20221213Staff 19-31 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
COMPAIIY'S APPLICATION FOR REVIEW OF
THE COMPAI\'Y'S CURRENT WILDFIRE
MITIGATION PLAN AND AUTHORIZATION
TO DEFER NEWLY IDENTIFIED
INCREMENTAL WILDFIRE MITIGATION
COSTS
CASE NO. IPC-E.22-27
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPAI\Y
IT[ilEIVED
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney 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 attomey of record,
Riley Newton, Deputy Attorney General, requests that ldaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, JANUARY 3, 2023.
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 identifu the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 DECEMBER13,2022
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. 19: Please describe alternative methods to the proposed vegetation-
focused satellite and aerial patrols that the Company evaluated. Application at2l. Please
provide the analysis the Company completed to determine the use of vegetation-focused satellite
and aerial patrols. Please include Excel spreadsheets with cost comparisons between all
altemative methods evaluated by the Company.
REQUEST NO. 20: Please explain how the proposed vegetation-focused satellite and
aerial patrols described in the Application differ from currently used satellite methods such as
how satellites are used for the Fire Potential Index ("FPI") in the Wildfire Mitigation Plan
("WMP"). Wildfire Mitigation Plan at 34. Please describe the additional capabilities or
advantages expected.
REQUEST NO.2l: The Company states that "in 2024 and beyond, it will utilize
contract purchase services to aid in further refinement of the ensemble weather forecast system
and weather and climate data analysis." Application at 12. Please describe how the contract
purchase services will be monitored following implementation.
REQUEST NO.22: Please provide the analysis used by the Company to determine that
field observers will benefit from the deployment of mobile weather kits. Application at 14.
a. How many field observers does the Company deploy?
b. How will the Company determine which field observers will be issued kits?
REQUEST NO.23: Please explain why the Company's Transition tolMaintain 3-yr
Vegetation Management Cycle in Attachment 2 is approximately $1.175 million higher in2024
than planned spend for 2025. Please provide supporting workpapers.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 DECEMBER 13,2022
REQUEST NO. 24: Please describe what membership in the Idaho Fire Board entails,
provide how often the group meets, and supply copies of or links to meeting information and
minutes.
REQUEST NO.25: Please describe the composition of the Technology Strategy
Initiative team and function of each member.
REQUEST NO.26: Please clarify if the Company's fuel reduction plan includes the
regional fuel reduction program described on page 29 of the2022WMP. Additionally, please
explain how costs are determined and allocated among participants in the regional fuel plan.
Please provide supporting workpapers.
REQUEST NO. 27: Please provide an analysis that shows how and why a l0-year cycle
was selected for the detailed visual inspection and wood pole ground line inspection programs.
Please provide supporting workpapers.
REQUEST NO. 28: Please provide a copy of the Company's Emergency Response
Communication Plan.
REQUEST NO. 29: Please quantiS the updated overall cost for the entire Wildfire
Mitigation Plan for the years 2021 through2025. Please include the operating expenses specific
to the wildfire mitigation plan, the increased vegetation management expenses, Wildfire
Mitigation Plan capital investments, the depreciation expense associated with those capital
expenditures, and the insurance cost. Please break down the expenditures by project, by type of
expense, and by year.
REQUEST NO.30: Please provide the supporting documentation for the increase in
insurance related to the Wildfire Mitigation Plan for 2021. Please provide any supporting
documentation for the estimated increase to insurance costs for 2022 and2023.
SECOND PRODUCTION REQUEST
TO IDAHO POWER J DECEMBER 13,2022
REQUEST NO.3l: Please provide the actual costs for 2021, separated into the various
components of the Wildfire Mitigation PIan. Please quantiff the inuemental amounts that have
been deferred by component.
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DATED at Boise,Idatro, this /3 du1 of December2}22
for:Deputy Attorney General
i:umisc:prodrcq/ipce22.27mklksk prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 DECEMBER13,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I3TH DAY OF DECEMBER 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-22-27, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
mgoicoecheaallen@idahopower. corn
dockets@ idahopower.com
ALISON WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE