20230718Staff 115-134 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 )FIFTH PRODUCTION
IN THE STATE OF IDAHO AND FOR )REQUESTOF THE
ASSOCIATED REGULATORY )COMMISSION STAFF
ACCOUNTING TREATMENT )TO IDAHO POWER COMPANY
Staff of the Idaho Publ.ic 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 TUESDAY AUGUST 8,2023.
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
telephone number of the record holder.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER l JULY 18,2023
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.115:Please provide the Idaho Jurisdictional average net rate base for
electric service calculated using a December 31,2022,test year end.Please provide all
workpapers supporting the calculations in electronic format with all formulas intact and enabled.
REQUESTNO.116:Please update the Company's Idaho electric revenue requirement
models using a December 31,2022,test year end using average net rate base.Please provide all
workpapers used in the model in electronic format with all formulas intact and enabled.
REQUESTNO.117:Please provide an updated Base Net Power Expense using a
December 31,2022,test year end using average net rate base.Please provide all workpapers
used to determine Base Net Power Expense in electronic format with all formulas intact and
enabled.
REQUESTNO.118:Please provide updated Test Year Sales Forecast calculations
using a December 31,2022,test year end using average net rate base.Please provide all load
research and forecasting workpapers,includingweather normalization,used to determine the
Test Year Sales Forecast in electronic format with all formulas intact and enabled.
REQUESTNO.119:Please provide an updated Test Year Retail Sales Revenue
forecast using a December 31,2022,test year end using average net rate base.Please provide all
workpapers used to determine the test year retail sales revenue forecast in electronic format with
all formulas intact and enabled.
REQUESTNO.120:Please provide an updated Cost of Service Model using a
December 31,2022,test year end using average net rate base.Please provide all workpapers
used to determine Cost of Service Model in electronic format with all formulas intact and
enabled.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 18,2023
REQUESTNO.121:Regardingthe Company's response to Production Request No.5,
Confidential Attachment 1,please provide a description of why legal counsel was needed for
each circumstance in 2022.
REQUESTNO.122:Regarding the Company's response to Production Request No.5,
Confidential Attachment 2,please provide an explanation why legal counsel was needed for all
matters listed in the attached Confidential spreadsheet "Idaho Power Legal Sample"in 2022.
REQUESTNO.123:Regarding the Company's response to Production Request No.6,
Confidential Attachment F,please state the amount spent on maintenance and amount spent on
flights in 2022.Please also provide a log of individual flights,which includes the cost of each
flightand reason for each flight.
REQUESTNO.124:Please provide a breakdown of the costs of cloud seeding from
years 2017 to 2022.Please describe the methods used to facilitate cloud seeding.Please also
provide an analysis that outlines the benefits and reimbursements the Company and its customers
have received from cloud seeding.
REQUESTNO.125:Regarding the Company's response to Production Request No.6,
Attachment G,please provide the date of each transaction.
REQUESTNO.126:Regarding the Company's response to Production Request No.13,
Confidential Attachment,please provide jurisdictionalallocations of all expenses.
REQUESTNO.127:The Company states in response to Production Request No.15
that "additional advertisements are provided that do not have above the line charges."Please
identify which advertisements are above the line and which are below the line.
REQUESTNO.128:Please indicate which advertisements from the Company's
attachments to its response to Production Request No.15 correlate to each expense indicated the
FIFTH PRODUCTION REQUEST
TO IDAHO POWER 3 JULY 18,2023
Company's response to Production Request No.14,Confidential Attachment,on all applicable
expenses.
REQUESTNO.129:Regarding the Company's response to Production Request No.
16,Attachment 1,please provide jurisdictional allocations of all expenses.
REQUESTNO.130:Regarding the Company's response to Production Request No.21,
Attachment 1,please indicate which compensation categories are being sought for recovery.
REQUESTNO.131:Regarding the Company's response to Production Request No.21,
Attachment 1,please explain how allocation factors are determined.Please also provide
Jurisdictional allocations.
REQUESTNO.132:Regarding the Company's response to Production Request No.24,
with the General Wage Adjustment ("GWA")and every six months Merit Salary Increases,
("MSI"),are employees eligible for three periodic base salary increases per year?Please indicate
if there is a maximum percentage for GWA and MSI and explain how increase percentages are
determined.
REQUESTNO.133:Regarding the Company's response to Production Request No.25,
Confidential Attachment,please explain why the Company chooses to have a cliff vesting
schedule for the 401k plan that fully vests at one year of service.
REQUESTNO.134:Regarding the Company's response to Production Request No.32,
Confidential Attachment 1,please provide transaction level details for Company purchase cards
posted on the dates selected in the attached spreadsheet "Idaho Power Credit Card Sample"in
2022.This should include date,vendor names,dollar amount of each transaction,description of
purchases,and all other useful information.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER 4 JULY 18,2023
DATED at Boise,Idaho,this day of July 2023.
Deputy Atto ey General
Technical Staff: Travis Culbertson (115-120)
James Chandler (121-134)
i:umise:prodreq/ipce23.1ldhkl prod req 5
FIFTH PRODUCTION REQUEST
TO IDAHO POWER 5 JULY 18,2023
18th
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF JULY 2023,SERVEDTHEFOREGOINGFIFTHPRODUCTIONREQUESTOFTHECOMMISSION
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]
[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] ~
[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:[e-mail]
E-MAIL:[e-mail]
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27THST EAGLE ID 83616
BOISE ID 83702 E-MAIL:[e-mail] -
E-MAIL:peter richardsonadams.com -
CERTIFICATE OF SERVICE
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 HOLLAND &HART LLP
E-MAIL:[e-mail] 555 17TH ST STE 3200
DENVER CO 80202
E-MAIL:[e-mail] -
[e-mail] -
[e-mail] -
[e-mail] -
clmoser hollandhart.com '
TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
[e-mail]
erin.cecil arkoosh.com
ED JEWELL WIL GEHL
DARRELL EARLY ENERGY PROGRAM MANAGER
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S OFFICE PO BOX 500
PO BOX 500 BOISE ID 82701-0500
BOISE ID 83701-0500 E-MAIL:wgehl citvofboise.orgE-MAIL:[e-mail]
ejewell citvofboise.ore
dearly cityofboise.ore
MARIE CALLAWAY KELLNER BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:[e-mail] E-MAIL:
bheusinkveld idahoconservation.org
SECRETARY
CERTIFICATE OF SERVICE