20170213Staff 1-14 to IPC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 10177
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Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
DETERMINATION OF HELLS CANYON
COMPLEX RELICENSING COSTS THROUGH
2015 AS PRUDENTLY INCURRED.
CASE NO.IPC.E-16.32
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Camille Christen, Deputy Attorney General, request that Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, by MONDAY,
MARCH 6,2017.
This Production Request is continuing, and Idaho Power is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question and supporting workpapers that provide detail or
are the source of information used in calculations. Idaho Power is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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1 FEBRUARY I3,2OI7
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the complete Transaction Detail File of all
expenditures and entries charged to the Hell's Canyon Complex relicensing CWIP account
REQUEST NO. 2: Please provide a list of all Detailed Work Orders for the Hell's
Canyon Complex (HCC) relicensing. Please include a brief description of each work order
REQUEST NO. 3: Please provide all Variance Reports for the Detailed Work Orders
for the HCC relicensing.
REQUEST NO. 4: Please provide a listing of all Detailed Cost Elements (DCE's) used
by Idaho Power with definitions of each DCE.
REQUEST NO. 5: Please provide a brief description of how work order numbers and
DCE's are developed and assigned.
REQUEST NO. 6: Please provide a listing describing all of the Cost Centers used by
Idaho Power. Please include with your list the Idaho Power personnel responsible for each cost
center.
REQUEST NO. 7: Please provide the calculation of each AFUDC entry charged to the
Hell's Canyon Relicensing CWIP account.
REQUEST NO. 8: Please provide all exhibits and tables embedded in testimony in
Excel format with all formulas intact.
REQUEST NO. 9: Please provide all supporting documents and workpapers for the
"independent review" performed by Idaho Power of the HCC relicensing expenses.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 FEBRUARY I3,2OI7
REQUEST NO. 10: Please provide all Internal Audit Reports and SOX 404 Reports
pertaining to the HCC relicensing project.
REQUEST NO. 11: Please provide access to all Board of Directors meeting minutes,
including handouts and presentations, related to HCC relicensing.
REQUEST NO. 12: Please provide the approval requirements for all expenditures for
the HCC relicensing, including dollar levels and the Idaho Power personnel with approval
authority at each expenditure level.
REQUEST NO. 13: Please provide a detailed description of all cost containment
measures, analysis, and studies for the HCC relicensing.
REQUEST NO. 14: Please provide all the studies referred to in Company Witness
Randolph's testimony and Exhibit No. 2.
Dated at Boise, Idaho, this \3 \,\,
day of February 2017
Technical Staff: Haleena fud (l-14)
i:umisc:prodreq/ipce16.32ccha prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Camille Christen
Deputy Attorney General
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J FEBRUARY I3,2OI7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF FEBRUARY 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAF'F TO IDAHO POWER COMPAY, IN CASE NO. IPC-E-16.32,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: I nordstrom(Oidahopower.com
dockets@idahopower. com
TIM TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : ttatum (0 idahorrower. corn
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l 19
POCATELLO ID 83205
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
DR DON READING
6070 HILL ROAD
BOISE ID 83703
BENJAMIN J OTTO
710 N 6TH STREET
BOISE ID 83702
CERTIFICATE OF SERVICE