20180125Staff 1-10 to IPC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAI-
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
RECEIVED
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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 TO ESTABLISH A
METHOD OF RECOVERY FOR COSTS
ASSOCIATED WITH PARTICIPATION IN THE
WESTERN ENERGY IMBALANCE MARKET.
CASE NO. IPC.E.I7.I6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attomey General, request that Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, by
THURSDAY, FEBRUARY 8, 20t 8.r
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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I JANUARY 25,2018
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.
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 an itemized list of actual capital investments and
operations and maintenance expenses to date related to participation in the western EIM. Each
line item should include, but not limited to a description of the expense and a reason why the
expense is needed.
R-EQUEST NO. 2: Please provide an itemized list of estimated capital investments and
operation and maintenance expenses to be incurred before the Company begins participation in
the western EIM. Each line item should include, but not limited to a description of the expense
and a reason why the expense is needed. Include a description of how each expense was
estimated.
REQUEST NO.3: Please provide an itemized list of ElM-related costs currently
included in the regulatory deferral account created in Order No. 33706.
REQUEST NO. 4: Using the revenue requirement amount of $3,393,212 in Exhibit No.
I of Company witness White's direct testimony, is this the amount that will be subtracted from
the PCA forecast filed later this year as described on page 14, lines 12-16 of her direct
testimony? Please explain.
REQUEST NO. 5: Please identify and quantify any ongoing software expenses. Please
separately identify any yearly fees, monthly fees, and continuing software development fees.
REQUEST NO. 6: Please identify and quantify all ongoing fees associated with CAISO
and the western EIM. Who sets the fees?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JANUARY 25,2018
REQUEST NO. 7: Please provide the underlying source documents and spreadsheets
for the information contained in Exhibit 1. Please provide the excel spreadsheet for the Exhibit
with all formulas intact.
REQUEST NO. 8: How does the recent change in the tax law affect the gross-up
calculation? Please provide updated spreadsheets with the updated tax information.
REQUEST NO. 9: What is the "Other Available Pertinent Data" as shown on line 21,
page 14 of Company Witness White's direct testimony?
REQUEST NO. 10: Is the February Revenue Requirement recalculation designed to
cover only the ongoing operation and maintenance (O&M) costs and the start-up amortization
costs? Please explain.
Dated at Boise, Idaho, this p day of Janu ary 2018
Technical Staff: Michael Eldred (1-4)
Kathy Stockton (5-10)
i:umisc:prodreq/ipce 17. I 6bkmekls prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER
Brandon
JANUARY 25,2018J
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF JANUARY 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-I7-16,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail : j hilton@idahopower. com
dockets@ idahopower.com
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : twhite@idahopower. com
ARY
CERTIFICATE OF SERVICE