20230707Staff 107-114 to IPC.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 )FOURTH 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 throughits 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 FRIDAY JULY 28,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER l JULY 7,2023
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.107:Please provide the Net-to-Gross Tax Multiplierworkpaper in
Excel format with formulas intact and enabled.Exhibit No.35,Line 1097,Column F.
REQUESTNO.108:Please provide the individual revenue requirement models for
Valmy,Bridger,and Battery Accumulated Deferred Income Tax Credits ("ADITC")Mitigation
in Excel format with formulas intact and enabled.Exhibit No.35,Lines 40,41,and 42.
REQUESTNO.109:Please provide the status of relicensing Hells Canyon Complex.
REQUESTNO.110:Please provide the journal entries and workpapers of the
Allowance for Funds Used During Construction ("AFUDC")for Hells Canyon Complex
relicensing.Please include the amount booked to Construction Work in Progress from 2018 to
2022.
REQUESTNO.111:Exhibit Nos.34 and 35 include Oregon Income Tax to be paid by
Idaho customers.Please provide documentation outlining source of income from an Oregon
source.
REQUESTNO.112:Please provide Schedule 72 -GeneratorInterconnections to
Public Utility Regulatory Policies Act of 1978 ("PURPA")QualifyingFacility Sellers actual
revenues and expenses for 2018 to 2023 to date in Excel format with formulas intact and
enabled.
REQUESTNO.113:Please detail the cash working capital ("CWC")method used.
Also,please provide the workpapers used to calculate CWC amounts in Exhibit No.34 in Excel
format with formulas intact and enabled.Exhibit No.34,Lines 288-305.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 7,2023
REQUESTNO.114:Utilities requesting CWC in rate base must be able to demonstrate
that CWC needs are supplied by investors.Order No.19333.Please explain and provide
documentation showing how CWC is being supplied by investors.
DATED at Boise,Idaho,this day of July 2023.
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.1ldhkl prod req 4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 3 JULY 7,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF JULY 2023,SERVED
THE FOREGOING FOURTH 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] [e-mail]
[e-mail] [e-mail]
[e-mail]
[e-mail]
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]
courtney cleanenergyopportunities.com
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