20230802Staff 197-209 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL .ooIDAHOPUBLICUTILITIESCOMMISSION
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
Attorney for 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 )EIGHTH 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 TUESDAY AUGUST 23,2023.
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
telephone number of the record holder.
EIGHTH PRODUCTION REQUEST
TO IDAHO POWER 1 AUGUST 2,2023
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.197:Please provide a schedule showing the rate case processing
timeframes from filing until rates go into effect for the companies shown in Witness McKenzie's
Exhibit No.9.(i.e.,Idaho Power rate case time frame from filing until rates effective is seven
months).
REQUESTNO.198:For the companies included in McKenzie's Exhibit No.9,please
provide the date of each company's last rate case and the Return On Equity ("ROE")included in
that rate case.Please identify if that case was settled or not.
REQUESTNO.199:Please provide the details of how Value Line calculates the beta
provided in McKenzie's Exhibit No 13.
REQUESTNO.200:Please provide a schedule showing the number of employees at
each step of the Company's pay scale.Please include the years of service for each employee at
each step.
REQUESTNO.201:Please provide a schedule showing the number of bad debts
written off and the total amount of bad debt written off by month for the past five years.
REQUESTNO.202:Please provide a schedule showing the number of employees that
received a step increase by month for the past five years.Please also include the number of
employees that received a 2-step increase each month.
REQUESTNO.203:Please provide a list of services Idaho Power provides for IdaCorp
Financial.Please provide a schedule of expenses for those services and their location in this rate
case filing.
EIGHTH PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 2,2023
REQUESTNO.204:Please provide the costs for the Environmental,Social,
Governance ("ESG")steering committee and where they are in the rate case filing.
REQUESTNO.205:Please provide the Company's ESG scores and supporting
documentation from 2020 to present.
REQUESTNO.206:Please provide the Company's click rate on the internal phishing
tests from 2020 to present.
REQUESTNO.207:Regarding the Company's response to Production Request No.35,
Confidential Attachment 1,please provide all transactions,in Excel format,associated with each
project listed in the attached Confidential spreadsheet "Idaho Power Capital Project Sample".
REQUESTNO.208:Please provide a list of all vehicles purchased between 2015 and
2023,including the make,model,price,and what it is used for.Please explain how many
vehicles were retired and replaced,and how many are new purchases due to the growing
customer base.
REQUESTNO.209:Please provide all transactions and journal entries for the wildfire
mitigation deferral account in Excel format.Please include item name,brief description,cost
broken down by month and year since 2021 to date.
DATED at Boise,Idaho,this day of August 2023.
n Har e
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.1ldhkl prod req 8
EIGHTH PRODUCTION REQUEST
TO IDAHO POWER 3 AUGUST 2,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2nd DAY OF AUGUST 2023,
SERVED THE FOREGOING EIGHTH 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]
[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:kelsey kelseyiae.com 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:dreading mindspring.com
E-MAIL:[e-mail]
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 tom.arkoosh arkoosh.com
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.org
E-MAIL:[e-mail]
ejewell citvofboise.org
dearly citvofboise.org
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:
[e-mail]
PETER MEIER DWIGHT ETHERIDGE
US DEPT OF ENERGY EXETER ASSOCIATES
1000 INDEPENDENCE AVE SW 5565 STERRETT PLACE
WASHINGTON DC 20585 STE 310
E-MAIL:[e-mail] COLUMBIA MD 2l044
E-MAIL:detheridge exeterassociates.com
CERTIFICATE OF SERVICE
F.DIEGO RIVAS
NW ENERGY COALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:diego nwenergy.org
SECRETARY
CERTIFICATE OF SERVICE