20190128Staff 1-8 to IPC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY TO INCREASE
THE SUBSTATION ALLOWANCE IN
SCHEDULE I.9, LARGE POWER SERVICE.
CASE NO. IPC.E-19.02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, request that Idaho Power Company
(Idaho Power or Company) provide the following documents and information as soon as
possible, and no later than MONDAY, FEBRUARY 11,2018.1
Please provide answers to each question and supporting workpapers that detail, or are the
source of information used in, any calculations.
Besides the written copies provided as response to the questions, please provide all Excel
and electronic files on CD with formulas activated.
I Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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JANUARY 28,2019
These production requests and interrogatories are continuing. Idaho Power is requested
to provide, by way of supplementary responses, additional documents and information that it or
any person acting on its behalf may later obtain that will augment the documents and information
produced.
In preparing your responses, please restate in full each question asked, then state in full
your response to the question and the name and telephone number of the person(s) who prepared
the response and would be able to answer questions about it or sponsor it at hearing if needed.
See IDAPA 31.01.01.228.
REQUEST NO. 1: Please provide all evidence including calculations, workpapers,
supporting information, andlor analysis used to determine the material cost of the
138kV/13.09kV, 30 MVA transformer identified under FERC Account 362.61.
REQUEST NO. 2: Over the past 5 years, how many large substation transforrners
(similar to the 138kV/13.09kV, 30 MVA transformer) has the Company purchased? Please
provide the number of units purchased each year, a description, and the cost of each unit. Please
support the Company response with actual invoice copies.
REQUEST NO. 3: For the 138kV/13.09kV, 30 MVA transformer, FERC Account
362.61please provide justification for the 78Yo or 5119,932 increase.
REQUEST NO. 4: Please explain the variability in material cost for the
138kV/13.09kV, 30 MVA transformer over the past 3 years (i.e. T4-16-08 minus 5oA,TA 17-05
minus soh,TAl8-04 plus l8%).
REQUEST NO. 5: Does the Company believe a quotation for the l38kv/13.09kv, 30
MVA transformer from a single vendor provides least-cost pricing? If so please explain why. If
not, please explain why not.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JANUARY 28,2019
REQUEST NO. 6: Please provide the information including calculations, workpapers,
supporting information, and analysis used to determine the material cost of the 4-unit Metalclad
unit identified under FERC Account 362.67.
REQUEST NO. 7: Over the past 5 years, how many 4-unit Metalclad units has the
Company purchased? Please provide the number of units purchased each year, a description, and
the cost of each unit. Please support the Company response with actual invoice copies.
+DATED at Boise, Idaho, this LE day ofJanuary 2019.
/k-T /L
Karl T. Klein
Deputy Attorney General
umisc:prodreq/ipcel9.2kkrk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 JANUARY 28,2019
REQUEST NO. 8: Please explain and provide documentation supporting the 81%
increase in "Miscellaneous parts and material:" for FERC Accounts 362-55,058,59.
CBRTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OF JANUARY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-19-02,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : lnordstrom@idahopower. com
dockets@ idahopower. com
GRANT ANDERSON
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail: [e-mail]
YS
CERTIFICATE OF SERVICE