20220422ICIP 1-13 to IPC.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone : (2OB) 938 -223 6
Fax: [phone]
peter@ richardsonandoleary.com
Attorneys for the Industrial Customers of Idaho Power
BEF'ORE THE IDAHO PUBLIC UTILITIES COMMISSION
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. ,.,. i,';i jZ Pri tr: ifu
IN THE MATTER OF THE
APPLICATION OF THE IDAHO POWER
COMPAI.IY FOR AUTHORITY TO
IMPLEMENT POWER COST
ADJUSTMENT (*PCA") RATES FOR
ELECTzuC SERVICE FROM JUNE I,
2022, THROUGH MAY 31, 2O2I
cAsE NO.IPC-E-zz-tt
FIRST PRODUCTION REQUEST OF
THE TNDUSTRIAL CUSTOMERS OF
IDAHO POWER
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Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), the Indusfial Customers of Idaho Power ("ICIP") by and through its
attomey of record, Peter J. Richardson, hereby requests that ldaho Power Company ("Idaho
Power" or the "Company") provide responses to the following with supporting documents,
where applicable.
This production request is to be considered as continuing, and ldaho Power 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 responses or documents produced.
FIRST PRODUCTTON REQUEST OF THE ICIP
TN CASE NO. IPC.E.z}-II - PAGE I
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Readin g at: 6070 Hill Road, Boise, Idaho 83703, Tel: (208) 342- l 700; Fax: (208) 384- l5 I I ;
[e-mail].
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REOUEST FOR PRODUCTION NO. I
Please provide, in electronic format with all formulae intact where possible, all workpapcrs and
other documents used in the development of ldaho Power's Application in this matter,
specifically include tables one through six of Ms. Brady's direct testimony.
REOUEST FOR PRODUCTION NO. 2
Please provide copies of all communications between [daho Power and the Idaho Public Utilities
Commission and/or its Staffregarding Idaho Power's Application in this matter.
REOUEST FOR PRODUCTION NO.3
Please provide copies of all responses to production requests (both formal and informal)
provided to any other party to this proceeding.
REOUEST FOR PRODUCTION NO.4
Please identiff the Company's Idaho jurisdictional return on equity (ROE) for each year the PCA
has been in effect.
REOUEST FOR PRODUCTION NO.5
Please identiff the rate change (year over year) in the PCA for each year the PCA has been in
effect.
REOUEST FOR PRODUCTTON NO.6
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-2z-II _ PAGE 2
Please explain, in detail, the meaning of the phrase "financial returl" when it is used in the
Company's public notice materials in the context of: "Neither ldaho Power nor its shareholders
receive any Jinancial returnfrom this filing."
REOUEST FOR PRODUCTION NO.7
Does the Company expect to receive a "financial retum' form its "requested price increase to
collect the cost of an accelerated depreciation schedule for all coal-related investments at the
Jim Bridger Power Plant...".
REOUEST FOR PRODUCTION NO.8
Beginning on line 20 atpage 30 of Ms. Brady's pre-filed direct testimony is a reference to her
"discussions" in which she "consulted with managemenr" in order to "determine what rate
mitigation, tf any, the Company should include tn this filing." Please identifl the dates of all
referenced consultations and the identity of the management personnel who were consulted. For
each referenced consultation please provide copies of all notes, agenda, minutes, email
communications documentation (whether nor not contemporaneous) and/or all documentation of
said consultations.
REOUEST FOR PRODUCTION NO.9
At the top of page 3l Ms. Brady states that she was "advised by management to not propose any
rate mitigation measures in this case." Please identify the "management" personnel who
advised against proposing any rate mitigation measures in this case. Please provide copies of all
notes, agenda, minutes, email communications and all other documentation (whether nor not
contemporaneous) of said management advise to not propose any rate mitigation measures in this
case.
REOUEST FOR PRODUCTION NO. 10
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC.E-2Z-II _ PACE 3
Does ldaho Power's management believe there is a threshold rate increase in terms of percentage
increase such at a rate mitigation measure would be warranted? What is that threshold?
REOUEST FOR PRODUCTION NO. 1I
At several places in Ms. Brady's testimony she discusses the possibility of rate mitigation
"measures" and rate mitigation "options" in the plural. Yet, her testimony only addresses the
management's rejection of a single option or a single measure which is the possibility "spreading
recovery over multiple years. " (See page 3 I line l2). What other options or measures were
discussed (and ultimately rejected) by Idaho Power's management and/or Ms. Brady that would
help to mitigate the rate impact of the Company's proposed rate increase? What other rate
mitigation measures is the company generally aware of?
REOUEST FOR PRODUCTION NO. 12
Plcase cxplain whcther the Company would support a rate mitigation measure that spreads this
proposed rate increase over several years if it were proposed by, and only applicable to,
sophisticated customers who understood the risks associated with defened collection and "rate
pancaking."
REOUEST FOR PRODUCTION NO. 13
For the time period beginning with Idaho Power's last general rate case, please provide copies of
all references to the PCA made by tdaho Power or IDACORP or their respective management in
any discussions or analysis of its financial condition, results of operations and business and/or
regulatory risks to potential or existing investors, regulatorsl, bankers and/or security and
financial analysists. Please provide copies of any comments made by the same entities/personnel
I Other than the ldaho PUC in open proceedings.
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO, IPC-E-22-II _ PACE 4
regarding ldaho Power's PCA.
Dated this 22nd day of April2022.
Peter J. Richardson tSB # 3195
RICHARDSON ADAMS, PLLC
I HEREBY CERTIFY that on the 22nd day of April a true and correct copy of the within and
foregoing FIRST PRODUCTION REQLJEST of the Industrial Customers of ldatro Power in
Case No. IPC-E-2}-I lwas served, by electonic copy only, to:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
[e-mail]
[e-mail]
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
i an. noriyuki@.puc.idaho. qov
Commission Secretary
Idaho Public Utilities Commission
secretary@puc. idaho. eov
Matthew T. Larkin
Timothy E. Tatum
Jessi Brady
m larkin@ idahopower.com
ttatum(@idahopower. com
i bradv@ idahopower.com
I
Ric
ISB # 3195
FIRST PRODUCTION REQUESTOF THE ICIP
TN CASE NO. IPC-E-z2-II - PAGE 5