20230714ICIP 10-21 to IPC.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
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 AUTHOzuTY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOTJNTING TREATMENT
CASE NO. IPC.E-23-II
SECOND 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 Idaho 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
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE I
RECEIVED
2023 JULY 14, 2023 3:40PM
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.
REOUBST FOR PRODUCTION NO. 10:
At page 7 of her testimony, Ms. Grow references "our [daho Power's] seven peer utilities."
Please provide the written criteria and documentation used to select the seven listed utilities as
Idaho Power's "peer utilities." Please also explain in narrative form the rationale for selecting
the listed utilities as Idaho Power's "peer utilities."
REOUEST FOR PRODUCTION NO. 11:
At page 16 of her testimony, Ms. Grow observes that, "Since the Company's last general rate
case the Company has shared 5126,752,809 of earnings with its customers under the
ADITC/Revenue Sharing Mechanism." Please identifu the dollar amount of the shared earnings
that were used to fund the Company's pension or retirement plans.
REOUEST FOR PRODUCTION NO. 12:
At page 23 of her testimony Ms. Grow presents Figure No. 6 showing "Net Electric Plant in
Service." That Figure has superimposed a line representing the Company's annual depreciation
expense. The two data points present a relatively smooth and steady increase over the decade
with one exception. In the 2021 - 2022 year the annual depreciation expense line takes a sharp
out-of-trend jump relative to the trend line for plant in service. Please explain the reason for this
disparate increase in annual depreciation expense relative to net plant in service.
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 2
REOUEST FOR PRODUCTION NO. 13:
Ms. Grow comments on a "recent downgrade by Moody's" at page 28 of her testimony. Please
provide copies of all communications between the Company and Moodys for the time period
beginning January 1,2022 through today.
REOUEST FOR PRODUCTION NO. 14:
Also on page 28 Ms. Grow references a'orecent note from Standard and Poor's ("S&P")
downgrading its liquidity assessment of the Company." Please provide copies of all
communications between the Company and Standard and Poor's for the time period beginning
January 1,2022 through today.
REOUEST FOR PRODUCTION NO. 15:
Please provide the current Moody's rating and the current Standard and Poor's liquidity
assessment for each of the seven peer utilities Ms. Grow identified on page 7 of her testimony.
REQUEST FOR PRODUCTION NO. 16:
At page 29 of her direct testimony Ms. Grow reports that, "immediately following the last GRC
[General Rate Case]" the company began increasing its equity ratio to achieve a 55 percent
equity ratio as recently as year end2022. Please identify the equity ratio the Commission
approved in the Company's last GRC. Please provide copies of all communications between the
Company and the Commission since its last GRC addressing the Company's equity ratio.
REQUEST FOR PRODUCTION NO. 17:
Please provide the current equity ratio for each of the seven peer utilities Ms. Grow identified on
page 7 of her testimony.
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC.E-23-I I PAGE 3
REOUEST FOR PRODUCTION NO. 18:
At page 32 of her testimony Ms. Grow is asked to identify the options available to customers to
"help them manage their energy costs." Has the Company conducted any analyses or studies as
to whether the adoption of its proposed Residential Price Modernization plan will have any
impact on its customers' ability to manage their energy costs? If so, please provide copies of all
such analyses, studies and supporting workpapers. Has the company conducted any analyses or
studies as to the ability of its customers to manage their energy usage if the proposed Residential
Price Modernization Plan is adopted? If so please provide copies of all such analyses, studies
and supporting workpapers.
REOIIEST F'OR PRODUCTION NO. 19:
At page 23 of her testimony Ms. Grow states, "In addition, environmental
mandates require the replacement or retrofitting of aging equipment with
technology that is often more expensive." For the time period since the conclusion
of the company's last general rate case, please identifu each "environmental
mandated" Ms. Grow is referencing and the associated "equipment" that such
mandate requires to be replaced andlor retrofìtted. Please quantifo the dollar
impact of each referenced instance of equipment that has been or is being replaced
due to each such "environmental mandate" Ms. Grow is referencing in her
testimony.
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 4
REOT]EST FOR PRODUCTION NO.20:
Does the Company consider carbon emissions reduction one such environmental
mandate that is referenced by Ms. Grow at page 23 of her testimony?
REOUEST FOR PRODUCTION NO.21:
Regardless as to whether the Company views carbon emissions reduction as a
mandate or not, please identift each of the Company's carbon emissions reduction
activities and quantifu the dollar amount spent by the Company on each such
project.
Dated this 14th day of July 2023
J # 319s
RICHARDSON ADAMS, PLLC
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23.II PAGE 5
I HEREBY CERTIFY that on the l4th day of July 2023, a true and comect copy of the within and
foregoing SECOND PRODUCTION REQUEST of the Industrial Customers of Idaho Power in
Case No. IPC-E-23-l I was served, by electronic copy only, to:
Lisa D, Nordstrom
Donovan Walker
Megan Goicoechea Allen
Regulatory Dockets
Idaho Power Company
lnordstrom@ idahopower.com
dwalker@.idahopower. com
mgoicoecheallen@ idahopower.com
dockets@ idahopower.com
Clean Energy Opportunities for Idaho
Courtney White
Mike Heckler
[e-mail]
[e-mail]
Kelsey Jae
Law for Conscious Leadership
[e-mail]
Idaho Conservation League
Marie Callaway Kellner
mkellner@idahoconservation. ors
Idaho Conservation League
Brad Heusinkveld
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
[e-mail]
lance@,aesisinsi ght. com
Commission Secretary
Idaho Public Utilities Commission
[e-mail]. gov
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
i an.noriyuki@Fuc. idaho. gov
Timothy Tatum
Connie Aschenbrenner
Matt Larking
ttatum@ idahopower. com
cashenbrenner@ idahopower. com
mlarkin@idahopower. com
City of Boise
Ed Jewell
Will Gehl
Darrell Early
[e-mail]
dearlvlDci
ej ewell@cityofboise. org
IdaHydro
C. Tom Arkoosh
tom.arkoosh@arkoosh. com
erin.cecil@arkoosh. com
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I I PAGE 6
Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Justin W. Jensen
Jim Swier
darueschhoff@hollandhart. com
tnel son@hollandhart. com
awj ensen@hollandhart. com
aclee@ho llandhart. com
elmo ser@holllandhart. com
[e-mail]
Federal Executive Agencies
U.S Department of Energy
Peter Meier
Dwight Etheridge
peter.meier@hq. doe. gov
detherid ge@exeterassociates. com
Richardson
rsB # 3195
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-23-I1 PACE 7
Northwest Energy Coalition
F. Diego Rivas
diego@nwener&v.org