20230705Staff to IPC 81-106.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
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
Attorneyfor 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 )THIRD 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 26,2023.
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 workpapersthat 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.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 1 JULY 5,2023
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.81:Please provide a detailed explanation of the Company's calculation
of uncollectible accounts.Please also include workpapers in Excel format with all formulas
mtact.
REQUESTNO.82:Please provide an explanation of the increases in payroll expenses
in April 2022 and September 2022 according to the workpaper provided by Company Witness
Noe "PayrollAnnualizingAdjustments 2023."
REQUESTNO.83:Please explain why December 2022 payroll expenses were
annualizedmultiplyingby 13 instead of by 12 in the workpaper provided by Company Witness
Noe "PayrollAnnualizingAdjustments 2023."
REQUESTNO.84:Please provide the plan documents for each of the Company's
qualified retirement plans.
REQUESTNO.85:Please provide the Summary Plan Description for each of the
Company's qualified retirement plans.
REQUESTNO.86:Please provide statistics regarding employee turnover rate from
years 2018 through 2022.Please indicate percentages of employees each year who retired,were
terminated,or voluntarilyresigned.
REQUESTNO.87:Has the Company conducted any comparative analyses of
employee retention rates for companies offering defined benefit plans vs.companies offering
defined contribution plans.If yes,please provide the analysis.If not,why not.
REQUESTNO.88:Please provide statistics regarding the percentage of employees
who participate in the defined contribution plan.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 5,2023
REQUESTNO.89:Please outline the incentive criteria for non-executive employees
and provide copies of any incentive plans or policies.
REQUESTNO.90:Please provide details regarding any occurrence where severance
pay was issued in years 2018 through 2022,if applicable.
REQUESTNO.91:Please provide job descriptions and salaries for all executive
officers and members of the board of directors.
REQUESTNO.92:The Company released a Mobile Application ("App")"...due to
the increasing shift in customers'preferences toward accessing their account and service-related
information on the go."Hanchey Direct at 15.Please respond to the followingabout the App:
a.Please provide any surveys,focus group,or other supporting documentation used
to inform the Company of customer preferences of accessing information on the
go.In the response,please include the results of any surveys conducted including
population size,how the survey was distributed,and response rate by distribution
method;
b.Please provide a supporting worksheet that details the actual amount spent on
development,implementation,maintenance,and advertisement of the App by
year since the development of the App to date;
c.Please provide a brief description and a supporting worksheet that breaks down
forecasted spend by year for 2023-2025 for the App;
d.Please explain if the Company conducted a cost benefit analysis for its App.If
yes,please provide the cost benefit analysis.If not,please explain why not;
e.Please explain how the Company promotes its App to customers.Please provide
supporting documentation;
f.Since it launched,please provide a worksheet detailing the number of customers
who have downloaded the App by month,the number of customers who use the
App on a monthlybasis,the number of customers who pay their bills monthly
THIRD PRODUCTION REQUEST
TO IDAHO POWER 3 JULY 5,2023
through the App,the number of customers who signed up for push notifications
by month through the App;and
g.Please provide an example of how a customer's bill displays through the App.
REQUESTNO.93:For My Account information accessed via desktop computers and
by the mobile website,please provide a worksheet separated by desktop computer and mobile
website access detailing the number of customers who access their information monthly,the
number of customers who pay their bills monthlythrough My Account,and the number of
customers who have signed up for text notifications by month.
REQUESTNO.94:Hanchey Direct at 29-30 describes a reduction in annual call
volumes is likely from various self-serve features implemented by the Company.Please explain
if the App and My Account has created any savings in labor due to the reduction in calls to the
Customer Service Center.
REQUESTNO.95:On page 24 of Hackett's Direct testimony,Hackett states "[t]he
Company is requestingin this case to include $146.8 million for 120 MW of battery capacity
plus an additional $28 million investment to account for performance degradationover time that
will ensure the 11 batteries maintain the 120 MW of capacity."Please respond to the following:
a.Please explain how the additional $28 million will be utilized to preserve the
batteries'capacity.Please provide supporting workpapers that detail how $28
million would be spent;and
b.Please explain if battery preservation costs were included in the least-cost least-
risk analysis in Case No.IPC-E-22-13.
REQUESTNO.96:Please provide the 2023 Integrated Resource Plan ("IRP")analysis
and workpapers used to support the Company's rationale to expand the summer season to the
end of September.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 4 JULY 5,2023
REQUESTNO.97:Please provide the analysis performed by the power supply
planning team for the 2023 IRP used to identify highest risks hours for all schedules containing
time-of-use ("TOU")components.AschenbrennerDirect at 21.
REQUESTNO.98:Please explain why the proposed expanded summer season for
customers consuming energy is different than the proposed summer season in the Company's
concurrent export credit rate filing,Case No.IPC-E-23-14.Please provide supporting
workpapers.
REQUESTNO.99:Please respond to the followingquestions about the Company's
proposed shift of Demand Side Management("DSM")labor costs from the energy efficiency
rider to base rates.
a.Under the proposed adjustment,would the Company include labor cost in its cost
effectiveness calculations?
i.If not,why not?
ii.If yes,please explain how the Company would calculate cost effectiveness
of its DSM offerings while factoring in labor cost and provide example
workpapers demonstrating the calculations in Excel format with equations
intact and enabled.
b.Please provide the annual DSM labor expenses from 2017 to 2022;
c.Please include all calculations used to apply the 2%wage increase year-to-year
from 2017 to date;
d.For the proposed Schedule 91 Energy EfficiencyRider rate,please provide a
forecast for the beginning balance as of January 1,2024,revenues,expenditures
by category (i.e.,incentive,marketing,evaluations,etc.),expenditures by
programs,and ending balance by month for 2024,2025,and 2026 in Excel format
with all equations intact and enabled.
REQUESTNO.100:Please respond to the followingregarding the Company's
Schedule 5 on-peak/off-peak price differential.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 5 JULY 5,2023
a.Please provide the Brattle study and accompanying workpapers referenced in
Anderson Direct at 19;and
b.Please provide an analysis,in Excel format with formulas enabled and intact,of
how the Schedule 5 summer 4.0x and non-summer 1.5x align with actual
Company expenditures during those times.
REQUESTNO.101:Please provide a complete list of the tools the Company's Field
Observers have available in wildfire risk zones.
a.Please provide a supporting worksheet that includes the tool name,total quantity
of tools,purchase date,and cost.Please separate the Mobile Weather Kits
purchased in 2022 from the other tools;
b.Please discuss tangible or intangible benefits that the Mobile Weather Kits have
provided;and
c.Please explain if the Company plans to purchase additional Mobile Weather Kits
in 2023 through 2025.If so,please provide number of kits and expected costs by
year.
REQUESTNO.102:Please explain the expected increase in the incremental costs for
Weather Forecasting Personnel from Version 4 of the Wildfire MitigationPlan ("WMP")to
Version 5 for the years 2023 through 2025.
REQUESTNO.103:The Company requests to continue deferring only incremental
vegetation management Operation and Maintenance ("O&M")expenses.Tatum Direct at 7.
Does the Company expect to defer any incremental costs for the other components of the WMP?
a.If no,please explain why the Company expects no incremental costs;and
b.Please provide estimated cost of incremental cost of vegetation management
O&M by year for 2023-2025.
REQUESTNO.104:Please respond to the followingabout the Emergency Outage
Notification System tool described in Hanchey Direct Testimony at 17:
THIRD PRODUCTION REQUEST
TO IDAHO POWER 6 JULY 5,2023
a.Please explain how the Emergency Outage Notification System identifies
customers in affected areas of planned and unplanned outages;
b.Please explain if the Company can automatically enroll certain customers into
outage notifications for this tool;
c.Please explain what kind of load shed events are notified by this tool;
d.Please explain if the Company can use this tool to identify and notify critical
customers in the public safety power shutoffs areas;and
e.Please provide the cost to implement and maintain this tool.Please provide
supporting workpapers.
REQUESTNO.105:Please respond to the followingabout Enterprise Omnichannel
Notification System ("EONS")tool:
a.Please explain how the EONS tool identifies customers in affected areas of
planned and unplanned outages;
b.Please explain if the Company can automatically enroll certain customers into
outage notifications for this tool;
c.Please explain what kind of load shed events,if any,are notified by this tool;
d.Please explain if the Company can use this tool to identify and notify critical
customers in the public safety power shutoffs;and
e.Please provide the cost to implement and maintain this tool.Please provide
supporting workpapers.
REQUESTNO.106:In Company Witness Hanchey's Direct testimony,he described
the Emergency Outage Notification System.Hanchey Direct at 17.Please answer the following:
a.Please explain the difference between the Emergency Outage Notification System
tool and the EONS tool used for the Wildfire Mitigation program;
b.Please provide a worksheet that details date of use,the use of the tool for
outages/load shed events other than wildfire outages/load shed events,number of
customers impacted per event,how customers were notified (i.e.,text or voice
messaging),yearlycost to use tool,FERC account booked;
THIRD PRODUCTION REQUEST
TO IDAHO POWER 7 JULY 5,2023
c.Please explain how the Company uses its different outage notification systems;
and
d.Please provide supporting worksheet that includes the functions of each
notification system.
DATED at Boise,Idaho,this day of July 2023.
Dayn Hardi '
Deputy Attorney General
i:umise:prodreq/ipce23.1 ldhkl prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 8 JULY 5,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF JULY 2023,SERVED
THE FOREGOING THIRD 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] caschenbrenner idahopower.com
[e-mail] mlarkin idahopower.com
[e-mail]
dockets idahopower.com
KELSEY JAE MICHAEL HECKLER
LAW FOR CONSCIOUS LEADERSHIP COURTNEY WHITE
920 N CLOVER DR CLEAN ENERGY OPPORTUNITIES
BOISE ID 83703 3778 PLANTATION RIVER DR
E-MAIL:[e-mail] STE 102
BOISE ID 83703
E-MAIL:
[e-mail]
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aegisinsight.com
E-MAIL:elo echohawk.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27TH ST EAGLE ID 83616
BOISE ID 83702 E-MAIL:[e-mail]
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
SECRETARY
CERTIFICATE OF SERVICE