Production Request
No. 63 Supplemental Response No. 1 to determine accumulated depreciation balances
through August 31, 2024. Please see CONFIDENTIAL ATTACHMENT 4, Staff PIS
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
IRRIGATION PUMPERS ASSN, INC. 3 NOVEMBER 25, 2024

&Ace Dep Monthly Calculations,which provide calculations for monthly plant in
service and accumulated depreciation balances for January 1, 2024, through August
31, 2024.
DATED at Boise, Idaho, this 251h day of November 2024.
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Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-07 Staffs Response to IIPA PR#l.doex
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO
IRRIGATION PUMPERS ASSN, INC. 4 NOVEMBER 25, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF NOVEMBER 2024, SERVED
THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE FIRST PRODUCTION
REQUESTS OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., IN CASE NO.
IPC-E-24-07, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: lnordstromkidahopower.com E-MAIL: ttatumkidahopower.com
dwalkergidahopower.com caschenbrennergidahopower.com
mgoicoecheaallenkidahopower.com mlarkinkidahopower.com
dockets(kidahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lancegae ism hg t.com
E-MAIL: elo(kechohawk.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreadin mindspring com
E-MAIL: peter(arichardsonadams.com
PETER MEIER EMILY W MEDLYN
US DEPT OF ENERGY US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585 WASHINGTON DC 20585
E-MAIL: peter.meier(abhq.doe.gov E-MAIL: Emily.medlynghq.doe.gov
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubble&cityofboise.org
E-MAIL: ejewellgcityofboise.org
boiseci . attorney(kcityofboise.org
CERTIFICATE OF SERVICE

JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 KRISTINE A.K. ROACH
E-MAIL: jswier(�),micron.com HOLLAND &HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoff(a�hollandhart.com
tnel sonkhollandhart.com
awjenl senkhollandhart.com
karo achkhollandhart.com
aclee(khollandhart.com
mamcmillen hollandhart.com
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KERI J. HAWKER
Legal Assistant to Chris Burdin
CERTIFICATE OF SERVICE

CONFIDENTIAL ATTACHMENT 3
IPC-E-24-07
Staff's Confidential Attachment 3
IPC-E-24-07
Response to IIPA First RFP
11/25/24

CONFIDENTIAL ATTACHMENT 4
IPC-E-24-07
Staff's Confidential Attachment 4
IPC-E-24-07
Response to IIPA First RFP
11/25/24