20210630Staff 1-11 to IPC.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8" SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE ITS RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS ASSOCIATED
WITH THE JIM BRIDGER POWER PLANT
CASE NO. IPC-E -2I-17
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,
Erick Shaner, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, JULY 21, 2021.
This Production Request is to be considered as continuing, and the 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
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 JUNE 3O,2O2I
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.
REQUEST NO. 1: Please provide a schedule with updated2020 information in the
format of Larkin Exhibit No. 2.
REQUEST NO.2: The following requests are related to information in Larkin Exhibit
No. I
a. Please provide supporting information and workpapers for the amounts listed;
b. Please provide a schedule showing all the forecasted incremental investments
anticipated (with dates expected to be placed in service) included in Component A;
c. Please provide documents supporting the $73.47 million revenue requirement for
Component A. Include the calculations for the levelized revenue requirement;
d. Please provide the supporting documents for the decommissioning costs included in
Component B. Include the calculations for the levelized revenue requiremen! and
e. Please provide the supporting documents for the non-fuel O&M savings included in
Component C. Include the calculations for the levelized revenue requirement.
REQUEST NO.3: Please provide the following analyses:
a. The impact to the Company's ROE should recovery be approved; and
b. The impact to the Company's ROE if recovery is not approved.
REQUEST NO. 4: Please explain how system reliability will be maintained given the
requested Bridger closure dates in the Application. Id.
REQUEST NO. 5: Please provide workpapers for Adelman Exhibit No. 3 in electronic
format with links intact and formulae enabled.
REQUEST NO. 6: Please provide a list of the forecasted Bridger investments through
2030 in a similar format as Adelman Exhibit No. 3 in electronic format, as discussed in
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 30,2021
Adelman's direct testimony on pages 29-32. Include a description of each investment and the
justification for projects over $l million dollars.
REQUEST NO. 7: In Adelman's direct testimony, pages 6-7,he states, "The revision
has been proposed for approval by the U.S. Environmental Protection Agency ('.EPA"), Region
8 and was submitted to the office of the Federal Register. The co-owners are currently awaiting
action from the incoming Administration." Please provide:
a. A copy of the proposed plan submitted to the EPA;
b. The exit dates for each Bridger unit in the plan submitted to the EPA; and
c. When the co-owners expect the EPA to decide on the proposed plan?
REQUEST NO. 8: In Adelman's direct testimony, page9, he states, "Appropriation
Requests are available for every project, which include a project description, investment reason,
project number, and projected expenditures for the project, by year." Please provide:
a. A copy of the Appropriation Requests for all projects over $1 million made between
January 1,2012, through December 21,2020;
b. The actual expense, by year, for all projects over $1 million incurred between
January 1,2012, through December 21,2020; and
c. A copy of the Appropriation Requests for all projects over $1 million for the
forecasted Bridger investments through 2030 discussed on pages 29-32 in Adelman's
direct testimony.
REQUEST NO. 9: In Adelman's direct testimony, pages 9-10, he states, "Under the
agreement, if the forecast for projects changes by 10 percent or more during the calendar year,
PacifiCorp will noti$ Idaho Power." Please provide:
a. A list of projects over $l million that the forecast changed by 10 percent or more;
b. An explanation why the forecast changed by l0 percent or more for these projects;
and
c. Any documentation and/or evidence for justification of the change.
FIRST PRODUCTION REQUEST
TO IDAHO POWER aJ JUNE 3O,2O2I
REQUEST NO. 10: In Larkin's direct testimony, page 8, he states, "Idaho Power
believes a depreciable life of year-end 2030 for all units is appropriate as it will help minimize
revenue requirement impacts to customer." Has the Company performed an analysis on the
impact of depreciation dates other than the 2030 date? If so, provide any analyses the Company
performed.
REQUEST NO. 11: On page 30 of Adelman's direct testimony, he states the capital
addition forecast assumes PacifiCorp's current exit dates of the four Bridger units. On page 20
of Larkin's direct testimony, he discusses the total forecasted incremental investments of $95.05
million and how this cost forecast is modeled based on Idaho Power's Preferred Portfolio
Bridger exits dates, with the exception of the first unit. Please respond to the following:
a. Is the capital addition forecast discussed by Adelman the same as the forecasted
incremental investments of $95.05 million discussed by Larkin? Please explain your
response;
b. If the capital addition forecast is the same as the forecasted incremental investment,
please explain which set of Bridger exit dates (PacifiCorp's or Idaho Power's) was
used to determine the forecast; and
c. Please provide a detailed list of the individual projects that make up the $95.05
million discussed by Larkin. Please provide the list in electronic format with links
intact and formulae enabled and include a description of each investment, and the
justification for projects over $l million dollars.
DATED at Boise, Idaho, tnis 34ay of June 2021.
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Erick Shaner
Deputy Attorney General
i:umisc:prodreq/nsww2l . I esksk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JLINE 3O,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF JUNE 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-21-I7, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: lnordstrom@.idahopower.com
dockets@ idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL : [e-mail]
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE