20230825Staff 268-276 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 )FOURTEENTH 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 throughits 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 FRIDAY SEPTEMBER 1,2023.1
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 telephonenumber of
I Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FOURTEENTH PRODUCTION REQUEST
TO IDAHO POWER 1 AUGUST 25,2023
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.268:Please respond to the followingregarding the Company's
response to Staff Production Request No.138.
a.If embedded transmission revenues are approved for true up in the PCA,please
confirm that the Company's proposed amount of $46,361,643 for "Transmission
Point-to-Point"revenues as shown in Cell G389 of Exhibit 35 is the amount to be
used as the base for true up..If different,please explain the difference with a
breakdown of each component,and where each component can be found in the
Company's workpapers or exhibits in this case;
b.Please explain how the value of $46,361,643was determined and provide
workpapers that calculate the amount with formula intact;
c.Please explain how the value of $48,333,338 in Cell F389 of Exhibit 35 was
determined and provide workpapers that calculate the amount with formula intact;
and
d.Please provide the costs of transmission that the Company stated would also need
to be included for true-up in the PCA.Please explain why each cost should be
included and provide where each component can be found in the Company's
workpapers or exhibits in this case.Please provide workpapers that calculate the
amount with formula intact.
REQUESTNO.269:Page 13 of Exhibit No.26 states "Account 537 was
increased by $471,796 above 2022 Base due to a 9.9 percent increase from the Idaho
Department of Fish and Game for the cost of hatchery operations."Please provide
supporting documentation includinginvoices,contracts,and other necessary information
to verify and calculate the 9.9 percent increase.
REQUESTNO.270:Please provide an Excel spreadsheet listing all expenses
booked into FERC Account 561-Load Dispatching in 2022.
FOURTEENTH PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 25,2023
REQUESTNO.271:The Company's response to Staff Production Request No.
139 (a)states that "[t]he Company reduced the AURORA-stated zonal price by the
weighted average wheeling rate in the model and the Company's loss rate of 3.6
percent."Please respond to the following:
a.Please explain how the weighted average wheeling rate in the model is
determined;and
b.Please explain why the Company's loss rate,instead of inter-zonal loss
rate,is used.
REQUESTNO.272:Brady's Workpaper No.4 shows that Transmission
Expenses are calculated as the product of the Company's three-yearAverage Wheeling
Rate ($/MWh)and the AURORA generated Market Purchase Volume (MWh).Please
respond to the following:
a.Please explain why the wheeling rate in the AURORA model,which
determined the AURORA generated Market Purchase Volume (MWh),is not
used;and
b.Please provide the Transmission Expenses that are calculated using the
wheeling rate in the AURORA model,instead of the Company's three-year
Average Wheeling Rate ($/MWh).
REQUESTNO.273:The Company's response to Staff Production Request No.
146(b)states that for DR programs,only estimated fixed incentives were included in the
net power expenses,and estimated variable incentives were not included in the net power
expenses.Please explain why.
REQUESTNO.274:Please explain whether the AURORA-calculated market
purchase expense (recorded in FERC Account 555)and surplus sales revenue (recorded
in FERC Account 447)net the expenses and revenues associated with wheeling,and
whether these expenses and revenues associated with wheeling are recorded in other
accounts.
FOURTEENTH PRODUCTION REQUEST
TO IDAHO POWER 3 AUGUST 25,2023
REQUESTNO.275:Please explain whether the base level of market purchase expense
contained in FERC Account 555 has already netted the expenses associated with wheeling.
REQUESTNO.276:In the example described in the Company's response to Staff
Production Request No.151,please explain why Zone A's purchase expense is not equal to Zone
B's surplus sales revenue.
DATED at Boise,Idaho,thi day of August 2023.
Har
Deputy Attorney General
i:umisc:prodreq/ipce23.11 prod req 14
FOURTEENTH PRODUCTION REQUEST
TO IDAHO POWER 4 AUGUST 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF AUGUST 2023,
SERVED THE FOREGOING FOURTEENTH 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:[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:[e-mail]
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:mkellner idahoconservation.org E-MAIL:
bheusinkveld idahoconservation.org
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 STEVE W CHRISS
NW ENERGY COALITION DIR ENERGY SERVICES
1101 8TH AVE WALMART INC
HELENA MT 59601 2608 SOUTHEAST J ST
E-MAIL:[e-mail] BENTONVILLE AR 72716
E-MAIL:[e-mail]
NORMAN M SEMANKO JUSTINA A CAVIGLIA
PARSONS BEHLE &LATIMER PARSONS BEHLE &LATIMER
800 W MAIN ST STE 1300 50 W LIBERTY ST STE 750
BOISE ID 83702 RENO NV 89502
E-MAIL:[e-mail] E-MAIL:jcaviglia parsonsbehle.com
SECRETARY
CERTIFICATE OF SERVICE