20240716Staff 31-33 to IPC.pdf

RECEIVED
Tuesday, July 16, 2024 11:18:28 AM
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 ) FIFTH 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
TUESDAY,AUGUST 6, 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.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 16, 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. 31: Please provide the following information for the Oxbow Hatchery
project referenced by Direct Testimony of Eric Hackett. 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 any confidential documents not available to the public related to the
rebuild of the Oxbow fish hatchery, and"1980 Settlement Agreement"that dictates
the Company's obligation to operate the current fish hatchery.
b. If a Request for Proposal(s) ("RFP") or Request for Quote(s) ("RFQ")was submitted,
please provide the following information:
i. A copy of the RFP(s) or RFQ(s)that were submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the proposal(s);
iii. The short-list bidder scorecard(s); and
iv. A copy of the winning bid(s).
c. 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.
d. Please provide the following for the Baseline Construction Project Plan:
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
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 16, 2024

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.
e. 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. 32: Please provide the following documentation for the single vendor
platform project referenced by Colburn Direct at 28. 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;
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JULY 16, 2024

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. 33: Please provide the following data in Excel format for each
individual expense for the projects listed in the Confidential attachment labeled "Capital Project
Data Request January Through May 2024".
a. Invoice date;
b. Invoice number;
c. Invoice amount; and
d. Invoice description(services performed and/or material purchased, etc.).
DATED at Boise, Idaho, this 161h day of July 2024.
k�— U.
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#5.docx
FIFTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JULY 16, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF JULY 2024,
SERVED THE FOREGOING FIFTH 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: lnordstromLidahopower.com E-MAIL: ttatumLcoidahopower.com
dwalker,c idahopower.com caschenbrenner(aidahopower.com
mgoicoecheaallen c�idahopower.com mlarkinLidahopower.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 aegisinsight.com
E-MAIL: elo(cvechohawk.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: dreading Lixmindspring com
E-MAIL: peter'Lbrichardsonadams.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.nykiel)gmail.com E-MAIL:
heusinkveld Lctidahoconservation.org
PATRICIA JORDAN, S CRETARY
CERTIFICATE OF SERVICE