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Home My WebLink About20230918IPC to IdaHydro 3.pdf LISA D. NORDSTROM Lead Counsel lnordstrom@idahopower.com September 18, 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 the Second Production Request of IdaHydro 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 to 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 Monday, September 18, 2023 4:26:58 PM IDAHO PUBLIC UTILITIES COMMISSION IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 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: (208) 388-5825 Facsimile: (208) 388-6936 lnordstrom@idahopower.com dwalker@idahopower.com mgoicoecheaallen@idahopower.com 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. ) ) ) ) ) ) ) ) CASE NO. IPC-E-23-11 IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to Idaho Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a IdaHydro Second Production Request to Idaho Power Company dated August 28, 2023, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 2 REQUEST FOR PRODUCTION NO. 3: In its Response to Request for Production No. 2, Idaho Power writes: Once these projects [Qualifying Facilities] are placed into service, they are deemed a part of Idaho Power’s plant the same any another plant that is non-customer funded and the cost of maintaining (or replacing) this equipment is paid for by all Idaho Power customers, with an offsetting revenue credit for the amounts collected through operations and maintenance charge assessed to QF interconnections. How is the cost of maintaining or replacing Idaho Power plant determined? How is this cost translated into the percentage operation and maintenance charges set out in Schedule 72? If different than the above, how is the cost of maintaining or replacing Schedule 72 interconnection determined? What, if anything, do customers pay for the cost of maintaining or replacing QF interconnections over and above the amounts collected through operations and maintenance charges assessed to QF interconnections? RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The cost of maintaining or replacing Idaho Power plant are based on actual costs incurred. The percentage operation and maintenance (“O&M”) charges set out in Schedule 72 were originally developed in Case No. IPC-E-90-20 and were based on the ratio of actual O&M expenses associated with distribution and transmission to actual distribution and transmission plant account balances. The ratio of O&M to plant for distribution and transmission were calculated as 0.7 percent and 0.4 percent, respectively. Attachments IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 3 1 and 2 to this request show the calculation of distribution and transmission rates, respectively. Those rates were then used as the basis for the 35-year inclining O&M rates on Schedule 72. The inclining O&M rate methodology initially developed by Commission Staff incorporates discount rates and inflation factors to more closely match recovery of O&M costs with the expected pattern they will be incurred, recognizing that 1) the amount of O&M required would be expected to be lower earlier in the life of the interconnection assets and increase over time and 2) that O&M costs are subject to inflation over time. Pages 4 and 5 of Attachment 3 to this request show the methodology used to develop the percentages set out on Schedule 72. The costs of maintaining or replacing Schedule 72 interconnection equipment is determined the same way as the cost of maintaining or replacing Idaho Power plant described above. As noted in the Company’s Response to IdaHydro Request No. 2, Idaho Power does not separately track actual costs incurred for operation and maintenance expenses on Qualifying Facilities (“QF”) interconnections. Once these projects are placed into service, they are deemed a part of Idaho Power’s plant the same as any other plant that is noncustomer funded and the cost of maintaining (or replacing) this equipment is paid for by all Idaho Power customers, with an offsetting revenue credit for the amounts collected through the operations and maintenance charge assessed to QF interconnections. Thus, the Company cannot determine on an annual basis what, if anything, customers pay for the cost of maintaining or replacing QF interconnections above the amounts collected through O&M charges assessed to QF interconnections. The response to this Request is sponsored by Mark Annis, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 4 DATED at Boise, Idaho, this 18th 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 RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 18th day of September 2023, I served a true and correct copy of Idaho Power Company’s Response to the Second Production Request of IdaHydro 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 Dayn.Hardie@puc.idaho.gov Chris.Burdin@puc.idaho.gov Clean Energy Opportunities for Idaho Kelsey Jae Law for Conscious Leadership 920 N. Clover Dr. Boise, ID 83703 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email Kelsey@kelseyjae.com Courtney White Mike Heckler Clean Energy Opportunities for Idaho 3778 Plantation River Drive, Suite 102 Boise, ID 83703 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email courtney@cleanenergyopportunities.com mike@cleanenergyopportunities.com Industrial Customers of Idaho Power Peter J. Richardson Richardson Adams, PLLC 515 N. 27th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter@richardsonadams.com IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 6 Dr. Don Reading 280 Silverwood Way Eagle, Idaho 83616 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email dreading@mindspring.com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, Idaho 83205 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email elo@echohawk.com Lance Kaufman, Ph.D. 2623 NW Bluebell Place Corvallis, OR 97330 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email lance@aegisinsight.com Micron Technology, Inc. Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen Holland & Hart, LLP 555 Seventeenth Street, Suite 3200 Denver, Colorado 80202 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com aclee@hollandhart.com clmoser@hollandhart.com Jim Swier Micron Technology, Inc. 8000 South Federal Way Boise, Idaho 83707 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email jswier@micron.com IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 7 City of Boise Ed Jewell Darrell Early Boise City Attorney’s Office 150 N. Capitol Blvd. Boise, ID 83701 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email ejewell@cityofboise.org dearly@cityofboise.org boca@cityofboise.org Wil Gehl Boise City Dept. of Public Works 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email wgehl@cityofboise.org Idaho Conservation League Marie Callaway Kellner Idaho Conservation League 710 N. 6th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email mkellner@idahoconservation.org Brad Heusinkveld Idaho Conservation League 710 N. 6th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email bheusinkveld@idahoconservation.org IdaHydro C. Tom Arkoosh Arkoosh Law Offices 913 W. River Street, Suite 450 P.O. Box 2900 Boise, Idaho 83701 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email tom.arkoosh@arkoosh.com erin.cecil@arkoosh.com IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 8 Federal Executive Agencies Peter Meier U.S. Department of Energy 1000 Independence Ave., S.W. Washington, DC 20585 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter.meier@hq.doe.gov Dwight Etheridge Exeter Associates 5565 Sterrett Place, Suite 310 Columbia, MD 21044 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email detheridge@exeterassociates.com NW Energy Coalition F. Diego Rivas 1101 8th Ave Helena, MT 59601 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email diego@nwenergy.org Walmart Inc. Norman M. Semanko Parsons Behle & Latimer 800 West Main Street, Suite 1300 Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email NSemanko@parsonsbehle.com Steve W. Chriss Director, Energy Services Walmart Inc. 2608 Southeast J Street Bentonville, Arkansas 72716 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email Stephen.Chriss@walmart.com IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 9 Walmart Inc. Justina A. Caviglia Parsons Behle & Latimer 50 West Liberty Street, Suite 750 Reno, NV 89502 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email jcaviglia@parsonsbehle.com Stacy Gust, Regulatory Administrative Assistant