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Home My WebLink About20231003IPC to IdaHydro 4-8.pdf LISA D. NORDSTROM Lead Counsel lnordstrom@idahopower.com October 3, 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 Third 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 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:cd Enclosures RECEIVED 2023 OCTOBER 3, 2023 4:41PM 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 the attachment to Response to Request No. 4 and No. 8 to Idaho Power Company’s Response to the Third Production Request of IdaHydro to Idaho Power Company dated October 3, 2023, may contain information that may be a confidential trade secret of a third party 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 Tuesday, October 3, 2023. LISA D. NORDSTROM Counsel for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE THIRD 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 THIRD 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 Third Production Request to Idaho Power Company dated September 12, 2023, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 2 REQUEST FOR PRODUCTION NO. 4: For each of the projects named in Idaho Power’s Response to Request for Production No. 1, please provide the interconnect investment amount for each project that Idaho Power uses to calculate each project’s share of operation and maintenance (“O&M”). RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the Confidential Excel file “Attachment – Response to IdaHydro Request No. 4 and No. 8”. The response to this Request is sponsored by Paula Jeppsen, Forecasting and Planning Director, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 3 REQUEST FOR PRODUCTION NO. 5: Is a Qualifying Facility’s (“QF”) plant interconnection investment subtracted from the entire system-wide plant costs of Idaho Power when calculating O&M charged to other plants other than QFs? RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Idaho Power’s costs of operating and maintaining its distribution and transmission system are not allocated to generation plants. The response to this Request is sponsored by Paula Jeppsen, Forecasting and Planning Director, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 4 REQUEST FOR PRODUCTION NO. 6: What are the impediments, if any, Idaho Power alleges would prevent Idaho Power from charging QFs for O&M on QF interconnections for actual costs of O&M as they are incurred? RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Idaho Power is required to follow Commission orders and approved tariff schedules. Idaho Power charges the O&M fees authorized and required by Commission-approved Schedule 72. Charging actual O&M costs for QF projects would mean that an entirely separate system of work order preparation and billing would have to be established just for QF projects, which is currently at approximately 135 projects. Idaho Power believes that such a requirement is both unreasonable and would result in unnecessary incremental costs. The present system of charging a percentage of construction costs reasonably approximates Idaho Power’s O&M costs, provides the QF with a high level of predictability as to what their O&M costs will be over the life of the project, and reasonably ensures that QF-related O&M costs are not shifted to retail customers. The response to this Request is sponsored by Paula Jeppsen, Forecasting and Planning Director, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 5 REQUEST FOR PRODUCTION NO. 7: What is the total dollar amount of the construction cost and transfer cost for each QF that Idaho Power uses as a base cost for its monthly O&M charges? RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Please see the Company’s response to Request for Production No. 4. The construction and transfer cost for each QF is identified as the Initial Investment in the referenced response. The response to this Request is sponsored by Paula Jeppsen, Forecasting and Planning Director, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 6 REQUEST FOR PRODUCTION NO. 8: For each of the operating years 2017, 2018, 2019, 2020, 2021 and 2022, what was the amount of the monthly O&M charges billed by Idaho Power to each of the QFs listed in Idaho Power’s Response to Request for Production No. 1 for the operating year beginning in each calendar year? RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Please see the Confidential Excel file “Attachment – Response to IdaHydro Request No. 4 and No.8”. The response to this Request is sponsored by Paula Jeppsen, Forecasting and Planning Director, Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 7 DATED at Boise, Idaho, this 3rd day of October 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 THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 3rd day of October 2023, I served a true and correct copy of Idaho Power Company’s Response to the Third 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 THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 9 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 THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 10 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 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 IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF IDAHYDRO TO IDAHO POWER COMPANY - 11 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 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 Christy Davenport Legal Administrative Assistant