20230828IPC to Staff 214_216-217.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
August 28, 2023
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-23-11
Idaho Power Company’s General Rate Case
Dear Ms. Noriyuki:
Enclosed for electronic filing, please find Idaho Power Company’s Response to
Request Nos. 214, 216, and 217 of the Ninth Production Request of the Commission Staff
to Idaho Power Company. Responses to the other requests in this set were previously
filed on August 21, 2023. Although Production Request No. 216 referenced language
from a confidential document provided in response to Production Request No. 60, Idaho
Power believes the language in Production Request No. 216 should be designated as
public information.
Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.
The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided the parties that have executed the
Protective Agreement in this matter.
RECEIVED
2023 AUGUST 28, 2023 4:02PM
IDAHO PUBLIC
UTILITIES COMMISSION
Jan Noriyuki, Secretary
August 28, 2023
Page 2
If you have any questions about the attached filing, please do not hesitate to contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-11
In the Matter of the Application of Idaho Power Company for Authority to Increase
Its Rates and Charges for Electric Service to Its Customers In the State of Idaho
and For Associated Regulatory Accounting Treatment
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that some attachments in Response to Requests Nos. 216 and 217, to Idaho
Power Company’s Response to the Confidential Ninth Production Request of the
Commission Staff dated August 28, 2023, contain information that Idaho Power Company
and a third party claim are trade secrets, and/or business records of a private enterprise
required by law to be submitted to or inspected by a public agency, as described in Idaho
Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public
disclosure and exempt from public inspection, examination, or copying.
DATED this 28th day of August, 2023.
LISA D. NORDSTROM
Counsel for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
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CASE NO. IPC-E-23-11
IDAHO POWER COMPANY’S
RESPONSE TO THE
CONFIDENTIAL NINTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Confidential Ninth Production Request of the Commission Staff
(“Commission” or “Staff”) dated August 7, 2023, herewith submits the following
information:
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 214: The Company
provides housing to a certain number of employees whose primary work location is in
remote or rural areas. This ensures the necessary resources are available within close
proximity to support Idaho Power’s generation facilities and field operations. Of the 86
employees who live in Company-owned housing, 82 of those live in housing located near
the Company’s hydro generation fleet. Additionally, there are two properties in Hailey,
one in McCall, and one in New Plymouth.
Providing this housing is necessary because there is simply no housing available
within a reasonable distance given the rugged and/or remote locations where Idaho
Power’s hydro facilities are located, and employees are required to live within one hour
of these remote locations. Hydro power is Idaho Power’s lowest-cost resource and the
primary source of baseload power necessary to serve its customers and having
employees within a short distance to these critical power plants benefits customers.
Employees living in Company-owned housing near Idaho Power’s hydro facilities are
required to pay income tax on the fair-market rental value of the home. Idaho Power
currently provides Company-owned housing to 43 employees in the western power plant
region and 39 in the southern/eastern power plant region.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 3
In addition to the housing located near the hydro plants, a limited amount of
housing is provided due to the inadequate inventory and extremely high cost of housing
in the resort communities of Hailey and McCall. To serve customers in these areas, it is
necessary to have sufficient staff within a reasonable distance to maintain the system and
restore power in a timely manner when there are outages. The houses are generally used
on a temporary basis by employees who relocate into the area while they get established
and are able to rent or purchase a home. Beyond the high cost of housing, the inventory
is extremely limited so it can be a significant amount of time for a suitable property to
become available.
Employees living in company-owned housing in resort communities on a
temporary or transitional (up to one year) basis are required to pay income tax on the fair-
market rental value of the home. If an employee remains in company-owned housing
beyond one-year, they are required to pay the full fair-market rent value on a monthly
basis and are no longer taxed on the rental value. There was $13,049 in rent recorded in
2022 to account 454. Idaho Power currently provides company-owned housing to two
employees in Hailey and one employee in McCall.
As housing has become more challenging in the Company’s service area, the
Company purchased a property in New Plymouth to utilize as a transitional space when
bringing in necessary talent from outside the area. This property is meant to be a
temporary option when a highly skilled employee is hired and needs to relocate but is
unable to secure housing within a reasonable timeframe. This helps the Company ensure
the necessary resources are available to serve customers. Idaho Power currently
provides company-owned housing to one employee in New Plymouth.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 4
Attachment 1 – Response to Staff Request No. 214 provides a list of Company-
owned housing including the location of housing.
Please refer to Attachment 2 – Response to Staff Request No. 214 for historical
cost and depreciation rate information for employee housing. Employee housing assets
are included with other Structures and Improvement assets associated with the related
Hydro Production facilities (within plant account 331 Structures and Improvements) or
Line Operations (within plant account 390 Structures and Improvements) as applicable.
Employee housing is not individually identifiable within Idaho Power’s plant records due
to the group asset nature and structure of these plant accounts. The Hydro Plant Facility
information presented in Attachment 2 was gathered by pulling asset cost data associated
with our “OP VILLAGE” property units within the 331 plant account and then summarized
by location.
The table below shows the 2022 actual maintenance expenses associated with
employee housing.
Year Labor Materials Purchased Services Other Expenses Total
2022 214,651.46 78,262.16 195,960.05 37,077.09 525,950.76
The original cost of employee housing is recorded to Account 101 Electric Plant in
Service, accumulated depreciation associated with employee housing is recorded in
Account 108 Accumulated Provision for Depreciation, depreciation expense associated
with employee housing is recorded in Account 403 Depreciation Expense and
maintenance expenses associated with employee housing are recorded in O&M Account
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 5
920 A&G Salaries, Account 921 A&G Office Supplies & Expenses and Account 935 Mnt.
A&G General Plant.
The response to this Request is sponsored by Sarah Griffin, V.P. Human
Resources, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 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 Higgins & Rutledge Insurance, Saif
Corporation, and Ceridian Tax Service.
a. Please explain what "ValmyMonthly","Boardman Monthly"and "Bridger Prop
& Gen Liab" 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 216:
a. Idaho Power is a minority partner in the Valmy, Bridger, and Boardman plants.
Idaho Power is responsible for paying a portion of the costs to operate each plant which
includes the cost of insurance. The transactions described as “ValmyMonthly”,
“Boardman Monthly”, and “Bridger Prop & Gen Liab” are Idaho Power’s portion of the
insurance expenses associated with each plant.
b. For Higgins & Rutledge Insurance and Saif Corporation, the requested invoices
are provided in Confidential Attachment 1 – Response to Staff Request 216.
Ceridian Tax Service transactions are related to payroll taxes. Specifically, the
transactions in Request No. 60 are related to the Oregon Workers’ Benefit Fund
(“WBF”) which is a mandatory tax assessment that funds return-to-work programs for
Oregon workers who are permanently and totally disabled. The rate for 2023 is 2.2
cents per hour worked (only for hours worked in Oregon). This is a small portion of the
overall calculation for payroll tax which is done each employee pay period which is
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 7
every two weeks. It may be worth noting, these costs have declined from $2,290 in
2019 to $1,952 in 2023. There are 119 Ceridian Tax Service transactions in the data
set provided in Production Request No. 60. The average cost of the Ceridian
transactions is $75.14. Due to the nature of these transactions and the small average
cost of each transaction, the Company has provided a support document for one of
these transactions in Attachment 2 – Response to Staff Request 216.
c. The documentation for the “ValmyMonthly”, “Boardman Monthly”, and “Bridger
Prop & Gen Liab” is voluminous, and Idaho Power must work with its operating
partners at each plant to retrieve these invoices. Therefore, Idaho Power requested
that Staff select a sample for which Idaho Power will provide the requested
documentation. Staff provided their sample selection on Friday, August 18, 2023, and
Idaho Power will supplement this response when it receives the invoices from the plant
operator.
It should be noted that not all of the transactions provided in Idaho Power’s
Confidential Attachment 1 - Response to Staff Request No. 60 are invoices. The
transactions that don’t have an associated invoice represent the amortization of
prepaids where the invoice is paid in advance and the expense is amortized in the
period that receives the benefit. Please see Attachment 3 – Response to Staff
Request 216 that provides the supporting detail for the non-plant operator transactions
selected in the Staff sample provided on August 18, 2023. Note the transaction
description 2020 AEGIS MMBR LLTY CR is a member credit from the insurance
company and was originally deposited in IDACORP’s bank account and was moved
over to IPC, which is this is an intercompany transaction.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 8
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 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."
RESPONSE TO REQUEST FOR PRODUCTION NO. 217: Please see
Attachment 1 – Response to Staff Request No. 217 which is the Confidential spreadsheet
“Idaho Power Wildfire Transaction List” with notes added for clarity for the supporting
transaction information provided in Attachment 2 – Response to Staff Request No. 217.
Please note that many of the supporting invoices are allocated to multiple accounts. For
example, a tree trimming invoice might be associated with work for a transmission line
and work for a distribution line and as a result the invoice would be allocated to separate
FERC accounts. Therefore, to tie a specific transaction to the supporting invoice Idaho
Power provided support for the allocation figures.
In addition, there were multiple transactions related to employee labor charges.
These charges are the result of employees charging hours directly to these work orders.
Additional notes are included in Attachment 1 to help explain the labor charges. Similarly,
there are vehicle charges associated with activity in these accounts based on mileage or
hours used on a project or activity.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 10
DATED at Boise, Idaho, this 28th day of August 2023.
LISA D. NORDSTROM
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 11
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of August 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Confidential Ninth Production
Request of the Commission Staff to Idaho Power Company upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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U.S. Mail
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FAX
FTP Site
X Email [e-mail]
Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
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FTP Site
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[e-mail]
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Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
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FTP Site
X Email [e-mail]
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 12
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616
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FAX
FTP Site
X Email [e-mail]
Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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[e-mail]
[e-mail]
[e-mail]
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 13
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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[e-mail]
IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701
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Federal Executive Agencies
Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL NINTH PRODUCTION REQUEST
OF THE COMMISSION STAFF - 14
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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U.S. Mail
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FTP Site
X Email [e-mail]
NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
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Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
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Stacy Gust, Regulatory Administrative
Assistant