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Home My WebLink About20250214IPC to Staff 1-5.pdf "4%611—NIQAHO m Re RECEIVED Friday, February 14,2025 MEGAN GOICOECHEA ALLEN IDAHO PUBLIC Corporate Counsel UTILITIES COMMISSION mgoicoecheaallenC&_idahopower.com February 14, 2025 Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Boulevard Building 8, Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-25-01 Idaho Power Company's Annual Compliance Filing to Update the Substation Allowance Amount Under Schedule 19, Large Power Service; Tariff Advice No. IPC-TAE-24-06 Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power in the above-entitled matter. The confidential attachments will be provided to the parties who sign the Protective Agreement. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, ukr I f��Cfi�1.PA Megan Goicoechea Allen MGA:sg Attachments 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-25-01 Idaho Power Company's Annual Compliance Filing to Update the Substation Allowance Amount Under Schedule 19, Large Power Service; Tariff Advice No. IPC-TAE-24-06 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that all of the attachments in Response to Requests Nos. 1, 3, 4, and 5 to Idaho Power Company's Response to the First Production Request of the Commission Staff dated February 14, 2025, contain information that Idaho Power and/or a third-party claim constitutes trade secrets or other confidential business data exempt from disclosure under Idaho Code § 48-801, et seq. and § 74-101, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 14th day of February, 2025. Megan Goicoechea Allen Counsel for Idaho Power Company MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 mgoicoecheaallenCo)idahopower.com Attorney for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S ANNUAL COMPLIANCE ) CASE NO. IPC-E-25-01 FILING TO UPDATE THE SUBSTATION ) ALLOWANCE AMOUNT UNDER ) IDAHO POWER COMPANY'S SCHEDULE 19, LARGE POWER SERVICE; ) RESPONSE TO THE FIRST TARIFF ADVICE NO. IPC-TAE-24-06. ) PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission ("Commission" or "IPUC") Staff to Idaho Power Company dated January 24, 2025, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 1 REQUEST FOR PRODUCTION NO. 1: For the following items contained in Company workpaper: CONFIDENTIAL 2025 Sch. 19 Substation Allowance Calculation.xlsx, please provide: (1) the workpapers (with formulas intact) for the derivation of the loaded material cost, and (2) the foundational cost documentation (actual invoices, quotes, etc.) and workpapers with formulas intact used to determine the direct material cost: a) 4-unit metal-clad switchgear; b) 44.8 MVA transformer; c) 138kV air brake switch structure and foundation; d) 138kV high-side circuit interrupter foundation; e) 13kV air brake switch structure and foundation; and f) 13kV pad mount local service. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see CONFIDENTIAL Response for Production No. 1 —Attachment 1. This attachment provides a summary of the direct material cost and the derivation of the loaded material cost detailing how the loadings were applied to each of the materials as filed. Note, the direct cost of materials used in determining the Company's proposed update to the Substation Allowance is based on each material's respective average unit price of current inventory at the time of the proposed adjustment. For a sampling of available purchase orders and invoices, please see the confidential attachments below: a) Please see CONFIDENTIAL Response for Production No. 1 — Attachment 2 b) Please see CONFIDENTIAL Response for Production No. 1 — Attachment 3 IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 2 c) Please see CONFIDENTIAL Response for Production No. 1 — Attachment 4 d) Please see CONFIDENTIAL Response for Production No. 1 — Attachment 5 e) Please see CONFIDENTIAL Response for Production No. 1 — Attachment 6 f) Please see CONFIDENTIAL Response for Production No. 1 — Attachment 7 The response to this Request is sponsored by Ashley Herrera, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 3 REQUEST FOR PRODUCTION NO. 2: Please provide the workpapers (with formulas intact) that show the derivation of the loading rate(s) used to calculate the loaded material cost in Company workpaper: CONFIDENTIAL 2025 Sch. 19 Substation Allowance Calculation.xlsx. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see CONFIDENTIAL Response to Production No. 1 — Attachment 1, which details the derivation of the loading rate(s) used to calculate the loaded material cost. The stores loading rate is evaluated quarterly to determine whether an adjustment is needed to better align the clearing rate with year-to-date stores expenses and issuances while also considering expected forecasted activity. The evaluation is conducted by an internal committee comprised of leaders from the Company's Supply Chain and Finance Departments (the "Committee"). During the July 2024 review, the Committee determined that lower stores rates were appropriate primarily due to the expected increase in capital work. The Company estimates that the reduced stores loading rates will yield a reasonable level of uncleared stores-related expenses by year end, the balance of which would be appropriately associated with unissued inventory. The response to this Request is sponsored by Ashley Herrera, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-4 REQUEST FOR PRODUCTION NO. 3: Please explain the cost increase/decrease for the following items used to calculate the Three Phase Allowance in Company workpaper: CONFIDENTIAL 2025 Sch. 19 Substation Allowance Calculation.xlsx. Also, please include any documentation and the Company's workpapers with formulas intact used to calculate the amounts, including any overheads that were applied: a) Company vehicles (increase); and b) Labor cost (decrease). RESPONSE TO REQUEST FOR PRODUCTION NO. 3: a) Please see CONFIDENTIAL Response to Production No. 3 — Attachment 1 detailing the Company's vehicle expenses used in the calculation of the proposed substation allowance. The increase in 2025 compared to 2024 can be attributed to anticipated increases in licensing, depreciation, and miscellaneous expenses to include but not limited to maintenance costs. b) Please see CONFIDENTIAL Response to Production No. 3 — Attachment 2 detailing the Company's labor costs used in the calculation of the proposed substation allowance. While this production request implies a decrease in labor cost, the labor costs related to the calculation of the substation allowance increased by approximately 4 percent compared to the previous years' labor cost as referenced in the CONFIDENTIAL 2025 Sch. 19 Substation Allowance Calculation.xlsx submitted. This labor cost increase can be attributed to an increase in wages to include the general wage adjustment for 2025. In the Company's workpaper: CONFIDENTIAL 2025 Sch. 19 Substation IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 5 Allowance Calculation.xlsx, the overheads are applied to the Field Total (the sum of Total Material Cost, Company Vehicles, and Labor Cost). The overheads are calculated by multiplying the overhead rate of 2.64 percent and the Field Total, resulting in an overhead total of 115,030 dollars (cell G40). The response to this Request is sponsored by Ashley Herrera, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 6 REQUEST FOR PRODUCTION NO. 4: Please provide workpapers, which further detail the calculation of the overhead rate calculation. This should include capital spend and overhead allocation inputs. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see CONFIDENTIAL Response to Production No. 4 — Attachment 1. The Capital Spend tab contains the actual capital spend between November 2023 and October 2024 used in the calculation. The Overhead Allocation tab contains the actual overhead amounts allocated between November 2023 and October 2024. Formulas dependent upon these supporting tabs are in blue text on the Rates Calculation tab. Formulas dependent only on cells on the Rates Calculation tab remain in black text. Note, the totals relied on to calculate the Overhead Rate are captured as a snapshot in time. In preparation of this response, the Company identified that the Power Supply Project Actuals were overstated by approximately 90 thousand dollars and a single workorder of approximately 473 thousand dollars shifted between Corporate Projects and Customer Operations (which nets to zero), both due to changes of a work order type that occurred after the initial information was compiled. While the Total Overhead Allocated decreased by 90 thousand dollars as a result of the changes, the calculated overhead rate remains unchanged at 2.64 percent. The response to this Request is sponsored by Ashley Herrera, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 7 REQUEST FOR PRODUCTION NO. 5: Please provide data in Excel format for all transactions that total the "Stations" capital spend; and also provide the overhead allocation totals, broken out by category, "Customer Operations", "Planning, Engineering & Construction", "Corporate Projects", Power Supply Projects", etc. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see CONFIDENTIAL Response to Production No. 5 — Attachment 1. The OVHD — 12 Month Acts. tab provides the overhead actuals broken out by category. The Cap — 12 Month Acts. Summary tab provides the total dollar amounts for all transactions broken out by project category. Information detailing each capital transaction can be found in the "Type" tabs which correlate with the Project Category number. The response to this Request is sponsored by Ashley Herrera, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 8 Respectfully submitted this 14t" day of February 2025. Awrl T I06UA & MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 9 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 14th day of February 2025, 1 served a true and correct copy of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power 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 chris.burdin(cbpuc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 10