20230711ICIP 1-9 to IPC.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, Idaho 83702
Telephone: [phone] I
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT
CASE NO. IPC-E-23-II
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
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Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industrial Customers of Idaho Power ("ICIP") by and through its
attorney of record, Peter J. Richardson, hereby requests that ldaho Power Company ("ldaho
Power" or the "Company") provide responses to the following with supporting documents,
where applicable.
This production request is to be considered as continuing, and Idaho Power 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 responses or documents produced.
In addition to providing your responses to Mr. Richardson at the address noted above,
please provide an additional electronic copy, or if unavailable, a physical copy, to Dr. Don
FIRST PRODUCTION RE,QUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE I
RECEIVED
Tuesday, July 11, 2023 4:37:43 PM
IDAHO PUBLIC
UTILITIES COMMISSION
Reading at:280 S Silverwood Way, Eagle, Idaho 83616, Tel: [phone];
dreading@mindspring. com.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REOUEST FOR PRODUCTION NO. 1
Please provide, in electronic format with all formulae intact where possible, all workpapers and
other documents used in the development of Idaho Powers Application in this matter.
RFJ,OT]EST F'OR DUCTION NO. 2
Please provide copies of all communications between ldaho Power and the Idaho Public Utilities
Commission and/or its Staff regarding ldaho Power's Application in this matter
UEST FOR PRODUCTI
Please provide copies of all responses to production requests (both formal and informal)
provided to any other party to this proceeding
REOUEST FOR PRODUCTION NO. 4:
Please provide the class cost-of-service (CCOS) model used by Pawel P. Goralski in electronic
format with all formulas intact and enabled along with all workpapers used to develop used to
create CCOS.
FOR PRODUCTION NO.
Exhibit No. 48, P. Goralski IPC, Page 5 of 5, lists a column labeled 'Cost of Service Index'.
Please provide an explanation of how the Index was calculated. Please provide all workpapers
and models in electronic format with all formulae intact used in the calculation of the Index.
REOUEST FOR PRODUCTION NO. 6:
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 2
Exhibit No. 42, P. Goralski IPC, Pages I and2,lists row 39 labeled 'Rate of Return -
Index'. Please provide an explanation of how this Index was calculated. Please provide all
workpapers and models in electronic format with all formulae intact used in the calculation of
the Index.
REQUEST FOR PRODUCTION NO. 7:
Please explain fully and how each calculation varies for the 'Cost of Service Index' and the 'Rate
of Retum - Index' found in Exhibits 42 and 48.
REOUEST FOR PRODUCTION NO. 8:
Which Index, the 'Cost of Service Index' or the 'Rate of Return - [ndex', was used in the
allocation of rate increases to the customer classes? Please explain fully rational of why that
Index was chosen.
REOUEST FOR PRODUCTION NO. 9:
The Direct Testimony of Grant Anderson on page 30, states, "For all rate components, the
Company is proposing rates that represent a uniform 30 percent movement toward the costs to
serve" for Large Power Service. Please explain fully why 30 percent was selected and/or derived.
Also please explain fully why the Company did not propose to move this class to full Cost-of-
Service.
REOUEST FOR PRODUCTION NO. 9:
Page 1 1 of P. Goralski DI presents Table 1 that indicates the Classification of Purchased Power -
PURPA has been changed from Demand/Energy to 100% Energy. Given the PURPA rate
contains both a capacity portion and an energy portion please explain fully the rationale why
PURPA should be classified as all energy and provide supporting documentation of your
analysis.
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 3
Dated this l0th day of luly 2023
Peter J.ISB # 3195
RICHARDSON ADAMS, PLLC
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 4
I HEREBY CERTIFY that on the 10tl'day of July 2023,a true and correct copy of the within and
foregoing FIRST PRODUCTION REQUEST of the Industrial Customers of ldaho Power in
Case No. IPC-E-23-11 was served, by electronic copy only, to:
Lisa D, Nordstrom
Donovan Walker
Megan Goicoechea Allen
Regulatory Dockets
Idaho Power Company
[e-mail]
dwalker@idahopower. com
mgoicoecheallen@idahopower. com
[e-mail]
Clean Energy Opportunities for Idaho
Courtney White
Mike Heckler
courtney@cleanenergvopportunites. com
mike@cleanenergyopportunities. com
Kelsey Jae
Law for Conscious Leadership
kel sey @,kel seyi ae. com
Idaho Conservation League
Marie Callaway Kellner
[e-mail]
Idaho Conservation League
Brad Heusinkveld
bheusinkveld@ idahoconservation. org
Idaho Irrigation Pumpers Association, Inc
elo(@echohawk.com
lance@aegisinsi ght. com
Commission Secretary
Idaho Public Utilities Commission
secretary@puc. idaho. gov
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
i an. noriy uk i(ò,puc.idaho . s ov
Timothy Tatum
Connie Aschenbrenner
Matt Larking
ttatum@,idahopower. com
cashenbrenner@ idahopower. com
mlarkin@idahopower. com
City of Boise
Ed Jewell
Will Gehl
Darrell Early
fboise
dearly@cityo fboise.org
ej ewell @ cit)¡ofbo ise. org
IdaHydro
C. Tom Arkoosh
tom. arkoosh@arkoosh. com
erin. ceci I lô,arko o sh. com
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 5
Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin Vy'. Jensen
Jim Swier
darueschhoff@ hollandhart. com
tnel son@hollandhart. com
awj ensen@.hollandhart. com
[e-mail]
elmoser@holllandhart. com
[e-mail]
rsB # 3195
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 6