20151228IPC to Staff 1-3.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
December 28,2015
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-26
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Application for Approval of the Transfer and Sale of Certain Assets to the
United States Department of Justice Federal Bureau of lnvestigation
- ldaho Power Company's Response to the First Production Request of the
Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and three (3) copies of
Idaho Power Company's Response to the First Production Request of the Commission
Staff.
ln addition, enclosed are four (4) copies of a confidential disk containing
information responsive to Staff's production requests. Please handle the confidentia!
information in accordance with the Protective Agreement executed in this matter.
If you have any questions about this filing, please do not hesitate to contact me.
Very truly yours,
df=f,.t[^u'*-."Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ id a ho powe r. co m
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AN
ORDER APPROVING THE TMNSFER AND
SALE OF CERTAIN ASSETS TO THE
UNITED STATES DEPARTMENT OF
JUSTICE FEDERAL BUREAU OF
INVESTIGATION.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-15-26
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Comp?[y"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated December 4,2015, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: Please provide work papers and spread sheets (with
calculations and links enabled) used to determine the following cost components:
a. Net book value.
b. True-up of past levelized ROR. Please include an explanation of the
Company's calculations of present worth for declining debUequity used in this
calculation.
c. Near-term ROR impact resulting from sale of assets.
d. Near time operational impact resulting from the sale of assets.
e. Net tax gross-up.
RESPONSE TO REQUEST NO. 1: Please see the confidentia! Excel file
provided on the confidential CD in electronic format with all formulas intact. The Excel
workbook includes the calculations to determine the requested cost components.
The Company's calculation of present worth for declining debUequity used to
determine the true-up of past levelized rate of return ("ROR") is based on the 7.86
percent ROR approved in the Company's most recent general rate case, Case No. IPC-
E-11-08, Order No. 32426. The ROR is reduced annually for the effect of straight-line
depreciation and deferred taxes. A schedule presenting the declining ROR is included
in the confidential Excelfile in the tab labeled "Price Component Detail".
The confidentia! attachment will only be provided to those parties that have
executed the Protective Agreement in this matter.
The response to this Request is sponsored by Zach Harris, Regulatory Analyst Il,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: Please explain how Rule H requires the system protection
package described in section 4 (page 3) of the Agreement.
RESPONSE TO REQUEST NO. 2: Rule H does not require the system
protection package. The system protection package is a necessary reclosure that
protects customers located before the system protection package's location and is
needed to ensure continued reliable electric service to customers. ln the event that a
fault occurs at the FBI site, the reclosure will trip and electric service will continue to be
provided to customers located prior to the service protection package. The FBI will be
charged the work order cost of installing the system protection plan in accordance with
Rule H.
The response to this Request is sponsored by Zach Harris, Regulatory Analyst ll,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 3: ln the Application, the Company explained that it used a 3
year basis to compute the near-term rate of return and operational impacts of the sale.
The Company explained that 3 years is a conservative proxy for the amount of time that
may pass between general rate case filings. Given that the Company's last general rate
case involving distribution plant was concluded in 2011, please explain why the
Company believes it likely that another 3 years will pass before it applies for another
genera! rate case with the Commission.
RESPONSE TO REQUEST NO. 3: The referenced three-year period is not
intended to represent an estimate of the timing of the Company's next general rate
case; rather, it represents a proxy for the amount of time that may pass between
general rate case filings. During the last 20 years, ldaho Power has filed five general
rate cases for an average of one case every four years. Based on this review of the
historical frequency of rate case filings, the Company views the three-year period to be
conservative. It is the Company's intent that this proxy be utilized in the calculation of
the sales prices of assets for all facilities that ldaho Power agrees to sell in accordance
with Section 3 of Rule M, and therefore has applied this assumption in the FBI sales
price determination.
The response to this Request is sponsored by Zach Harris, Regulatory Analyst ll,
ldaho Power Company.
DATED at Boise, ldaho, this 28th day of December 2015.
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 28th day of December 2015 t served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hil! Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 5