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Home My WebLink About20230420IPC to Staff 1-6.pdfMEGAN GOICOECHEA ALLEN Corporate Counsel mgoicoecheaallen@idahopower.com April 20, 2023 Jan Noriyuki, Secretary Idaho Public Utilities Commission 11331 W. Chinden Boulevard Building 8, Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-23-09 Idaho Power Company’s Application for Authority to Implement Fixed Cost Adjustment (“FCA”) Rates for Electric Service from June 1, 2023 Through May 31, 2024. Dear Ms. Noriyuki: Attached for electronic filing, please find Idaho Power Company’s Response to Staff’s First Production Request in the above-entitled matter. The confidential attachments will be provided in a separate email to the parties who sign the Protective Agreement. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, Megan Goicoechea Allen MGA:sg Enclosures RECEIVED Thursday, April 20, 2023 3:16:33 PM IDAHO PUBLIC UTILITIES COMMISSION CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Idaho Power Company’s Application for Authority to Implement Fixed Cost Adjustment (“FCA”) Rates for Electric Service from June 1, 2023 through May 31, 2024 Case No. IPC-E-23-09 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the attachments in response to Request Nos. 1 and 5 to Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company, dated April 20, 2023, may contain information that Idaho Power Company or a third party claims is confidential as described in Idaho Code § 74-101, et seq., and § 48-801, et seq., or is otherwise protected from public disclosure and as such is exempt from public inspection, examination, or copying. DATED this 20th day of April 2023. Megan Goicoechea Allen Counsel for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 MEGAN GOICOECHEA ALLEN (ISB No. 7623) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2664 Facsimile: (208) 388-6936 mgoicoecheaallen@idahopower.com lnordstrom@idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION FOR AUTHORITY TO IMPLEMENT FIXED COST ADJUSTMENT (“FCA”) RATES FOR ELECTRIC SERVICE FROM JUNE 1, 2023 THROUGH MAY 31, 2024. ) ) ) ) ) ) ) ) ) CASE NO. IPC-E-23-09 IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the First Production Request of the Commission Staff (“Commission” or “Staff”) dated March 30, 2023, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST FOR PRODUCTION NO. 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the confidential attachment provided with this response. Audit Services performed audits of internal controls over the Fixed Cost Adjustment (“FCA”) and components of the FCA during the period of 2020 to present as part of complying with Sarbanes-Oxley (“SOX”) requirements. The related SOX processes are Regulatory Fixed Cost Adjustment (“RPFC”), Customer Revenues (“CREV”) Customer Revenues IT (“CRIT”), and Entity-Wide Information & Communication (“EWIC C02”). Audit Reports are only issued for SOX internal control audits in the event of a finding(s). SOX testing is performed on a rotational basis. The following table provides testing performed on these SOX processes by year: IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 SOX Process* 2020 2021 2022 Comments RPFC: C01 N/A X N/A Not tested in 2020 or 2022 C05 N/A X N/A Not tested in 2020 or 2022 EWIC C02 Voucher #138 N/A X N/A Not tested in 2020 or 2022 CRIT: C03 X X X C05 X X X Deficiency identified in 2020 and 2022. See "2020 CRIT Final Control Report - Deficiency Identified" and "2022 CRIT Final Report - deficiency identified." C06 X X X C07 X X X C08 X X X C09 X X X C10 X X X C11 X X X CREV: C04 N/A X N/A Not tested in 2020 or 2022 C07 N/A X N/A Not tested in 2020 or 2022 C08 N/A X N/A Not tested in 2020 or 2022 EWIC C02 Voucher #57, #133 N/A X N/A Not tested in 2020 or 2022 * No SOX testing has yet been performed in 2023 The 2020 and 2022 deficiency for CRIT C05 did not impact the rate schedules included in the FCA, or FCA deferral calculation. See Confidential Attachment to this request at PDF pages 3 through 7 for the 2020 deficiency, and PDF pages 85 through 89 for the 2022 deficiency. The response to this Request is sponsored by Sonse Sutezzo, Operations Audit Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 REQUEST FOR PRODUCTION NO. 2: Please provide the monthly sales forecast in kWh for the residential and small general service classes in the 2023-2024 FCA year. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see Attachments 1-3 provided for this response. In the process of preparing the Power Cost Adjustment (“PCA”) filing the Company became aware of a variance between the forecast used in the FCA filed on March 15, 2023, and the forecast ultimately used in the PCA which was filed on April 14, 2023; Attachment 1 to this response shows the monthly sales forecast utilized for the FCA filing and the updated sales forecast utilized for the PCA filing, as well as the variance between the two test years. The discrepancy was due to an incorrect assignment of sales between the Idaho and Oregon jurisdictions in the test year forecast used for the FCA filing. Once identified, the necessary correction was incorporated for the PCA test year. Also provided as Attachment 2 to this response is an updated version of the FCA Rate Determination that was provided as Exhibit No. 5 to the Goralski Testimony, and Attachment 3 is an updated version of the Summary of Revenue Impact provided as Exhibit No. 6 to the Goralski Testimony. Together Attachments 2 and 3 demonstrate the test year update does not change the proposed 2023-2024 FCA rates and the bill impact percentage is unchanged at a decrease of 1.56 percent. There is a minor revenue impact of $196 less decrease in billed revenue, from a filed overall decrease of $9,976,903, to a decrease of $9,976,707 based on the updated test year. Idaho Power anticipates filing an Errata to the Direct Testimony of Pawel P. Goralski to replace Exhibit Nos. 5 and 6 of the Goralski Testimony with the updated versions provided as Attachments 2 and 3 to this Response. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 The response to this Request is sponsored by Paul Goralski, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 REQUEST FOR PRODUCTION NO. 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 monthly customer counts were derived. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see Attachments 1 and 2 provided for this response. Monthly customer counts are calculated by multiplying Number of Customers (“NCUST”) customer count against the relationship between the number of meters and active Utility Service Agreements (“USAs”). The monthly NCUST customer count is provided from the respective month’s NCUST Report, which is a count of customers receiving service the day cycle 21 billing is generated and includes partial-month customers. The relationship between the historical number of meters and active USAs is from the Company’s last general rate case, IPC-E-11-08, test year. Application of the relationship of meter counts and USAs to NCUST customers counts, which include partial month customers, approximates equivalent full month only customers. The response to this Request is sponsored by Paul Goralski, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 REQUEST FOR PRODUCTION NO. 4: Please provide supporting documentation for the billed kWh sales provided in Exhibit No. 3. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see Attachment 1 provided for the Company’s Response to Staff’s Request No. 3. The response to this Request is sponsored by Paul Goralski, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST FOR PRODUCTION NO. 5: Please provide a schedule showing kWh sold per month from January 2021 through March 2023 separated by customer class. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the confidential attachment provided for this response. The response to this Request is sponsored by Paul Goralski, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 REQUEST FOR PRODUCTION NO. 6: Please provide Exhibit Nos 1 - 6 in excel format, with all formulas still intact. RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see Attachments 1-6 provided for the Company’s Response to Request No. 6. Please note that Attachment Nos. 5 and 6 represent excel versions of Exhibit Nos. 5 and 6 to the Goralski Testimony as filed on March 15, 2023. The response to this Request is sponsored by Paul Goralski, Regulatory Consultant, Idaho Power Company. DATED at Boise, Idaho, this 20th day of April 2023. MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 20th day of April 2023, I served a true and correct copy of Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Michael Duval Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8 Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email Michael.Duval@puc.idaho.gov Stacy Gust, Regulatory Administrative Assistant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 1 ATTACHMENT NO. 1 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 2 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 2 ATTACHMENT NO. 2 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 2 ATTACHMENT NO. 3 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 3 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 3 ATTACHMENT NO. 2 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 5 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 6 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 6 ATTACHMENT NO. 2 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 6 ATTACHMENT NO. 3 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 6 ATTACHMENT NO. 4 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 6 ATTACHMENT NO. 5 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-09 IDAHO POWER COMPANY REQUEST NO. 6 ATTACHMENT NO. 6 SEE ATTACHED SPREADSHEET