20230119Staff 1-6 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 9 PM D 50
PO BOX 83720
BOISE,IDAHO 83720-0074 SiCN
[phone]
IDAHO BAR NO.11202
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-22-30
AUTHORITY TO ESTABLISH )COMPENSATION FOR THE MANDATORY )INTERRUPTION REQUIREMENTOF )FIRST PRODUCTION
SCHEDULE 20 -SPECULATIVE HIGH-)REQUESTOF THE
DENSITY LOAD )COMMISSION STAFF
)TO IDAHO POWER COMPANY
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 followingdocuments and information as soon as possible,but no later than
THURSDAY,FEGRUARY 9,2023.
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 identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 JANUARY 19,2023
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.
REQUESTNO.1:Please provide all workpapers in electronic format with formulas
enabled supporting the Company's proposed interruptioncompensation contained in the
Application.
REQUESTNO.2:Please explain if the Company considered any other methods for
determining an interruption compensation structure for Schedule 20 besides the method
discussed in the Application.If other methods were considered,please explain the method(s)
considered and why these method(s)were not selected.If no other method(s)were considered,
please explain why.
REQUESTNO.3:If the Commission deferred approving a compensation structure
until evaluation of cost assignment responsibility for Schedule 20 is completed in a general rate
case,please explain how the Company would evaluate the compensation structure.In addition,
please explain what information is required to perform the analysis and if the information would
be available in the Company's next general rate case.
REQUESTNO.4:If the Commission deferred approving a compensation structure
until evaluation of cost assignment responsibility for Schedule 20 is completed in a general rate
case,please explain how the Company would avoid the double crediting discussed on page 6 of
the Application during the evaluation.
REQUESTNO.5:If the Commission were to approve the Company's proposed
compensation structure from the Application,please explain whether the Company would
reevaluate the compensation structure during the next general rate case.If so,please explain
how the Company would evaluate the compensation structure both with and without (no new
Schedule 20 customers in the system)actual customer data.If not,please explain why.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JANUARY 19,2023
REQUESTNO.6:Please explain how the Company's proposed compensation structure
from the Application avoids the double crediting discussed on page 6 of the Application.
DATED at Boise,Idaho,this day of January 2023.
Riley Newton
Deputy AttorneyGeneral
i:umisc:prodreq/ipce22.30rnme prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 JANUARY 19,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF JANUARY 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-22-30,BY E-MAILING
A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNERLISANORDSTROMPAULGORALSKI
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail] [e-mail]@idahopower.com
S CRET Y
CERTIFICATE OF SERVICE