20210803IPC to Staff 6-16.pdf

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An IDACOIP Company
LISA D. NORDSTROM
Lead Counsel
lnordstrom@ida hopowe r.com
LDN:sg
Enclosures
August 3,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Re:Case No. IPC-E-21-18
ln the Matter of the Application of ldaho Power Company for Authority to
lncrease lts Rates Due to Revised Depreciation Rates for Electric Plant-ln-
Service
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho Power
Company's Response to the Second Production Request of Commission Staff.
Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Very truly yours,
X*!.(,,1-t.-*,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. s733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstromtOida honower-com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORIry TO
INCREASE ITS RATES DUE TO
REVISED DEPRECIATION RATES FOR
ELECTRIC PLANT.I N.SERVICE.
CASE NO. |PC-E-21-18
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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COMES NOW, ldaho Power Company ("ldaho Powe/'or "Company"), and in
response to the Second Production Request of the Commission Staff dated July 13,
2021, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
REQUEST NO. 6: For each account shown within PART Vll. 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).
RESPONSE TO REQUEST NO. 6: Please see the attached.
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, ldaho Power Company.
IDAHO POWER COMPANYS RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.2
REQUEST NO. 7: For each account shown within PART Vlll. 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).
RESPONSE TO REQUEST NO. 7: Please see the attached.
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.3
REQUEST NO. 8: For each account shown within PART IX. DETAILED
DEPRECIATION CALCULATIONS of EXHIBIT NO.2 - 2020 DEPRECIATION
STUDY, please provide al! "CALCULATED REMAINING LIFE DEPRECIATION
ACCRUAL RELATED TO ORIGINAL COST AS OF DECEMBER 31, 2020" data in
Microsoft Excel electronic format with formula intact.
RESPONSE TO REOUEST NO. 8: Please see the attached file. The file has
been provided in Microsoft Word as the data is not available in Microsoft Excel.
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.4
REQUEST NO. 9: Staff is expanding its depreciation analytic tools. For
Account 355.00 POLES AND FIXTURES referenced on page lX-127 within PART lX.
DETAILED DEPRECIATION CALCULATIONS of EXHIBIT NO.2 - 2O2O
DEPRECIATION STUDY, please explain and show in detailthe 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
t. 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.
RESPONSE TO REQUEST NO. 9:
a. - d. There are no mathematical steps to compute the Calculated Accrued,
Allocated Book Reserve, Future Book Accruals and Remaining Life. The amounts are
based on the curve or age of the assets.
e. The Annual Accrual in column (7) is the Future Book Accrual in column (5)
divided by the Remaining Life in column (6).
f. ldaho Power's plant records do not include activity within Account 355.00 -
Powers and Fixtures with a vintage of 1945. The absence of activity is an indication
that either no Account 355.00 assets were installed that year or that any 1945 Account
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.5
355.00 assets that were installed were fully retired prior to the late 1990s when the
Company's plant asset records were converted to the current plant accounting software
application.
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.6
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.
RESPONSE TO REQUEST NO. 10: Please see the attached files.
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF. T
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 2020 Depreciation Study.
RESPONSE TO REQUEST NO. 11: Please see Attachment 1, which sets forth
adjustments to the origina! Cohpany plant data used in the 2020 Depreciation Study,
and Attachment 2 which sets forth adjustments to the original Company net salvage
data used in the 2020 Depreciation Study. The adjustments primarily reflect transaction
code changes in order to properly establish the most appropriate survivor curve and net
salvage percentage for each asset class into the future.
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF. S
REQUEST NO. 12: Please explain the reason for any adjustment to the origina!
Company data (excluding corrections).
RESPONSE TO REQUEST NO. 12: Most of the adjustments represent changes
in the transactional code based on discussions with Company personnelto understand
the cause of the transaction. Some of these entries were considered abnorma! or
outliers which will not be consistent with the expectations of other assets when
determining life and net salvage characteristics.
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.9
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 Com pany's 2020 Depreciation Study.
RESPONSE TO REQUEST NO. 13: The Company's2020 Depreciation Study
sets forth the results and support for the depreciation parameters and depreciation
rates. ln addition to the files provided as attachments to other responses of Staffs
Second Production Request, please see the attached files for additional support used in
preparation of the 2020 Depreciation Study.
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
GOMMISSION STAFF. 1O
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
Compa ny's 2020 Depreciation Study.
RESPONSE TO REQUEST NO. 14: The attached files set forth the notes,
photographs and/or workpapers developed by Gannett Fleming Valuation and Rate
Consultants, LLC during Company interviews and meetings held for the 2020
Depreciation Study. Please note, a list of locations and dates of prior site visits are
provided on pages lll-2 and Ill-3 of the 2020 Depreciation Study. Confidential
Attachment 1, the Data Questions file, references additional Exce! files provided by
ldaho Power in response to the preliminary depreciation study data questions. The files
referenced include large amounts of data the Company believes is not valuable for use
by others and therefore has not provided the information at this time. However, ldaho
Power stands ready to provide the information should any party request it.
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.11
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 virtua!.
RESPONSE TO REQUEST NO. 15: Please see the Response to Request No.
14 for notes and workpapers developed by Gannett Fleming during field site facility
visits which occurred virtually.
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF. 12
REQU NO. 16:For each account where Gannett Fleming Valuation and
Rate Consultants, LLC selected a particular lowa-type curve, please explain the basis
for selecting the curve and why other curves were removed from consideration.
RESPONSETO REQUEST NO. 16: As discussed in Part lll of the 2020
Depreciation Study, life estimation and analysis is a combination of statistical analysis of
historical data and informed judgment. The statistical analysis is presented in Part Vll
of the 2020 Depreciation Study. lnformed judgment includes an understanding of
Company plans, management outlook for each asset class, observations during past
field visits, previous estimates of survivor curves from prior studies and estimates of
other electric utilities across the United States. The selected curve reflects a
combination of all the factors.
The survivor curves for generation accounts set forth the interim rates of
retirement up to the concurrent final retirement date. Many of these curves are the
same or similar to the currently approved estimate for interim retirements for Idaho
Power.
Because the criteria for the determination of the selected curve for most accounts
is the same and would therefore be repetitive to describe each one, the Company has
included a description of the process for only the mass accounts below:
o Account 352: Structures and lmprovements - The 70-R3 Iowa-type curve
was selected based on judgment and statistical fit to the original curve
through age 47. This curve represents the expected recovery pattern for
the assets reflected in this account based on historical experience and the
expectations of Company management.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
a Account 353: Station Equipment - The 52-S0 lowa-type curve was
selected based on judgment and is a reasonable fit to the original curve
through age 78. The 52-50 survivor curve does represent a longer
service life than the original curve throughout a substantial portion of the
curve. This is consistent with the expected recovery pattern of ldaho
Power management for the assets in this account. Iowa-type curves
reflecting shorter recovery patterns that were a better fit to the original
curve were not selected as they were inconsistent with Company
expectations for the future.
Account 355: Poles and Fixtures - The 61-S0.5 lowa-type curve was
selected based on judgment and is a very good fit to the original curve
through age 74 and represents the expected recovery pattern for the
assets reflected in this account based on historical experience and the
expectations of the Company. The 61-year average life is on the long end
of the industry but reflects that the trend to increased life characteristics.
Account 364: Poles. Towers and Fixtures'The 62-R1 lowatype curve
was selected based on judgment and reasonable fit to the original curve
through age 61. The historical indications show more early age
retirements and fewer older age retirements which is not the expected
recovery pattern for the assets in this account for the future. Therefore,
judgment along with historical experience and the expectations of
Company management led to the 62-year average life and R1 type curve.
o
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
o
a
Account 365: Overhead Conductors and Devices - The 50-R0.5 lowa-type
curve was selected based on judgment and is a reasonable fit to the
original curve through age 60 which represents the expected recovery
pattern for overhead conductor and devices. The 50-year average life and
forces of retirement that affect many ages of assets are consistent with the
expectations of Company management and the estimates of other utilities.
Account 370.1: Meters - AMI - The 18-R1 lowa-type curve was selected
based on the 2007-2020 historical indications and is a good fit to the
original curve through age 17. These assets are relatively young so
industry information as well as Company plans were considered to help
support the 18-year average life for this newer technology meter. Many in
the industry utilize a 1S-year average with fewer early age retirements but
the 18-R1 was a better selection for ldaho Power.
Account 390.12: Structures and lmprovements - Excludino CHQ Buildino
- The 65-S0.5 lowa-type curve was selected based on the understanding
of the type of structures in the account and the reasonably good fit to the
original curve through age 52. The 65-year average life represents the
interim rate of retirement for these structures before the concurrent date of
retirement. Both the interim curve and the probable retirement dates are
longer than currently utilized as the structures continue to be operational
for their use. The 65-S0.5 lowa-type survivor curve was truncated at age
60 consistent with the expected recovery period related to the probable
retirement dates for the major structures in the account.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF. 15
The response to this Request is sponsored by John Spanos, President, Gannett
Fleming Valuation and Rate Consultants, LLC for ldaho Power Company.
DATED at Boise, ldaho, this 3rd day of August 2021.
&-fr.ffw**,
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POWER COMFANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3'd day of August 2021, I served a true and
correct copy of IDAHO POWER COMPANY'S RESPOSNE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Gommission Staff
Dayn Hardie
Deputy Attorney General
!daho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customer of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hi!! Road
Boise, ldaho 83703
Hand Delivered
_U.S. Mail
_Overnight Mail
-FAX
X Email [e-mail]
FTP Site
_Hand Delivered
_U.S. Mail
_Overnight Mail_FAX_ FTP SiteX Email [e-mail]
i u, t--
_Hand Delivered
_U.S. Mail
_Overnight Mail_FAXX EMAIL dread [e-mail]
FTP Site
itr\nr\ {
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
cAsE NO. IPC-E-21-19
IDAHO POWER COMPANY
REQUEST NO.6
ATTACHMENT NO. 1
SEE ATTAGHED WORD DOGUMENT
BEFORE THE
IDAHO PUBLIC UTILITIES COTI,IMISSION
cAsE NO. IPC.E-21-19
IDAHO POWER COMPANY
REQUEST NO.7
ATTACHMENT NO. 1
SEE ATTACHED WORD DOCUMENT
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
cAsE NO. IPC-E-2{.{8
IDAHO POWERCOMPANY
REQUEST HO.8
l
ATTACHMEHT NO. 1
SEE ATTACHED WORD DOCUMENT
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
CASE NO, !PC.E-21.18
IDAHO POWER COMPANY
REQUEST NO. {O
ATTAGHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG.EA1.iI8
IDAHO POWER COMPANY
RESUEST NO. 10
ATTACHMENT NO.z
SEE ATTAGHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE HO, IPG-E.21.18
IDAHO POWER COMPANY
REQUEST NO. 11
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.EA1*1$
IDAHO POWER COMPANY
REQUEST NO. I{
ATTACHMENT NO.2
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-21-18
IDAHO POUI'ER GOMPANY
REQUEST NO. 13
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMIS$ON
cAsE NO. IPC-E-21-{8
IDAHO POWER GOMPANY
REQUEST NO. 13
ATTACHMENT NO.2
TRANSACTION CODE DESCRI PTIONS
Code
0
Descriotion
Reoular Retirement. All retirements from plant which occur in the course of normal
operations for causes that are to be covered by depreciation accruals. Typically, these
include all causes other than those listed below.
Reimbursed Retirement. Retirement for which the Company received payment
approximating or exceeding the depreciated original cost of the property, and such
payment was recorded as a credit to the depreciation reserye account. Reimbursed
retirements are usually related to extraordinary circumstances such as fire or other
accidents for which the loss is covered by insurance, and to property moved or
abandoned due to the requirements or requests of outside parties, for which the
Company is reimbursed.
Sale. Transfer of ownership of property for which the Company received payment
approximating or exceeding the depreciated original cost, and the property would not
have been retired at or near that time if the sale had not occurred. Sales are generally
related to circumstances in which the property has not actually been retired, but
continues in public service following the transaction. Sales in lieu of abandonment are
classified as regular retirements.
Transfer. Transfer of property between accounts or property groups. Use for both
transfers-in and transfers-orrt, and for intraaccount transfers.
Beqinning-of-lnterval Transfer. Transfer of property between accounts or property groups
that is to be considered as occurring at the beginning rather than the end of the age
interval. lncludes major transfers of property into the account or property group, such
as to initiate an account or to substantially increase the size of an existing account.
Acouisition. Purchase, trade, or similar transaction where property previously in public
service was acquired.
Adjustment. Used for control purposes in Plant Accounting data, and for adjustments,
special appropriations, ortransfers to orfrom the Depreciation Reserve account in Cost
of Removaland Salvage data.
Outlier Retirement. A retirement that occurs under unusua! circumstances such that the
analyst deems it appropriate that it be excluded from the retirements used in the service
life or salvage study.
Endino Balance. The balance of plant in service as of December 31 of the most recent
year included in the Experience Band, or as of a specific calculation date.
Beqinning Balance. The balance of plant in service as of December 31 of the year
preceding the first year included in the Experience Band.
Gross Addition. Placements of plant in service as replacements of plant retired or as
additions to plant in service.
1
2
3
4
5
6
7
8
I
I
Note: Corrections should be assigned the same code as the transaction being corrected.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-EAL1h
IDAHO POWER COMPANY
REQUEST NO. 13
ATTACHMENT NO.3
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMTITISSION
cAsE NO. IPG-E-21-18
IDAHO POWER GOMPAHY
CONFIDENTIAL
RESUEST NO. 14
ATTAGHN'ENT NO. 1
cofiFttrENTfAtiE IrilErdT sEstT
SEPfiRATELY
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPG.EA148
IDAHO POWER COMPANY
REQUEST NO. 14
ATTACHMENT NO.2
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IDAHO PUBLIG UTILITIES COMMISSION
cAsE NO. IPC.E.21-18
IDAHO POWER COMPANY
REQUEST NO. 14
ATTACHMENT NO.3
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IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21.19
IDAHO POWER COMPANY
REQUEST NO. 14
ATTACHMENT NO.4
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPG.E-21-18
IDAHO POWERGOMPANY
REQUEST HO. 14
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21.19
IDAHO POWER COMPANY
REQUEST NO. 14
ATTACHMENT NO,6
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-19
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 14
ATTAGHMENT NO.7
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