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HomeMy WebLinkAbout20241125IPC to IIPA 1-8.pdf 0-10AM POWER. LISA D. NORDSTROM Lead Counsel RECEIVED Inordstrorn(Widahopower.com Monday, November 25, 2024 IDAHO PUBLIC November 25, 2024 UTILITIES COMMISSION VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s Third Set of Data Requests. Due to the collectively voluminous confidential and non-confidential information provided in response to data requests in this case, the Company is posting the attachments to these requests to the secure FTP site to allow parties to view the requested information remotely unless otherwise noted in the response. Because certain attachments contain confidential information, the FTP site is divided between confidential and non-confidential information. The login information for the non-confidential portion of the FTP site has been provided to all parties that have intervened to date. The login information for the confidential portion of the FTP site will be provided to the parties that execute the Protective Agreement in this matter. If you have any questions about the attached filing, please do not hesitate to contact me. Sincerely, ot� Lisa D. Nordstrom LDN:sg Enclosures 1221 W. Idaho St(83702) P.O. Box 70 Boise, ID 83707 CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-24-07 Idaho Power Company's Application for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the attachments to Request Nos. 3-1, 3-3, 3-6 and 3-7 to Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s Third Set of Data Requests dated November 25, 2024, contain information that Idaho Power Company and/or a third party claim is a trade secret or confidential public records exempt from disclosure by state or federal law (material nonpublic information under U.S. Securities and Exchange Commission Regulation FD), as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 25th day of November 2024. Lisa D. Nordstrom Attorney for Idaho Power Company LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(aMdahopower.com dwalker idahopower.com mgoicoecheaallenCabidahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE ) APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07 COMPANY TO INCREASE RATES FOR ) ELECTRIC SERVICE TO RECOVER ) IDAHO POWER COMPANY'S COSTS ASSOCIATED WITH ) RESPONSE TO IDAHO INCREMENTAL CAPITAL ) IRRIGATION PUMPERS INVESTMENTS AND CERTAIN ) ASSOCIATION, INC.'S THIRD SET ONGOING OPERATIONS AND ) OF DATA REQUESTS MAINTENANCE EXPENSES. ) COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Second Set of Data Requests to Idaho Power Company dated November 14, 2024, herewith responds to the following information: IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 1 REQUEST FOR PRODUCTION NO. IIPA 3-1: Please refer to IPC's response to IIPA DR 2-24 attachment C. Please provide the data in the sheet "Inputs" for January 2024 to October 2024. Please provide this data using: a. Actual values b. Weather normalized actual values based on IPC's standard normal weather assumptions. c. Weather normalized actual values based on 20-year average weather. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-1: a. Please see Confidential Attachment 2 provided with this request for the 2024 test year sales forecast using actual kilowatt-hour ("kWh") sales through October. November and December data is based on the Company's most recent sales forecast produced in September 2024. b. Please see Confidential Attachment 1 provided with this request for the 2024 test year sales forecast using weather normal kWh sales through September. October through December data is based on the Company's most recent sales forecast produced in September 2024. The Company is not able to provide weather normal sales for October 2024, as the calculation cannot be completed and validated within the requested timeframe. c. The Company is not able to calculate weather normalized sales based on 20-year average weather, as this would require the development and validation of a new model, which could not be completed within the requested timeframe. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 2 REQUEST FOR PRODUCTION NO. IIPA 3-2: Please refer to IPC's response to IIPA DR 2-24 attachment C. Please provide the data in the sheet "Inputs" for October 2024 to December 2024. Please provide this data using: a. IPC's most current forecast under IPC's standard normal weather assumptions. b. IPC's most current forecast under 20-year average weather. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-2: a. Please see Confidential Attachment 1 provided in response to IIPA Request No. 3-1. b. The Company is not able to calculate an updated sales forecast based on 20-year average weather, as this would require the development and validation of a new model, which could not be completed within the requested timeframe. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 3 REQUEST FOR PRODUCTION NO. IIPA 3-3: Please refer to IPC's response to Staff Data Request No. 3 attachments 1, 2, 3, 12, and 13. Please provide these workpapers revised to reflect actual plant additions from January 2024 to October 2024 and forecasted plant additions from November 2024 to December 2024. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-3: Actual values from January 2024 through October 2024 have already been provided to parties as noted in the table below: Staff DR 3 Contents' Attachment containing Actuals Attach. # through October 2024 1 Accumulated Reserve CONFIDENTIAL Attachment— Third Supplemental Response to Staff Request No. 63 2 Depreciation /Amortization CONFIDENTIAL Attachment — Third Expense Supplemental Response to Staff Request No. 63 3, 12 Electric Plant In Service CONFIDENTIAL Attachment — Third Supplemental Response to Staff Request No. 62 Forecasted plant additions from November 2024 to December 2024 were included in the Company's initial filing and provided to parties through the Company's Response to Staff Request No. 3. Idaho Power has not re-forecast plant for these months based on actual closings through month-end October 2024. Attachment 13 — Response to Staff Request No. 3 reflects the incremental labor determination, not plant. Please see Confidential Attachment- Response to IIPA Request No. 3-3 for the updated incremental labor determination using actuals through October 2024. All attachments reflect the incremental calculation to determine the filed revenue requirement in this case. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS-4 The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 5 REQUEST FOR PRODUCTION NO. IIPA 3-4: Please refer to the Direct Testimony of Dr. Don Reading page 9 lines 21 to 23. Please also refer to "Attachment - Response to ICIP Request No. 2.xlsx" a. Is the referenced attachment identical to the CCOS used in IPC's 2023 GRC? If no, please explain how the referenced attachment differs from the 2023 GRC. b. Does the referenced attachment reflect rates approved in the 2023 GRC? RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-4: Please see the responses below regarding the file labeled "Attachment— Response to ICIP Request No. 2." a. No, the referenced attachment is not identical to the Class Cost-of-Service ("CCOS") study used in Idaho Power's 2023 General Rate Case ('2023 GRC"). The underlying methodology is generally the same. The primary differentiating factor is that the CCOS study used in developing the revenue allocation in this rate case only allocated the incremental revenue requirement, whereas the 2023 GRC CCOS study allocated the total system revenue requirement. Therefore, the composition of the incremental revenue requirement results in a different allocation to each customer class relative to the 2023 GRC. b. Idaho Power assumes this question is specific to the Retail Sales. In general, a CCOS study does not reflect retail customer rates. However, Tatum Exhibit 4, Column C, 2024 Retail Sales, does reflect rates approved in the 2023 GRC for calculating the percentage increase by class. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 6 REQUEST FOR PRODUCTION NO. IIPA 3-5: Please refer to the Direct Testimony of Dr. Don Reading page 11 lines 1 to 5. a. Please provide Schedule 19's COS Index as expressed in Column P of Tatum Exhibit 4 using the 2023 CCOS, before and after the 2023 GRC rate increase. b. Please explain the significance of the COS Index. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-5: Please see responses below. a. The 2023 GRC Settlement Stipulation did not explicitly include a "COS Index." However, the Company has prepared the file labeled "Attachment — Response to IIPA 3-5a," which contains the same metric for each customer class for the 2023 GRC Settlement Stipulation. The calculation compares each customer class's mill rate (i.e., revenue requirement per kWh sales) as a result of the final revenue allocation compared to the CCOS results. Therefore, a "before and after GRC" is not a calculation that can be performed as the final results are inherently embedded in the underlying calculation of the metric. As further described in subpart (b) to this response, the COS Index in Tatum Exhibit 4 is overstated towards 1.0 for each customer class due to the calculation being performed on total revenue requirement rather than just the incremental revenue requirement at issue in this limited issue rate case. b. The "COS Index" is a customer class's final revenue allocation ratio relative to the CCOS results. A customer class with a ratio greater than 1.0 or 100% is being allocated revenue requirement above the results of the CCOS study, and a ratio IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 7 less than 1.0 or 100% is being allocated revenue requirement below the results of the CCOS study. However, the CCOS study only includes the incremental revenue requirement in this limited issue rate case. The COS Index illustrated in Tatum Exhibit 4 combines existing base revenue with the CCOS results for the incremental revenue requirement. Therefore, the index is muted because each customer class's base revenue differs from the results of a CCOS study as if it had included all revenue requirement— not just the incremental revenue requirement. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 8 REQUEST FOR PRODUCTION NO. IIPA NO. 3-6: Please refer to IIPA Request 1-2 attachment 1 for allocation factors D10, D13, and E10. a. How is this data generated? b. What time period do these data represent? c. Does this data reflect actual or normal weather? If this data is not based on normal weather, please provide this data under normal weather. d. Cell R92 states "Net CEYW". Please explain what Net CEYW means and provide the data not "Net CEYW". RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-6: Please see below responses regarding the file labeled "Attachment 1 — Response to IIPA Request No. 2 — D10 D13 E10." a. This data reflects 2023 test year values from the Company's 2023 GRC. The data for the twelve monthly coincident demands at generation level, used for the monthly D10 factors, was generated by calculating a system coincident demand factor ("SCD"), based on 2022 actual sales for each rate. System coincident demand factors were calculated for each rate in each jurisdiction by dividing the rate class demand value at the time of system peak, by the average demand for each month. This SCD is then used to calculate a system coincident demand by multiplying the average kilowatts ("kW") for the month 2023 GRC test year by the SCD. The average kW for the month is calculated by dividing the test year energy by the number of hours in the month. Finally, the system coincident demand is grossed up for losses resulting in the monthly coincident demands at generation level. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 9 The data for the monthly energy requirements at generation level, used for the monthly E10 factors, was calculated by multiplying the 2023 test year sales for each month and rate class by the loss factor appropriate for each rate. b. The data in this file is weather normalized for 2023. c. It reflects weather normalized data. d. "Net CEYW" means net of Clean Energy Your Way generation. Please see the file labeled "Confidential Attachment— Response to IIPA 3-6(d)." The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company, and Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 10 REQUEST FOR PRODUCTION NO. IIPA 3-7: Please refer to the IPC 2023 IRP Technical Appendix C page 96, LOLE percentage by month. a. What years do these data represent? b. Please provide the data referenced in the footnote "January and February are expected to be as high as November and December for the 2025-2026 winter season due to forecasted industrial customer load ramps." c. Please also refer to Response to IIPA Request No. 2-12 - Attachment 1.xlsx Tab "Test Year 1", which indicates 35 percent of 2024 LOLP occurs in December. Please explain the difference between test year 1 2024 results and the results in Appendix C page 96. d. Please also refer to Response to IIPA Request No. 2-12 attachments 1 and 2. Please explain the difference between test years. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-7: a. The monthly Loss of Load Expectation ("LOLE") results represent a 2025 load and resource year. The 2023 Integrated Resource Plan ("IRP") LOLE analysis utilized six test years reflecting historical data from the years 2017 through 2022. b. Please see "Response to Request for Production No. IIPA 3-7 Attachment" for the 70th percentile peak load forecast and referenced industrial customer load ramps. c. In reviewing the referenced Loss of Load Probability ("LOLP") data for test year 1 of 2024, Idaho Power would clarify that 35 percent of LOLP values occur in January, not December. Generally speaking, as noted in part (a) above, the table on page 96 of the 2023 IRP reflects the results for a 2025 load and resource year (not a 2024 load and resource year). Also as stated in part (a) above, the monthly IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 11 LOLE analysis considers the results of all six test years (not one specific test year). The analysis reflecting the results of six test years for a 2025 load & resource year will be not match the results of a single test year for a 2024 load & resource year. d. IIPA Request No. 2-12 requested that the Company provide LOLE or LOLP values under two scenarios: 1) the 2023 IRP Preferred Portfolio, and 2) utilizing the assumption that no resources are added. The differences in values between the two attachments referenced in this request are due to the two scenarios requested in IIPA Request No. 2-12. Aside from the differing resource assumptions, the underlying test year data utilized in these analyses is the same. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 12 REQUEST FOR PRODUCTION NO. IIPA 3-8: Please provide IPC's actual hourly load from January 1, 2022 to present. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-8: Please see the attachment provided with this response. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 13 DATED at Boise, Idaho, this 25th day of November 2024. LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 14 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25th day of November 2024, 1 served a true and correct copy of Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s Third Set of Data Requests upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email PO Box 83720 Chris.Burdin(a)-puc.idaho.gov Boise, ID 83720-0074 Industrial Customers of Idaho Power Hand Delivered Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27' Street FAX Boise, Idaho 83702 FTP Site X Email peter richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dread ing�mindsprinq.com Idaho Irrigation Pumpers Association, Hand Delivered Inc. U.S. Mail Eric L. Olsen Overnight Mail ECHO HAWK & OLSEN, PLLC FAX 505 Pershing Avenue, Suite 100 FTP Site P.O. Box 6119 X Email Pocatello, Idaho 83205 elo echohawk.com Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance@aegisinsight.com IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 15 Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach FTP Site Holland & Hart LLP X Email 555 17t" Street, Suite 3200 darueschhoff(a)hol land hart.com Denver, CO 80202 tnelson(a)hol land hart.com awjensen _hol land hart.corn karoachC@hollandhart.com aclee hollandhart.com mamcmillen(c�hol land hart.com Jim Swier Hand Delivered Micron Technology, Inc. U.S. Mail 8000 South Federal Way Overnight Mail Boise, ID 83707 FAX FTP Site X Email Iswier(c)micron.com City of Boise Hand Delivered Ed Jewell U.S. Mail Deputy City Attorney Overnight Mail Boise City Attorney's Office FAX 150 N. Capitol Blvd. FTP Site P.O. Box 500 X Email Boise, Idaho 83701 BoiseCityAttorneyCa�cityofboise.org ejewell cityofboise.org Steven Hubble Hand Delivered Boise City Dept. of Public Works U.S. Mail 150 N. Capitol Blvd. Overnight Mail P.O. Box 500 FAX Boise, Idaho 83701-0500 FTP Site X Email shubble cityofboise.org IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 16 Federal Executive Agencies Hand Delivered Peter Meier U.S. Mail Emily W. Medlyn Overnight Mail U.S. Department of Energy FAX 1000 Independence Ave., S.W. FTP Site Washington, DC 20585 X Email peter.meielb-hg.doe.gov emily.medlyn(a)hg.doe.gov Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD SET OF DATA REQUESTS- 17