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HomeMy WebLinkAbout20240710Staff 17-30 to IPC.pdf RECEIVED Wednesday, July 10, 2024 4:32:14 PM IDAHO PUBLIC UTILITIES COMMISSION CHRIS BURDIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 IDAHO BAR NO. 9810 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07 INCREASE RATES FOR ELECTRIC ) SERVICE TO RECOVER COSTS ) ASSOCIATED WITH INCREMENTAL ) FOURTH PRODUCTION CAPITAL INVESTMENTS AND CERTAIN ) REQUEST OF THE ONGOING OPERATIONS AND ) COMMISSION STAFF MAINTENANCE EXPENSES ) TO IDAHO POWER COMPANY Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company") provide the following documents and information as soon as possible, but no later than WEDNESDAY,JULY 31, 2024. 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 telephone number of the record holder. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 JULY 10, 2024 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. REQUEST NO. 17: Please provide the following documentation for the 60 MW Franklin BESS project referenced by Hackett Direct at 8. If any of the information requested below cannot be provided or is not available,please explain why it is not available or cannot be provided. a. Please provide the approved Initial Project Plan including the following: i. Initial project scope; ii. Initial project budget; iii. Initial proposed schedule; and iv. Evidence the Initial Project Plan and budget was approved at the appropriate level. b. Please provide the Baseline Construction Project Plan including the following: i. Baseline project scope; ii. Baseline project budget broken down by Work-Breakdown Structure ("WBS"); iii. Baseline project schedule broken down by the WBS; iv. If the baseline construction project scope,budget, and/or schedule deviated from the Initial Project Plan,please explain the differences, explain the reason for the change, and provide evidence that the changes were approved at the appropriate level; V. Project status reports and action items; and vi. Contractor change orders. c. Please provide the following related to completion of the project: i. Baseline construction budget-to-actual comparison by WBS and by year; ii. Baseline construction schedule-to-actual comparison by WBS; iii. For any budget-to-actual cost overages by major WBS category that is over 5%, please explain the reason for the differences and provide evidence that the amount was approved at the appropriate level; and FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JULY 10, 2024 iv. Please explain any deviations in schedule from the baseline construction schedule. REQUEST NO. 18: Please provide the following documentation for the 36 MW Hemingway station BESS project referenced by Hackett Direct at 8. If any of the information requested below cannot be provided or is not available,please explain why it is not available or cannot be provided. a. Please provide the approved Initial Project Plan including the following: i. Initial project scope; ii. Initial project budget; iii. Initial proposed schedule; and iv. Evidence that the Initial Project Plan and budget were approved at the appropriate level. b. Please provide the Baseline Construction Project Plan including the following: i. Baseline project scope; ii. Baseline project budget broken down by WBS; Ili. Baseline project schedule broken down by WBS; iv. If the baseline construction project scope,budget, and/or schedule deviated from the Initial Project Plan,please explain the differences, explain the reason for the change, and provide evidence that the changes were approved at the appropriate level; V. Project status reports and action items; and vi. Contractor change orders. c. Please provide the following related to completion of the project: i. Baseline construction budget-to-actual comparison by WBS and by year; ii. Baseline construction schedule-to-actual comparison by WBS; iii. For any budget-to-actual cost overages by major WBS category that is over 5%, please explain the reason for the differences and provide evidence that the amount was approved at the appropriate level; and iv. Please explain any deviations in schedule from the baseline construction schedule. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JULY 10, 2024 REQUEST NO. 19: Please provide the following information for the 40 MW 2023 Peak Capacity Resource project referenced by Larkin Workpaper 3 at 11. Please include any available workpapers with formulas intact. If any of the information requested below cannot be provided or is not available, please explain why it is not available or cannot be provided. a. Please provide the approved Initial Project Plan including the following: i. Initial project scope; ii. Initial project budget; iii. Initial proposed schedule; and iv. Evidence that the Initial Project Plan and budget were approved at the appropriate level. b. Please provide the Baseline Construction Project Plan including the following: i. Baseline project scope; ii. Baseline project budget broken down by WBS; iii. Baseline project schedule broken down by WBS; iv. If the baseline construction project scope,budget, and/or schedule deviated from the Initial Project Plan,please explain the differences, explain the reason for the change, and provide evidence that the changes were approved at the appropriate level; V. Project status reports and action items; and vi. Contractor change orders. c. Please provide the following related to completion of the project: i. Baseline construction budget-to-actual comparison by WBS and by year; ii. Baseline construction schedule-to-actual comparison by WBS; iii. For any budget-to-actual cost overages by major WBS category that is over 5%, please explain the reason for the differences and provide evidence that the amount was approved at the appropriate level; and iv. Please explain any deviations in schedule from the baseline construction schedule. REQUEST NO. 20: Please provide the following information for the "Rebuild of Line 423"project referenced by Colburn Direct at 4. Please include any available workpapers with FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 JULY 10, 2024 formulas intact. If any of the information requested below cannot be provided or is not available, please explain why it is not available or cannot be provided. a. Please provide a detailed explanation for the need of the project including the analysis justifying the need; b. Please provide a list of all the potential alternatives the Company considered to fulfill the need and explain why the project was selected among the alternatives supported by the Company's economic analysis (costs and benefits) comparing them; c. If a Request for Proposal ("RFP") or Request for Quote ("RFQ") was submitted, please provide the following information: i. A copy of the RFP or RFQ that was submitted; ii. A detailed explanation of the selection process including the scorecard and list of the criteria used to select the project; iii. The short-list bidder scorecard; and iv. A copy of the winning bid. d. Please provide the approved Initial Project Plan including the following: i. Initial project scope; ii. Initial project budget; iii. Initial proposed schedule; and iv. Evidence that the Initial Project Plan and budget were approved at the appropriate level. e. Please provide the following for the Baseline Construction Project Plan including the following: i. Baseline project scope; ii. Baseline project budget broken down by WBS; iii. Baseline project schedule broken down by WBS; iv. If the baseline construction project scope,budget, and/or schedule deviated from the Initial Project Plan,please explain the differences, explain the reason for the change, and provide evidence that the changes were approved at the appropriate level; V. Project status reports and action items; and vi. Contractor change orders. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 JULY 10, 2024 f. Please provide the following related to completion of the project: i. Baseline construction budget-to-actual comparison by WBS and by year; ii. Baseline construction schedule-to-actual comparison by WBS; iii. For any budget-to-actual cost overages by major WBS category that is over 5%, please explain the reason for the differences and provide evidence that the amount was approved at the appropriate level; and iv. Please explain any deviations in schedule from the baseline construction schedule. REQUEST NO. 21: Please provide the following information for the "Rebuild of Line 902"project referenced by Colburn Direct at 7. Please include any available workpapers with formulas intact. If any of the information requested below cannot be provided or is not available, please explain why it is not available or cannot be provided. a. Please provide a detailed explanation for the need of the project including the analysis justifying the need; b. Please provide a list of all the potential alternatives the Company considered to fulfill the need and explain why the project was selected among the alternatives supported by the Company's economic analysis (costs and benefits) comparing them; c. If a RFP or RFQ was submitted,please provide the following information: i. A copy of the RFP or RFQ that was submitted; ii. A detailed explanation of the selection process including the scorecard and list of the criteria used to select the project; iii. The short-list bidder scorecard; and iv. A copy of the winning bid. d. Please provide the approved Initial Project Plan including the i. Initial project scope; ii. Initial project budget; iii. Initial proposed schedule; and iv. Evidence that the Initial Project Plan and budget were approved at the appropriate level. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 6 JULY 10, 2024 e. Please provide the following for the Baseline Construction Project Plan including the following: i. Baseline project scope; ii. Baseline project budget broken down by WBS; iii. Baseline project schedule broken down by WBS; iv. If the baseline construction project scope,budget, and/or schedule deviated from the Initial Project Plan,please explain the differences, explain the reason for the change, and provide evidence that the changes were approved at the appropriate level; V. Project status reports and action items; and vi. Contractor change orders. f. Please provide the following related to completion of the project: i. Baseline construction budget-to-actual comparison by WBS and by year; ii. Baseline construction schedule-to-actual comparison by WBS; iii. For any budget-to-actual cost overages by major WBS category that is over 5%, please explain the reason for the differences and provide evidence that the amount was approved at the appropriate level; and iv. Please explain any deviations in schedule from the baseline construction schedule. REQUEST NO. 22: Please provide the following information for the "Series Capacitor Bank Replacement"project referenced by Colburn Direct at 9. Please include any available workpapers with formulas intact. If any of the information requested below cannot be provided or is not available, please explain why it is not available or cannot be provided. a. Please provide a detailed explanation for the need of the project including the analysis justifying the need; b. Please provide a list of all the potential alternatives the Company considered to fulfill the need and explain why the project was selected among the alternatives supported by the Company's economic analysis (costs and benefits) comparing them; c. If a RFP or RFQ was submitted,please provide the following information: i. A copy of the RFP or RFQ that was submitted; FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 7 JULY 10, 2024 ii. A detailed explanation of the selection process including the scorecard and list of the criteria used to select the project; iii. The short-list bidder scorecard; and iv. A copy of the winning bid. d. Please provide the approved Initial Project Plan including the following: i. Initial project scope; ii. Initial project budget; iii. Initial proposed schedule; and iv. Evidence that the Initial Project Plan and budget were approved at the appropriate level. e. Please provide the following for the Baseline Construction Project Plan including the following: i. Baseline project scope; ii. Baseline project budget broken down by WBS; iii. Baseline project schedule broken down by WBS; iv. If the baseline construction project scope,budget, and/or schedule deviated from the Initial Project Plan,please explain the differences, explain the reason for the change, and provide evidence that the changes were approved at the appropriate level; V. Project status reports and action items; and vi. Contractor change orders. f. Please provide the following related to completion of the project: i. Baseline construction budget-to-actual comparison by WBS and by year; ii. Baseline construction schedule-to-actual comparison by WBS; iii. For any budget-to-actual cost overages by major WBS category that is over 5%, please explain the reason for the differences and provide evidence that the amount was approved at the appropriate level; and iv. Please explain any deviations in schedule from the baseline construction schedule. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 8 JULY 10, 2024 REQUEST NO. 23: Please provide the following information for the "Series Capacitor Bank Replacement"project referenced by Colburn Direct at 10. If any of the information requested below cannot be provided or is not available,please explain why it is not available or cannot be provided. a. Please provide justification, with necessary documentation(including but not limited to any communication or direct negotiations with the joint-owner PacifiCorp, etc.), for why the replacement project was deferred several times although it was identified in 2015; and b. Please provide necessary documentation and workpapers (with formulas intact) on any reliability issues the Company may have experienced (including but not limited to outages,power interruption, etc.) during 2015 —2023. Also provide necessary information on Company's actions to remedy those reliability issues during the same period. REQUEST NO. 24: Please provide the service level for the Customer Service Center by month for the year 2023 and YTD 2024. "Service Level"is the percentage of calls answered within a certain number of seconds, e.g., 80% of calls answered within 60 seconds. REQUEST NO. 25: Please provide the number of incoming calls handled by the Customer Service Center by month for the year 2023 and YTD 2024. REQUEST NO. 26: Please provide the number of abandoned calls to the Customer Service Center by month for the year 2023 and YTD 2024. "Abandoned calls" are calls that reach the Company's incoming telephone system, but the calling party terminates the call before speaking with a customer service representative. REQUEST NO. 27: Please provide the average speed of answer for the Customer Service Center by month for the year 2023 and YTD 2024. "Average speed of answer"is the interval (typically measured in seconds)between when a call reaches the Company's incoming telephone system and when the call is picked up by a customer service representative. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 9 JULY 10, 2024 REQUEST NO. 28: Please provide the average handling time for the Customer Service Center by month for the year 2023 and YTD 2024. "Average handling time" is the average amount of time (usually expressed in minutes) it takes for a customer service representative to talk with a customer plus and additional "off-line" time it takes to complete the transaction or fully resolve the customer's issue(s). REQUEST NO. 29: Please provide the first call resolution rate for the Customer Service Center by month for the year 2023 and YTD 2024. "First call resolution rate" is the percentage of calls where the transaction, inquiry, or complaint is resolved upon initial contact with the Company. REQUEST NO. 30: Please provide the average response time for email transactions for the Customer Service Center by month for the year 2023 and YTD 2024. "Average response time" is the average number of hours from receipt of an e-mail by the Company to sending a substantive response; auto-response acknowledgements do not count as a substantive response. DATED at Boise, Idaho, this 1 Oth day of July 2024. LA Chris Burdin Deputy Attorney General 1:\Utility\UMISC\PRDREQ\1PC-E-24-07 PR#4.docx FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 10 JULY 10, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS loth DAY OF JULY 2024, SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-07, BY E-MAILING A COPY THEREOF TO THE FOLLOWING: LISA D. NORDSTROM TIMOTHY TATUM DONOVAN E WALKER CONNIE ASCHENBRENNER MEGAN GOICOECHEA ALLEN MATT LARKIN IDAHO POWER COMPANY IDAHO POWER COMPANY PO BOX 70 PO BOX 70 BOISE ID 83707-0070 BOISE ID 83707-0070 E-MAIL: lnordstrom(a�idahopower.com E-MAIL: ttatumLcyidahopower.com dwalkerLctidahopower.com caschenbrennernidahopower.com mgoicoecheaallen c idahopower.com mlarkin gidahopower.com dockets(idahopower.com ERIC L OLSEN LANCE KAUFMAN PhD ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE PO BOX 6119 CORVALLIS OR 97330 POCATELLO ID 83205 E-MAIL: lance c ae isg insi h�t.com E-MAIL: eloCechohawk.com PETER J RICHARDSON DR DON READING RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY 515 N 27TH STREET EAGLE ID 83616 BOISE ID 83702 E-MAIL: dreadingLcymindspring.com E-MAIL: peter(arichardsonadams.com MATTHEW NYKIEL BRAD HEUSINKVELD ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE 710 N 6TH STREET 710 N 6TH STREET BOISE ID 83702 BOISE ID 83702 E-MAIL: matthew.nykielLcugmail.com E-MAIL: heusinkveldnidahoconsery ation.org PATRICIA JORDAN, ECRETARY CERTIFICATE OF SERVICE