20240710Staff 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
[phone]
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