20230807Staff 210-225 to IPC - Redacted.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL .;oIDAHOPUBLICUTILITIESCOMMISSION
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 )REDACTED NINTH
IN THE STATE OF IDAHO AND FOR )PRODUCTION REQUESTOF
ASSOCIATED REGULATORY )THE 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 MONDAY AUGUST 21,2023.1
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
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0312.
REDACTED NINTH PRODUCTION REQUEST
TO IDAHO POWER 1 AUGUST 7,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
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.210:Please outline the main use for the Hawk Substation and provide
costs to date.In your response,please include a list of asset(s),the cost of the asset(s),the costs
of additional work performed,completion date,and how much is included in the general rate
case.
REQUESTNO.211:For Micron's expansion and its new fabrication building,please
provide a list of projects that are needed to support them,the cost of the work to date,and where
it is included in the general rate case.Please include a list of projects/workorders that might
include,but are not limited to,substations,distribution lines,and transmission lines.
REQUESTNO.212:Please provide an update to the timeline for the new
distribution/inventorywarehouse that is located near the amity substation,and include when it
will be in-use and operational.Also include the costs to date and how much is included in the
general rate case.
REQUESTNO.213:Please describe why and who pays for the relocation of Company
facilities that may conflict with road construction.
REQUESTNO.214:Please provide the Company's justification for the need for the
Company to buy and pay for employee housing.In your response,please include the cost-
benefit analysis used to make this decision,the location of housing,the original cost of housing,
the depreciation rate,how many employees will benefit,and where the associated expenses are
located in the general rate case.
REQUESTNO.215:Regarding Company's response to Production Request No.60 -
Confidential Attachment 1,please explain if all insurance expenses provided in the Attachment
REDACTED NINTH PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 7,2023
are all wildfire-related.If not,please provide only wildfire-related insurance expenses in Excel
format by year and provide all invoices and supporting documentation for 2019 to date.
REQUESTNO.216:Regarding Company's response to Production Request No.60,
not all the invoices/documentation were provided.Please provide invoices/documentation for all
the expenses listed on Confidential Attachment 1,including all invoices/documentation from
a.Please explain what
mean,and where each are referenced in the invoices provided;and
b.If supporting documentation or invoices for the expenses mentioned above have
not been provided,please provide them.
REQUESTNO.217:Regarding the Company's response to Production Request No.64,
Confidential Attachment 1,please provide all transactions,invoices,contracts,and backup
documents,associated with each transaction in the attached Confidential spreadsheet "Idaho
Power Wildfire Transaction list."
REQUESTNO.218:In the Company's response to Production Request No.73,the
Company stated that "[t]he Company conducted a random sample and only performed audits on
15 percent of the work performed in wildfire risk zones.In 2023,the Company plans to
complete audits of 100 percent of vegetation work performed in wildfire risk zones."Please
explain why the Company is shifting from 15%vegetation audits in 2022 to 100%vegetation
audits in 2023.
REQUESTNO.219:As supplement to the Company's response to Production Request
No.67,please provide any documentation of each approved grant (i.e.,letter,award,email,etc.).
Please explain when the Company was notified that it had received each grant.
REQUESTNO.220:In the Company's response to Production Request No.67,
Attachment 2,the Company's application for an Office of Energy and Mineral Resource grant
request was $2.65 million for "Pruning"($2.5 million)and "Vegetation Intelligence"($150,000),
REDACTED NINTH PRODUCTION REQUEST
TO IDAHO POWER 3 AUGUST 7,2023
for a total project budget of $5.3 million.Please explain why the Company did not receive the
$2.5 million it had requested for additional pruning to be completed in 2022.
REQUESTNO.221:Please reconcile Idahojurisdictional Wildfire Mitigation Plan
("WMP")-relatedexpenses in 2022 of $21,003,203from Jeppsen Direct Testimony at 13 to the
2022 Idaho jurisdictionalWMP-related expenses listed in the "Confidential Attachment -
Response to Staff Request No.63".
REQUESTNO.222:Please explain the difference in the estimated incremental
expenses of vegetation management for 2023 to 2025 from Version 5 of the WMP to the
Company's response to Production Request No.103.
REQUESTNO.223:Please provide the yearly Capital and O&M expenses for each
notification system provided in "Attachment 2 -Response to Staff Request No.106".
REQUESTNO.224:For the Company's Enterprise Omni-Channel Notification System
("EONS")tool,please explain if the tool could replace the other alert notification systems.If not,
please explain why.If yes,please explain why the Company has not shifted to using EONS as
the main notification tool.
REQUESTNO.225:Version 4 and Version 5 of the Company's WMP estimated
incremental expenses for each component of the WMP in 2022 and 2023.Please explain why the
Company did not have any expenses for certain components of the WMP in "Confidential
Attachment -Response to Staff Request No.63".
DATED at Boise,Idaho,this day of August 2023.
Dayn Hardie
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.1Idhkl prod req 9
REDACTED NINTH PRODUCTION REQUEST
TO IDAHO POWER 4 AUGUST 7,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7nd DAY OF AUGUST 2023,
SERVED THE FOREGOING REDACTED NINTH 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] caschenbrenneráidahopower.com
[e-mail] mlarkin¾idahopower.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: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
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.org
E-MAIL:[e-mail]
[e-mail]
[e-mail]
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 21044
E-MAIL:detheridge exeterassociates.com
CERTIFICATE OF SERVICE
F.DIEGO RIVAS
NW ENERGY COALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE