20230725Staff 1-13 to IPC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10221
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 THE OF ROCKY )MOUNTAIN POWER'S APPLICATION FOR )CASE NO.PAC-E-23-16
A DEFERRED ACCOUNTING ORDER )REGARDING WILDFIRE CLAIMS )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy Attorney General,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY AUGUST 15,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementary responses,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 telephone number of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 25,2023
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.1:Please provide the Company's current Wildfire Mitigation Plan
("WMP")and any previous iterations of the WMP.
REQUESTNO.2:Please explain if the Company filed in other states for a similar
deferral regarding wildfire claims.
a.If so,please identify which state(s)and provide the case number(s)for each filing;
and
b.If not,why not.
REQUESTNO.3:Please explain how the Company will book expenses for its
requested deferral (i.e.,Multi-State Process inter-jurisdictionalcost allocation methodology).
REQUESTNO.4:For each fire that the Company is accused of negligentlycausing,
please answer the following:
a.Please explain in detail the Company infrastructure associated with the cause of
the fire (i.e.,transmission or distribution line,conductor associated with
distribution lines,substation,etc.).For any associated infrastructure for
transmission or distribution lines,please provide a list detailing the name of the
line,size of the line,and the impact of the line on the start of the fire;and
b.Please provide a map displaying the location of the start of the fire and the
Company's infrastructure near the fire start area.
REQUESTNO.5:Please provide all lawsuits pending against the Company due to the
Oregon September 2020 wildfires,please include the following:
a.Brief description of the case;
b.Which fire the lawsuit is associated with;
c.Case No;
d.County filed in;
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 25,2023
e.Name of parties;
f.Case caption;
g.Date filed;and
h.Any other relevant information.
REQUESTNO.6:Please provide all concluded lawsuits against the Company due to
the Oregon September 2020 wildfires (includingthose resolved by settlement,final judgment,or
otherwise),please include the following:
a.Brief description of the case;
b.Which fire the lawsuit is associated with;
c.Case No;
d.County filed in;
e.Name of parties;
f.Case caption;
g.Date filed;and
h.Any other relevant information.
REQUESTNO.7:Please provide all known potential lawsuits against the Company due
to the Oregon September 2020 wildfires and include all known information about the potential
litigationincludingthe associated fire.
REQUESTNO.8:Please provide a supporting worksheet that details each cost
associated with the Oregon September 2020 wildfire lawsuits to date.Please include item name,
brief description,actual spend,and which lawsuit each item is for,and date booked.
REQUESTNO.9:Please explain if the Company's wildfire insurance is expected to
cover any of the costs associated with the wildfire lawsuits and the expected coverage from the
insurance.Please explain why or why not.
REQUESTNO.10:The Company states that "[t]he costs identified in this application
would account for and track the third-partyclaims that may exceed the Company's insurance
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 25,2023
coverage currentlyin rates associated with the outcomes of this litigation due to wildfires that
occurred in September 2020."Application at 2-3.Please answer the following:
a.Please provide the current amount of insurance coverage in rates by policy year
from 2019 to date;and
b.Please provide the amount that exceeds the insurance coverage in rates by policy
year from 2019 to date.
REQUESTNO.11:Please explain how the Company will update the Commission
during this case with any new information and potential impacts to the Company followingthe
outcomes of lawsuits against the Company related to the Oregon September 2020 wildfires.
REQUESTNO.12:Please outline any contingent liabilities recorded to the financial
statements regarding each wildfire.
REQUESTNO.13:According to the Company's 2023 Oregon WMP,Page 6,the first
Oregon WMP was filed on Dec 30,2021,and it became effective on April 28,2022.
a.Please explain what the Company had in place,such as vegetation management
procedures,operational procedures,strategies,plans,policies,etc.that could
potentiallymitigate hazards due to wildfire prior to filing the first Oregon WMP.
b.Please provide copies of all documentation relative to the above that was in effect
starting in 2019 through 2021.
DATED at Boise,Idaho,this ay of July2023.
Adam Triplett
Deputy AttorneyGeneral
i:umise:prodreq/pace23.16kljesp prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF JULY 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-
23-16,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOE DALLAS
CARLA SCARSELLA ROCKY MOUNTAIN POWER
ROCKY MOUNTAIN POWER 825 NE MULTNOMAH ST
1407 WEST NORTH TEMPLE STE 330 STE 2000
SALT LAKE CITY UT 84116 PORTLAND OR 97232
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE