20230613Staff 1-37 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL 3 PM 2 38
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
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 THE APPLICATION )OF IDAHO POWER COMPANY FOR )CASE NO.IPC-E-23-11
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC SERVICE )FIRST PRODUCTION
IN THE STATE OF IDAHO AND FOR )REQUESTOF THE
ASSOCIATED REGULATORY )COMMISSION STAFF
ACCOUNTING TREATMENT )TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than WEDNESDAY,JULY 5,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 JUNE 13,2023
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 copies of the monthly trial balances from January
2018 through the most current month available.Please supplement your response when
additional months become available throughout 2023.
REQUESTNO.2:Please provide a copy of the Company's Chart of Accounts.
REQUESTNO.3:Please provide all workpapers and exhibits in Excel format with
formulas intact and enabled.
REQUESTNO.4:Please provide the revenue requirement model in Excel format with
formulas intact and enabled.
REQUESTNO.5:Please provide a list of all outside attorneys who performed services
for the Company or who were paid by the Company for services from the beginning of 2021
through 2023 to date.Please list the amounts paid,accounts charged,and date of payment.
Please also provide a brief summary of the services performed.Additionally,if services were
performed in support of a docketed federal/state court or regulatory action,please identify the
case name,case number,and jurisdiction.For each expense,please illustrate how the charge
was allocated to the Company's jurisdictions.
REQUESTNO.6:Please provide the total amount that the Company spent on the
followingactivities for 2020 through 2023 to date and show how the Company allocated the
amounts between jurisdictions:
a.Internal auditing expenses;
b.The Company's annual report;
c.Rating agencies;
d.All software or information system-related issues;
e.Board of Directors compensation,travel expenses,and meeting expenses;
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 13,2023
f.Corporate or chartered aircraft(s),if applicable;
g.Travel and training for all shared executives of the Company and affiliates;
h.Insurance coverage;
i.Overhead items includingutilities,property taxes,security services,and other
corporate headquarter expenses;and
j.All other allocated expenses.
REQUESTNO.7:Please provide a copy of all regulatory orders relating to the
Company or its subsidiaries issued by state agencies in Oregon or the Federal Energy Regulatory
Commission ("FERC")in 2021 through 2023 to date.
REQUESTNO.8:Please provide access to all employee newsletters published in 2021
through 2023 to date.
REQUESTNO.9:Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by employee title,division,and
company.Please include within your response the dollar level at which the individual capital
expendituresrequire approval by the Company's Board of Directors ("Board of Directors").
REQUESTNO.10:Please provide an analysis of any sales of land and/or plant for the
years 2021 through 2023 to date,if any.Please show gains,losses,and supporting
documentation includingaccounting entries for removal of items from rate base.
REQUESTNO.11:Please provide the details of any planned sales of land and/or plant
for the remainder of 2023 through 2025.Please include within your response the estimated date
of these sales and planned accounting treatment.
REQUESTNO.12:Please provide a list of "out-of-periodadjustments"and
"extraordinary items"for the years 2021 through 2023 to date.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 JUNE 13,2023
REQUESTNO.13:Please provide a schedule showing injuries and damages claims
over $1,000 for the years 2021 through 2023 to date.Please include within your response the
description of each item,the amount for each item,and the account charged.
REQUESTNO.14:Please provide the details of all advertising expenses recorded
above the line includingaccount and subaccounts where posted,dates posted,vendor names,
explanations,and amounts posted during 2021 through 2023 to date.
REQUESTNO.15:Please provide copies of all advertisements used during 2021
through 2023 to date and correlate the advertisement with the specific detail provided in the
Company's response to Request No.13.
REQUESTNO.16:Please provide copies of all billing inserts for 2021 through 2023 to
date.Please indicate the states where they were sent.Please also provide a schedule showing
the amount and account numbers charged for all costs to produce,print,and distribute the inserts.
REQUESTNO.17:Please provide copies of all Audit Reports issued by the
Company's internal auditors for all audits completed during 2021 through 2023 to date.
REQUESTNO.18:Please provide a copy of each adjustingjournal entry proposed by
the Company's independentauditors in the last two audits of the Company.Please include
within your response the documentation supporting these adjustments,and the documentation
supporting any items that the Company decided not to adjust that are not reflected in the
Company's fmancial records and/or financial statements.
REQUESTNO.19:Please provide a list of all leased items from 2021 through2023 to
date.Please separate capital leases from operating leases and show the dates,terms,amounts,
and accounts used for each lease.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JUNE 13,2023
REQUESTNO.20:Please provide a schedule of prepaid items for 2021 through 2023
to date showing amounts posted,vendor names,explanations,and accounts to which these items
were booked.Please include within your response any significant changes to prepaid items
occurring or planned to occur in 2023 and 2024.
REQUESTNO.21:For each officer of the Company,please provide the total dollar
amount of remuneration for 2018 through 2023 to date.Please separate by year,salary,incentive
pay,options,benefits,and other.For each officer,please provide the percentages of his or her
total remuneration that is allocated to other subsidiaries each year along with the basis for that
allocation.
REQUESTNO.22:Please provide the followingmonthlydirect labor related
information as recorded for 2018 through 2023 to date.Information,where applicable,should be
listed by O&M expense,other expense,construction and other account groups (listed by
functional categories,i.e.,generation,transmission,distribution,customer,A&G,etc.).Please
provide the information on a system-wide basis,and jurisdiction basis.The response should
include wages and salaries for each employee category (officer,exempt,non-exempt,and union),
paid time-off,overtime,bonuses,incentive pay,and overheads for pension,benefits,and payroll
taxes.Please also include average and year-end number of employees by employee category.
Include part-time and temporary employees as full-time equivalents.
REQUESTNO.23:Please provide the quantifiable savings from any cost/workforce
reduction programs during the past five years.Please provide any additional workforce
reduction programs planned for the remainder of 2023 through 2025.
REQUESTNO.24:Please provide the yearlypercentage pay rate increase by employee
and position since the last general rate case.Please provide in Excel format with formulas intact.
REQUESTNO.25:Please summarize all benefit and retirement plans provided to any
classification of Company employees.Please also include any changes that have occurred to the
benefits/accruals during the past five years.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 JUNE 13,2023
REQUESTNO.26:Please provide copies of the Company's pension and actuarial
reports for the years 2018 through 2023 to date.Also,please provide any actuarial calculations
and documentation that show the development of FAS 87 expenses (ASC 715 Compensation -
Retirement Benefits as codified),Company contributions,balances,and assumptions.
REQUESTNO.27:Please provide access to the Board of Directors'meeting minutes
for each meeting held during 2020 through 2023 to date.
REQUESTNO.28:Please provide copies of the Board of Directors'materials
distributed for/at meetings held from 2020 through 2023 to date.Please also include the same
for the CompensationCommittee.
REQUESTNO.29:To the extent not previously included in the Company's responses
to these Staff Production Requests,please provide access to copies of all studies used to
determine employee compensation,includingexecutive compensation,and explanations of how
the Company applied them in the years 2020 through 2023 to date.
REQUESTNO.30:Please provide a copy of the Company's property tax bills for 2021
through 2023 to date.
REQUESTNO.31:Please provide a copy of the Company's credit card,or purchase
card,policy.
REQUESTNO.32:Please provide statements for any Company credit cards that
include spending during 2022 through 2023 to date.
REQUESTNO.33:Please summarize all the Company's penalties or fines paid in 2021
through2023 to date.Please show all account numbers and the amount booked to each by
occurrence and date.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 JUNE 13,2023
REQUESTNO.34:Please describe the Company's method for developing,managing,
executing,and completing Capital Projects in a least cost manner.Please provide a copy of
Company's policies and procedures documenting the process.
REQUESTNO.35:Please provide an Excel file with formulas intact and enabled
showing all capital projects completed,by year,from 2012 through 2023 to date.For each
project,please include the following:name or title,number or identifier,in-service date,cost-of-
service classification,description,rationale analysis or business need,target start date,actual
start date,target completion date,actual completion date,estimated cost,budgeted cost,actual
cost,if a cost benefit analysis was performed,if the work was primarily completed by employees
or contractors,and if a request-for-proposal was performed.
REQUESTNO.36:Please provide a detailed Excel file of the 2023 capital expenditure
budget includingname or title,number or identifier,in-service date,cost-of-service
classification,description,rationale analysis or business need,target start date,actual start date
(if started prior to 2023),target completion date,actual completion date (if completed in 2023),
estimated cost,budgeted cost,actual cost,if a cost benefit analysis was performed,if the work
was primarily completed by employees or contractors,and if a request-for-proposal was
performed.
REQUESTNO.37:Please provide copies of the monthly,quarterly,and annual
comparisons of operating and capital budget to actual expendituresfor 2018 through 2023 to
date.Please include within your response a narrative explanation for budget variations.This
should include,but not be limited to,written operating and capital budget variance reports and
explanations used by Company officers and managers to monitor and control budgets under their
responsibility.Please supplement your response as additional information becomes available
throughout 2023.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 7 JUNE 13,2023
DATED at Boise,Idaho,this ay of June 2023.
Dadardie
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.1 l dhtnc prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 8 JUNE 13,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF JUNE 2023,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF
TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-11,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
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] caschenbrennerdidahopower.com
[e-mail] [e-mail]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE