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HomeMy WebLinkAbout20241125Staff 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 (208) 334-0314 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. 0 �. 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 Kvv &-f1 wK.yki�, 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