The URL can be used to link to this page

Home My WebLink About20240730Staff 51-58 to IPC .pdf RECEIVED Tuesday, July 30, 2024 10.39.09 AM 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 ) REDACTED SEVENTH CAPITAL INVESTMENTS AND CERTAIN ) PRODUCTION REQUEST OF ONGOING OPERATIONS AND ) THE COMMISSION STAFF TO MAINTENANCE EXPENSES ) 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, 2024.1 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 1 Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff s attorney at(208)334-0314. SEVENTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 JULY 30, 2024 the person preparing the documents. Please also identify the name,job title, location, and telephone number of the record holder. In addition to the written copies provided as response to the requests, please provide all Excel spreadsheets and electronic files with formulae intact and enabled. REQUEST NO. 51: Please provide documentation and explain the accounting treatment applied to any fines or penalties assigned to the Company or representatives acting as the Company's agent during the course of Capital Project related activities impacting any Public Right-Of-Way. REQUEST NO. 52: Please describe if the Company has any criteria in place to determine if Contractors are ineligible to bid on or be awarded a contract with the Company. REQUEST NO. 53: Please provide the following documentation for the "Bathroom/Core Upgrade Each Floor At CHQ"project referenced in IPC-E-24-07 response to Production Request No. 5. The information returned should encompass the full life of the project. 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 Work-Breakdown Structure ("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 SEVENTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JULY 30, 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. 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. 54: In its response to Production Request No. 5, the Company identifies "Non-Criteria Based Equipment"with a cost of$287,746. Please provide the business case for this expenditure, any other options that were explored, their cost, and justification as to why this solution was chosen. REQUEST NO. 55: In its response to Production Request No. 5, the Company identifies "AVTEC Consoles At Dispatch"project with a cost of$171,995. The description provided did not provide clarity regarding the work that was done. Please provide the following and 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 description and documentation on the other solutions that were explored. b. As the 5-year contract was expiring, it was known that either a contract renewal or another solution was required to avoid a gap in support,please provide what steps are being put in place to avoid a similar situation that would require an expenditure of $150,000 in unbudgeted capital. SEVENTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JULY 30, 2024 c. The Business Need provided indicates that an upgrade of dispatcher workstations is planned for this year and that there are efficiencies in performing the work simultaneously. i. Please provide clarification if this was indeed completed as a single solution; and ii. Please provide the expected savings in the efficiencies mentioned on an annual basis. REQUEST NO. 56: In its response to Production Request No. 5, the Company identifies "CHQ-6 Conference Room Furniture"project with a cost of$153,419. The description provided did not provide clarity regarding the work that was done. Please provide the following and 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 explain what was done with existing furnishings. If the existing furnishings were resold, please specify for what amount; and b. Please explain why the conference room redecorating needs to be completed with the "Bathroom/Core Upgrade Each Floor At CHQ" as stated in the Business Need for this project. Please provide additional details of savings from completing this work simultaneously. REQUEST NO. 57: IPC-E-24-07 response to Production Request No. 5 identifies "Purchase 3 Destination Trlrs For Seasonal Wrkrs At HCC"with a cost of$254,075. Please provide the following and 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 business case for this expenditure, any other options that were explored, their cost, and justification as to why this solution was chosen; b. Does the Company charge rent to the seasonal workers? If so, please provide the total rent revenue; c. Please explain what is done with the trailers in the off-season; d. Please explain what "Park"the Company is referencing in the Business Need of the project; and SEVENTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 JULY 30, 2024 e. Please explain the roles and responsibilities of each of the seasonal workers at HCC referenced in the response. REQUEST NO. 58: Please provide the information requested as it pertains to the "GridMod Single Vendor Platform"project discussed in Company witness Colburn's 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 explain and reconcile the different in-service dates, and differences in the projects, if any, for the first phase of this project from the following information provided by the Company: i. In response to Production Request No. 35 in the 2023 Rate Case, Confidential Attachment I has an in-service date of- for ii. In response to Production Request No. 36 in the 2023 Rate Case, Confidential Attachment I has an in-service date of- for _; and iii. In this rate case, Colburn Direct at 30 identifies an in-service date of October 2024 for this project. b. Please provide the annual expenses related to the software vendors providing Energy Management Systems, Outage Management System and a Distribution Management System/Integrated Volt/VAR Control services for the past three years. c. Please provide the total estimated capital expense and annual O&M expense for the "GridMod Single Vendor Platform." Please provide supporting workpapers. d. Please provide the status of any funding that has been applied for or awarded through the Infrastructure Investment and Jobs Act or any other source to offset the cost of this project. e. Please provide any expected savings from this project. Please identify where the Company applied any savings in this rate case. £ Please explain how this new platform will integrate with the existing software systems used for wildfire mitigation. SEVENTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 JULY 30, 2024 DATED at Boise, Idaho, this 30''day of July 2024. kx,.�biA Chris Burdin Deputy Attorney General 1AUtility\UM ISCIPRDREQUK-E-24-07 PR#7 Redacted.docx SEVENTH PRODUCTION REQUEST TO IDAHO POWER COMPANY 6 JULY 30, 2024 CERTIFICATE OF SERV\I^CE I HEREBY CERTIFY THAT I HAVE THIS V DAY OF JULY 2024, SERVED THE FOREGOING REDACTED SEVENTH 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: lriordstrotnEtidahoL)ower.com E-MAIL: ttatttiYrc%idahopo"-er.com dwalkerd clahoRLLv r.ann casclienbrenner;c idahopow-er.coin mLYoicoecheaallen�t'i idahoPo,,4 er.cotti mlarkinl't idahoPo��er.c:om dockets��c idaho power.corn 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<<i-ae�isinsiL�ht.cotn E-MAIL: eto,decliolw%k.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-a mindspring.com E-MAIL: peter dricliardsonadam�.COIn 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: E-MAIL: heLtsinkveld(it.idahocotiser�ation.orc, PETER MEIER EMILY W MEDLYN US DEPT OF ENERGY US DEPT OF ENERGY 1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW WASHINGTON DC 20585 WASHINGTON DC 20585 E-MAIL: petcnmeicn�dz .doe.g.,ov E-MAIL: Emil�.rnedi�n c�.h .doe.�i?t CERTIFICATE OF SERVICE JIM SWIER AUSTIN RUESCHHOFF MICRON TECHNOLOGY INC THORVALD A NELSON 8000 S FEDERAL WAY AUSTIN W JENSEN BOISE ID 83707 KRISTINE A.K. ROACH E-MAIL: jN� ier'a.tnicronxom HOLLAND & HART LLP 555 17TH ST STE 3200 DENVER CO 80202 E-MAIL: darucSchhot1ft liollandhart.com tnelsowii hollandhart.com a\�iensen,,,':,hollandhart.com karoachiahollandhart.com acic6t hollandhart.corn mamcmillen;�i hollandha►-t.com ED JEWELL STEVEN HUBBLE DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS BOISE CITY ATTORNEY'S PO BOX 500 PO BOX 500 BOISE ID 83701-0500 BOISE ID 83701-0500 E-MAIL: huhhi�cr cit�otboise. E-MAIL: �:jc\a ell:acit,.otboisc.or4 hoisecitcattorttc� 41 city otbotse.org PATRICIA JORDAN, SECRETARY CERTIFICATE OF SERVICE