20230330Staff to IPC 1-6.pdf

MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NOS.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-23-09
AUTHORITY TO IMPLEMENT FIXED COST )ADJUSTMENT ("FCA")RATES FOR )FIRST PRODUCTION
ELECTRIC SERVICE FROM JUNE 1,2023 )REQUESTOF THE
THROUGH MAY 31,2024.)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than THURSDAY,APRIL 20,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 MARCH 30,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide all internal audit reports and Sarbanes Oxley
("SOX")audits associated with the FCA or any components of the FCA that have been
completed since 2020.
REQUESTNO.2:Please provide the monthly sales forecast in kWh for the residential
and small general service classes in the 2023-2024 FCA year.
REQUESTNO.3:For the customer counts listed in Exhibit No.3,please provide
supporting documentation for these monthly customers counts and an explanation of how the
monthlycustomer counts were derived.
REQUESTNO.4:Please provide supporting documentation for the billed kWh sales
provided in Exhibit No.3.
REQUESTNO.5:Please provide a schedule showing kWh sold per month from
January 2021 through March 2023 separated by customer class.
REQUESTNO.6:Please provide Exhibit Nos 1 -6 in excel format,with all formulas
still intact.
DATED at Boise,Idaho,this lÒNday of March 2023.
Michael Duval
Deputy Attorney General
i:umisc:prodreq/ipce23.9dvic prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 30,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF MARCH 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-09,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA D NORDSTROM PAWEL P GORALSKI
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
[e-mail]
SECRETÁlfY
CERTIFICATE OF SERVICE