20221130Staff 1-18 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
IN THE MATTER OF IDAHO POWER
COMPAI\IY,S APPLICATION FOR REVIEW OF
THE COMPANI"Y'S CURRENT WILDFIRE
MITIGATION PLAI\I AND AUTHORIZATION
TO DEFER NEWLY IDENTIFIED
INCREMENTAL WILDFIRE MITIGATION
COSTS
;iItiElVED
i!,:? I;iiY 30 fil{ llr I 2
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CASE NO.IPC-E-22-27
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPAIIY
Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, DECEMBER 21, 2022.
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 identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER I NOVEMBER30,2022
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 explain how the Idaho jurisdictional wildfire mitigation
expense allocations are determined and provide supporting information or workpapers with
formulas intact.
REQUEST NO. 2: Please describe the expenses that will be included in the new
Information Technology cost category. Please explain whether this new category is limited to
the EONS communication tool or if other expenses included. Please explain.
REQUEST NO.3: Please describe how the EONS communication tool works and its
compatibility with other emergency management communication platforms used by the
Company and the Idaho Office of Emergency Management.
REQUEST NO. 4: Please describe the costs for each component of the communications
systems used for wildfire management including the new EONS tool.
REQUEST NO. 5: Please provide a breakdown of the costs associated with the covered
wire/conductor pilot project. Has the Company evaluated results of any similar projects
conducted by other utility companies? If not, why? If yes, what are the key takeaways the
Company learned?
REQUEST NO. 6: Please explain how costs associated with fuel reduction are allocated
with the Idaho Department of Lands, the National Forest Foundation, the U.S. Forest Service,
and U.S. Bureau of Land Management and provide any supporting information or worksheets
with formulas intact.
REQUEST NO. 7: Please explain how the Company will prevent or minimize the risk
of camera loss particularly in remote areas.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 NOVEMBER30,2022
REQUEST NO. 8: Please describe and provide supporting workpapers for the annual
Operational and Maintenance ("O&M") ca"mera costs by each camera type including all camera
programs.
REQUEST NO. 9: Please provide a cost comparison of wood to fiberglass crossarrns
based on service life of each type. Please provide workpapers supporting the Company's
assertion that fiberglass was the most cost-effective alternative when considering up-front capital
and installation costs. Wildfire Mitigation Planat32.
REQUEST NO. l0: Please describe the location selected for undergrounding 1.5 miles
of overhead line including an explanation of why the location was selected.
REQUEST NO. 11: On page l2 of its Application, the Company describes a new
weather forecasting ensemble.
a. Please provide a complete description of how the ensemble approach improves
decision making and results the Company expects to achieve.
b. Please describe the costs for implementing and maintaining the forecasting ensemble
and provide supporting information or workpapers with formulas intact.
REQUEST NO. 12: Please explain the differences between the Company's current pole
inspection program and what a contractor would do in a pole loading assessment. Explain the
benefits of having a contractor perform the pole loading assessment.
REQUEST NO. 13: The Company plans to join the Intemational Wildfire Risk
Mitigation Consortium. Please list other groups, organizations, or consortiums the Company is
involved with or a member of that are associated with wildfire mitigation.
REQUEST NO. 14: Please explain the incremental year over year expense lncreases rn
Table 3 of the Application for the Wildfire Mitigation Program Manager.
FIRST PRODUCTION REQUEST
TO IDAHO POWER aJ NOVEMBER30,2022
REQUEST NO. 15: Please describe why the Company's proposed vegetation-focused
satellite and aerial patrols benefit beyond the UAV methods currently used by the Company.
REQUEST NO. 16: Please provide a detailed description of the costs associated with
the $l 1.7 million incremental expense for transition to a three-year clearing cycle, please include
any workpapers with formulas enabled.
REQUEST NO. 17: Please provide examples of materials and programs the Company
intends to provide customers for the Public Safety Power Shutoff("PSPS") plan.
REQUEST NO. 18: Please provide a workpaper showing a breakdown of all costs
associated with the yearly $71,000 PSPS focused communication expense.
DATED at Boise, Idaho, thkkifday of November 2022.
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Riley Newton
Deputy Attorney General
i:umisc:prodreq/ipce22.27mksk prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 NOVEMBER30,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3OTH DAY OF NOVEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIM,
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC.E-22-27, BY E-MAILING A COPY THEREOF, TO THE FOLLOWNG:
LISA NORDSTROM
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
msoicoecheaal [e-mail]
dockets@idahopower. com
ALISON WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
SECRE
CERTIFICATE OF SERVICE