20210930Staff 1-14 to IPC.pdf

JOHN R. HAMMOND, JR. (ISB #5470)
DAYN HARDTE (rSB #9917)
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 s7 1334-03 t2
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION FOR APPROVAL OF
A CUSTOMER SURCHARGE AND
MODIFIED LINE ROUTE CONFIGURATION
FOR CONSTRUCTION OF A NEW 138 KV
TRANSMISSION LINE IN THE WOOD RIVER
VALLEY
Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E.21,.25
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,
John R. Hammond Jr., Deputy Attomey General, request that [daho Power Company ("Company")
provide the following documents and information as soon as possible, or by THURSDAY,
ocroBER 21, 2021.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01 .228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 30,2O2I
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: If the modified line route and surcharge are approved, please explain in
detail how expenses and surcharge revenue will be tracked and reported to the Commission.
REQUEST NO.2: If the modified line route and surcharge are approved, please provide
the following information regarding operation and maintenance ("O&M") of the modified line:
a. How will O&M costs be paid for?
b. How will the general body of rate payers be held harmless for the incremental
maintenance costs incurred by undergrounding of the line?
c. Please describe expected annual O&M costs for the overhead portion of the modified
line.
d. Please describe expected annual O&M costs for the underground portion of the modified
line.
REQUEST NO.3: Please provide the expected useful lives and the annualized revenue
requirement for the following:
a. The incremental 1.4 miles of transmission line that will be undergrounded.
b. The 8 miles of distribution line from the Wood River Substation to Owl Rock Road that
will be undergrounded.
c. The overhead transmission line included in the CPCN that is being replaced by the
undergrounded transmission line
d. The overhead distribution line included in the CPCN that is being replaced by the
undergrounded di stribution line.
REQUEST NO. 4: Please provide the cost estimates and all related workpapers (in
electronic format with formulae intact) for both the undergrounding of the incremental 1.4 miles of
transmission line to Owl Rock Road and for the 8 miles of distribution line from the Wood River
Substation to Owl Rock Road.
REQUEST NO. 5: Please provide the "segment-by-segment" cost estimates provided to
the Blaine County Planning & Zoning("P&Z-) Commission as described in Adelman's testimony
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 SEPTEMBER 30,2O2I
REQUEST NO. 6: Please identi$, the cost estimate that will be used to determine the cost
of the original Certificate of Public Convenience and Necessity ("CPCN") route used for
determining the actual cost of additional Owl Rock Road Burials. Specifically, will it use the
updated version as described in Adelman's testimony rather than the original CPCN estimates?
REQUEST NO. 7: Please provide detailed cost estimates and all related workpapers (in
electronic format with formulae intact) for the original CPCN route that was used in Case No.
IPC-E-16-28 and for the CPCN route that will be used to calculate the actual cost of the additional
Owl Rock Road Route burials as described in Adelman's testimony.
REQUEST NO. 8: Please provide maps showing the layout and identif, the location of the
infrastructure contained in the cost estimates for the following:
a. The original CPCN route.
b. The original CPCN route updated to reflect the updated cost estimate discussed in
Adelman's testimony.
c. The segment-by-segment route alternatives provided to the Blaine Cowty P&Z
Commission.
d. The final route agreed to by Blaine County that is included for recovery in this
Application.
REQUEST NO. 9: Please provide a proposed timeline for construction of the redundant
line.
REQUEST NO. 10: Please provide the supporting documentation and calculations for the
net present value of the 2U-year surcharge referred to on page 15 of witness Tatum's testimony.
REQUEST NO. 11: Please describe and provide documentation on how the allocation and
collection of the surcharge would change if the Company included Schedule 15 - Dusk to Dawn
Lighting, Schedule 40 - Unmetered, and Schedules 4l and 42 - Trafhc Control customers.
REQUEST NO. 12: Please provide a copy of the Backup Power Report referred to on
page 7 of the Company's Petition. Please also include all associated workpapers.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY J SEPTEMBER 30,2021
REQUEST NO. 13: Please provide a copy of the Company's 2020 revaluation of the Back
Up Power report referred to on page 8 of the Company's position and include all associated
workpapers.
REQUEST NO. 14: Please provide a copy of the Blaine County's non-scientific survey of
its residents as mentioned on page 16 of the Company's Petition. Please include the process for
gathering the results, along with a copy of the survey and all other workpapers associated with it.
DATED at Boise, Idaho, this day of September 2021.
Jr.
Attomey General
i:umisc:prodreq/ipce2 l.2Sjhdhksk prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
J
4 SEPTEMBER 30,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAF'F TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-21-25, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: dwalker@ idahooower.com
[e-mail]
KIKI LESLIE A TIDWELL
704 N RIVER ST #1
HAILEY TD 83333
E-MAIL: ktinsv@.cox.net
TIMOTHY K GRAVES
CHIEF DEPUTY PROSECUTING
ATTORNEY
219 IST AVE S STE 201
HATLEY ID 83333
E-MAIL : [e-mail]. id.us
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: ttatumrZ)idahopower.com
RONALD L WILLIAMS
HAWLEY TROXELL
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ELECTRONIC ONLY
BRADLEY MULLINS
MW ANALYTICS ENERGY
E-MAIL : [e-mail]
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SECRET AY-
CERTIFICATE OF SERVICE