20210212Staff 1-13 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL pg i :22IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR AN )CASE NO.IPC-E-21-02
ACCOUNTING ORDER AUTHORIZING THE )DEFERRAL OF INCREMENTAL WILDFIRE )MITIGATION AND INSURANCE COSTS )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy Attorney General,requests that Idaho Power Company provide the
followingdocuments and information as soon as possible,but no later than FRIDAY,
MARCH 5,2021.
This Production Request is to be considered as continuing,and Idaho Power Company 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 or information
produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephone number of
FIRST PRODUCTION REQUEST
TO IDAHO POWER l FEBRUARY 12,2020
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.1:Please provide the name and company of the external consultant the
Company contracted with to produce the Wildfire Risk Map and Fire Protection Index.Were the
external consulting expenses included in the O&M costs shown in Table No.2,page 19 of the
Application?
REQUESTNO.2:Please provide workpapers detailing how the Company calculated
the projected 5-year $385,000 Situational Awareness expenses discussed in the Application at
page 20.
REQUESTNO.3:Did the Company calculate different risk values for each risk zone to
determine potential infrastructure losses,claims,and replacement costs?If so,please explain the
analysis for the risk values and provide the analysis and documentation supporting the
conclusions.
REQUESTNO.4:Please provide the risk analysis or data demonstrating the need for a
3-year vegetation management cycle in low-risk areas.Please explain how the analysis or data
supports the Company's decision.
REQUESTNO.5:Has the Company applied for a special FAA waiver for
authorization to fly UAVs beyond visual line of site?If so,please explain the status of the
waiver.If the Company has not applied for a waiver,please explain why.
REQUESTNO.6:Has the Company considered sensor technology for remote fire
monitoring?If so,please explain that consideration.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY 12,2020
REQUESTNO.7:Please provide the cost/benefit analysis or business case for the pole
mesh wraps.Please include all costs and benefits the Company included and provide any
performance data used to support the analysis.
REQUESTNO.8:What was the Company's previous vegetation management cycle
before proposing a system-wide 3-year cycle with post trimming audits and second year
trimming for "rapid growing trees"?
REQUESTNO.9:Please describe the plan and process for identifyingand cataloging
"rapid growing trees"(by zone,tree,or map)and provide details for how this work will be
managed.Please include cost estimates for the additional mid-cycle pruning.
REQUESTNO.10:Does mid-cycle pruning amount to a 3-year vegetation
management cycle?
REQUESTNO.11:Please describe the current vegetation management plan,including
the current year over year cycle of the current plan.
REQUESTNO.12:Please quantifythe expected overall cost for the entire Wildfire
MitigationPlan for the years 2021 through 2025.Please include the operating expenses specific
to the wildfire mitigation plan,the increased vegetation management expenses,Wildfire
MitigationPlan capital investments,and the depreciation expense associated with those capital
expenditures,and the insurance cost.Please break down the expenditures by project,by type of
expense,and by year.
REQUESTNO.13:Please provide the budgeted amount and actual amount spent for
Vegetation Managementfor 2020 and the budgeted amount for 2021?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 FEBRUARY 12,2020
DATED at Boise,Idaho,this day of February 2021.
ayn Ha ie
Deputy AttorneyGeneral
i:umisc:prodreq/ipce21.2dhkisrf prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 FEBRUARY 12,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF FEBRUARY 2021,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-21-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER ENERGY CONTRACTSIDAHOPOWERCOMPANYIDAHOPOWERCOMPANYPOBOX70POBOX70BOISEID83707-0070 BOISE ID 83707-0070E-MAIL:dwalker idahopower.com E-MAIL:enerevcontracts idahopower.comdocketsidahopower.com
SECRETARY
CERTIFICATE OF SERVICE