20210713Staff 6-16 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.9917
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, TD 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES DUE
TO REVISED DEPRECIATION RATES FOR
ELECTRIC PLANT.IN-SERVICE
CASE NO. IPC.E.2I-18
SECOND 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,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than TUESDAY,
AUGUST 3,2021.
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
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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I JULY 13,2O2I
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. 6: For each account shown within PART VII. SERVICE LIFE
STATISTICS of EXHIBIT NO.2 -2020 DEPRECIATION STUDY, please provide all
"ORIGINAL LIFE TABLE" data in electronic format (i.e. Microsoft Excel or Word).
REQUEST NO. 7: For each account shown within PART VIII. NET SALVAGE
STATISTICS of EXHIBIT NO.2 -2020 DEPRECIATION STUDY, please provide all
"SUMMARY OF BOOK SALVAGE" data in electronic format (i.e. Microsoft Excel or Word)
REQUEST NO.8: For each account shown within PART IX. DETAILED
DEPRECIATION CALCULATIONS of EXHIBIT NO.2 - 2020 DEPRECIATION STUDY,
please provide aII "CALCULATED REMAINING LIFE DEPRECIATION ACCRUAL
RELATED TO ORIGINAL COST AS OF DECEMBER 31,2020" data in Microsoft Excel
electronic format with formula intact.
REQUEST NO. 9: Staff is expanding its depreciation analytic tools. For Account
355.00 POLES AND FIXTURES referenced on page IX-127 within PART IX. DETAILED
DEPRECIATION CALCULATIONS of EXHIBIT NO.2 - 2020 DEPRECIATION STUDY,
please explain and show in detail the mathematical steps used during the last ten years for
calculating:
a. CALCULATED ACCRUED;
b. ALLOC. BOOK RESERVE;
c. FUTURE BOOK ACCRUALS;
d. REM. LIFE; and
e. ANNUAL ACCRUAL.
f. Explain why no data is shown for 1945.
Note: Where a value or variable is used in the calculation that is not directly shown in
the table, please provide the source and basis for the value or variable, its purpose, how it varies
within the table, and the factors contributing to the variation.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 13,2O2I
REQUEST NO. 10: Please provide all depreciation and salvage account data prior to
any adjustment made or recommended by Gannett Fleming Valuation and Rate Consultants,
LLC.
REQUEST NO. 11: Please provide all documentation by Gannett Fleming Valuation
and Rate Consultants, LLC for addressing corrections or adjustments to the original Company
data used in the 2020Depreciation Study.
REQUEST NO. 12: Please explain the reason for any adjustment to the original
Company data (excluding corrections).
REQUEST NO. 13: Please provide any study completion schedule(s) and/or
flowchart(s) used by Gannett Fleming Valuation and Rate Consultants, LLC for the completion
the Company' s 2020 Depreciation Study.
REQUEST NO. 14: Please provide dates and copies of all notes, photographs, and or
workpapers developed by Gannett Fleming Valuation and Rate Consultants, LLC during the
Company employee interviews, or meetings held for completing the Company's 2020
Depreciation Study.
REQUEST NO. 15: Please provide dates and copies of all notes and or workpapers
developed by Gannett Fleming Valuation and Rate Consultants, LLC during field site facility
visits whether the visit was directly onsite or virhral.
REQUEST NO. 16: For each account where Gannett Fleming Valuation and Rate
Consultants, LLC selected a particular Iowa-type curve, please explain the basis for selecting the
curve and why other curves were removed from consideration.
SECOND PRODUCTION REQUEST
TO IDAHO POWER aJ JULY I3,2O2I
r3BDATED at Boise, Idaho, this day ofJuly 2fr21.
Deputy Attonrey General
i:umiscprodrcqfipeo2,l.lS&jt pod req 2
SECOND PRODTJCTION REQUEST
TO IDAHO POWER 4 JULY 13,20?1
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF ruLY 2021, SERVED
THE FOREGOTNG SECOND PRODUCTION REQUEST OF TIm COMn{ISSION
STAFF TO IDAHO POWER COMPAIYY, IN CASE NO. IpC-E-2t-18, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower.com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE