20230905IPC to Staff Supplemental 189_192.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
September 5, 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 Supplemental
Response to the Seventh Production Request of the Commission Staff to Idaho Power
Company.
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.
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
RECEIVED
2023 SEPTEMBER 5, 2023 4:57PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 Attachment 1 in Response to Supplemental Response to Request No. 189
to Idaho Power Company’s Supplemental Response to the Seventh Production Request
of the Commission Staff dated September 5, 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 5th day of September, 2023.
LISA D. NORDSTROM
Counsel for Idaho Power Company
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH 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
SUPPLEMENTAL RESPONSE TO
THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Seventh Production Request of the Commission Staff (“Commission” or
“Staff”) dated July 31, 2023, herewith supplements the following information:
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 189: Please provide explanations for
Company "2022 Actual Adjustments (column E)," "Forecast Adjustments (column H)," or
"Annualizing Adjustment" (column K) in Exhibit 34 for the following accounts. Please
include calculations of adjustments in Excel Format with formulas intact.
a. Other (Line 444)- Please justify the 40% increase for the "Forecast Adjustment";
b. Miscellaneous Expenses (Line 484)- Please justify the increase of 481% for the
"Forecast Adjustment "and the increase of 43% for the "Annualizing Adjustment";
c. Overhead Lines (Line 522)- Please justify the increase of 35% for the "2022
Actual Adjustment";
d. Overhead Lines (Line 553)- Please justify the increase of 58% for the "2022
Actual Adjustment";
e. Uncollectible Accounts (Line 566)- Please justify the increase of 77% for the
"Forecast Adjustment";
f. Injuries and Damages (Line 590)- Please justify the increase of 81% for the "2022
Actual Adjustments"; and
g. Employee Pensions & Benefits- Idaho (Line 593)- Please justify the increase of
105% for the "Forecast Adjustment".
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 189:
After the filing of the Company’s initial response to this request, Staff of the Idaho
Public Utilities Commission requested that Idaho Power file a supplemental response with
more detail of what is included in Account 925000 Injuries and Damages 2022 year-end
actuals, and the 2022 Actual Adjustment for this account.
First, to clarify, the Code of Federal Regulations (“CFR”) Title 18, Chapter 1,
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
Subchapter C, Part 101 Uniform System of Accounts for Public Utilities defines Account
925000 as:
925 Injuries and Damages:
A. This account shall include the cost of insurance or reserve accruals to protect
the utility against injuries and damages claims of employees or others, losses of
such character not covered by insurance, and expenses incurred in settlement of
injuries and damages claims. For Major utilities, it shall also include the cost of
labor and related supplies and expenses incurred in injuries and damages
activities.
B. Reimbursements from insurance companies or others for expenses charged
hereto on account of injuries and damages and insurance dividends or refunds
shall be credited to this account.
Please refer to Confidential Attachment 1 - Supplemental Response to Staff’s
Request No. 189 for all amounts recorded in Account 925000 in 2022. The total of these
transactions ties to Line 21, Column 4 of Exhibit No. 22 provided with Company Witness
Ms. Paula Jeppsen’s testimony.
The 2022 Actual Adjustment to Account 925000 of $5,309,456 is related to the
2022 Operations and Maintenance Expense (“O&M”) adjustment for Wildfire Mitigation
Plan (“WMP”) expenses that were deferred, presented in Table 3, Account 925000, on
page 15 of Ms. Jeppsen’s Testimony. Please refer to Attachment 2 - Supplemental
Response to Staff’s Request No. 189 for WMP Account 925000 expenses that were
deferred in 2022. The total of these transactions tie to Line 21, Column 5 of Exhibit No.
22 provided with Company Witness Ms. Paula Jeppsen’s testimony.
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 192: Please provide a list of workshops and
expos, and the respected costs, the Company held in years 2018-2023. In your response,
please provide whether each workshop and expo are annual events, locations, and the
cost. Please provide an overview of how workshops and expos affect this case.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 192:
In the Company’s initial Response to Staff’s Request for Production No. 192, Idaho
Power committed to follow up with additional cost information for irrigation workshops for
2018 – 2022. This initial response included a dollar amount of $6,607.93 in expenses for
the 2023 workshop recorded to Account 908000. The Company also noted that this
account was unadjusted between 2022 actual data and the 2023 test year (i.e., actual
year-end 2022 data is what is reflected in the Company’s 2023 test year for this account).
After further review, Idaho Power has determined that there are no costs related
to irrigation workshops in the 2023 test year. While preparing this supplemental response
it was determined that because the primary purpose of the workshops was energy
efficiency, all costs in 2022 were recorded to the Energy Efficiency Rider (“Rider”) and
were therefore excluded from the 2023 test year. For the time period 2018 – 2023, the
only costs associated with irrigation workshops that were recorded to non-Rider O&M
were $28.75 in 2020 and $1,217.34 in 2019. Neither of these amounts impact the
Company’s 2023 rate case. Consequently, the amount of $6,607.93 provided in the
Company’s initial response to this request is not reflective of non-Rider O&M expense in
2023, as the non-Rider O&M expense for the 2023 irrigation workshop was $0.
The Company’s initial response also stated that no workshops occurred in 2020
and 2021 due to the COVID-19 pandemic. However, this statement was not correct as a
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 6
combination of in-person and virtual workshops were held. No costs associated with these
workshops are included in the Company’s 2023 test year.
The response to this Request is sponsored by Bo Hanchey, Vice President,
Customer Operations and Chief Safety Officer, Idaho Power Company.
DATED at Boise, Idaho, this 5th day of September 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 SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Supplemental Response to the Seventh
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
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Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
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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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IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 8
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616
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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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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 9
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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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
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 10
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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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