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HomeMy WebLinkAbout20240731IPC to Staff 17-30.pdf 0-10AM POWER. LISA D. NORDSTROM RECEIVED Lead Counsel Wednesday, July 31, 2024 InordstromCaDidahopower.com IDAHO PUBLIC UTILITIES COMMISSION July 31, 2024 VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Response to the Fourth Production Request of the Commission Staff to Idaho Power Company. Due to the collectively voluminous confidential and non-confidential information provided in response to data requests in this case, the Company is posting the attachments to these requests to the secure FTP site to allow parties to view the requested information remotely unless otherwise noted in the response. Because certain attachments contain confidential information, the FTP site is divided between confidential and non-confidential information. The login information for the non-confidential portion of the FTP site has been provided to all parties that have intervened to date. The login information for the confidential portion of the FTP site will be provided to the parties that execute the Protective Agreement in this matter. Given the significant time and resources required to individually label each confidential document contained in the 390 MB of confidential attachments, Idaho Power has instead marked the entirety of the contents contained within Production Response Nos. 17(b) Attachment 3, 18(b) Attachment 3, 19(b) Attachment 4, 19(b) Attachment 5, 20(c) Attachment 7, 20(c) Attachment 8, 20(c) Attachment 9, 20(c) Attachment 10, 20(c) Attachment 12, 20(c) Attachment 13, 20(c) Attachment 14, 20(c) Attachment 15, 20(c) Attachment 16, 20(e) Attachment 4, 21(c) Attachment 4, 21(c) Attachment 5, 21(c) Attachment 6, 21(c) Attachment 7, 21(e) Attachment 4, 22(c) Attachment 7, 22(c) Attachment 8, 22(c) Attachment 9, 22(c) Attachment 10, 22(c) Attachment 11, and 22(e) Commission Secretary Idaho Public Utilities Commission July 31, 2024 Page 2 Attachment 5, confidential by designating the Attachment folder and individual file name as "CONFIDENTIAL". If you have any questions about the attached filing, please do not hesitate to contact me. Very truly yours, S. hen., Lisa D. Nordstrom LDN:sg Enclosures CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-24-07 Idaho Power Company's Application for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that some of the attachments to Request Nos. 17, 18, 19, 20, 21, 22, and 23 to Idaho Power Company's Response to the Fourth Production Request of the Commission Staff dated July 31, 2024, contain information that Idaho Power Company and/or a third party claim are trade secrets, business records of a private enterprise required by law to be submitted to or inspected by a public agency, and/or public records exempt from disclosure by state or federal law (material nonpublic information under U.S. Securities and Exchange Commission Regulation FD) as described in Idaho Code § 74-101, et seq., and/or § 48-801 , et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 31st day of July 2024. LISA D. NORDSTROM Attorney for Idaho Power Company LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(a)_idahopower.com dwalker idahopower.com mgoicoecheaallen(o)_idahopower.com Attorneys for Idaho Power Company 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 ) IDAHO POWER COMPANY'S ASSOCIATED WITH INCREMENTAL ) RESPONSE TO THE FOURTH CAPITAL INVESTMENTS AND ) PRODUCTION REQUEST OF THE CERTAIN ONGOING OPERATIONS ) COMMISSION STAFF TO IDAHO AND MAINTENANCE EXPENSES. ) POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Fourth Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated July 10, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 1 REQUEST FOR PRODUCTION 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; IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 2 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 17: a. Please note, the Company's ownership of the 60 megawatt (WW") Franklin Battery Energy Storage System ("BESS") was obtained through a Build Transfer Agreement ("BTA") with Duke Energy Solar ("Duke"), which included the purchase of the BESS, co-located with the Franklin Solar 100 MW solar photovoltaic ("PV") facility. The BTA provides for the transfer to Idaho Power from Duke Energy Solar of 100 percent of the equity interests in the Franklin BESS once mechanical completion is reached. Because Idaho Power is not constructing the project, the Company did not develop the project plan. However, the Build Transfer Agreement dated as of January 20, 2023, by and between Idaho Power Company and Duke Energy Renewables Solar, LLC, ("Franklin BESS BTA"), provided as Response to Request for Production No. 17(a) — Confidential Attachment 1, provides many of the items typically discussed in a project plan. i. Please see Appendix A, Section 3 of the Franklin BESS BTA for the scope of work provided as Response to Request for Production No. 17(a) — Confidential Attachment 1. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 3 ii. Please see Response to Request for Production No. 17(a) — Confidential Attachment 2 for the Budget Update — Authorized to Spend spreadsheet that identifies the original approved budget amount of$125 million. iii. Please see Article 10 and Appendix B of the Franklin BESS BTA for the preliminary project schedule. iv. Capital projects begin with the creation of a capital budget ID ("BID"). Then Idaho Power utilizes several approval processes throughout the life cycle of a project. First, employees and leaders evaluate project requests and establish a general conceptual level scope, estimate, and schedule incorporating feedback from project sponsors, subject matter experts, and leadership. The project requests are then evaluated amongst the many requests each year and ultimately prioritized and approved through the annual capital budget process. As part of that process, managers submit capital project proposals for senior management review. Then capital projects are reviewed and approved by the executive management team. Finally, the capital budget is then reviewed and approved by the Idaho Power Board of Directors. Once a project is approved, a work order ("WO") can then be created. A WO is created in Asset Suite (an enterprise resource planning tool) with required fields such as WO type, associated BID, capital indicator, location, accounting string, project estimate, property units. Then the WO is submitted for review and approval in Asset Suite, routing to the appropriate leader based on designated approval thresholds tied to the project estimate. Once approved, WO information is transferred to PeopleSoft Projects, the Company's financial IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-4 accounting software. Costs can then accumulate on WOs. Once the resulting asset can be used, the WO is placed in-service. BIDs may have a one-to-one association with a project (one BID to one project/WO) or may have a one-to-many association (one BID to many projects/WOs). Some BIDs are used to capture costs associated with a category of capital spend rather than a specific project and are estimated based on historic trends and growth projections. The BIDs are used to budget for and accumulate costs associated either with a specific project or category of capital spend. Throughout the year, projects are evaluated and re-forecasted as necessary to increase or reduce forecasted spend during the remaining life of the project. However, these updated forecasts are not retroactively used to adjust the approved budget for that year, the original approved budget for that year stays as originally approved. Idaho Power monitors its capital budget monthly through variance analysis reporting and quarterly through budget update analysis and reporting. Additionally, the majority of capital spend is managed within the Planning, Engineering, and Construction business unit which continuously manages and scrutinizes changes in scope, budget, or schedule on a monthly basis through MS Project Server scheduling software. These approvals happen in real-time based on the overall portfolio limits and are approved or denied. The changes, as appropriate, are documented by revising the scope, design drawings, construction specifications, and other pertinent documents and the budget and schedule are updated in MS Project related to forward action items that IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 5 overwrite previous plans. Baseline schedule comparisons to actual schedule delivery are not compared due to the ever-changing landscape of the entire portfolio of capital projects. Rather, projects are managed in real-time, and schedules are regularly monitored in comparison to the entire portfolio of projects to manage timeline and execution strategy, in conjunction with all other capital project needs. Project schedules are updated at least monthly for resource leaders to evaluate planned work across the matrixed organization. Variances in budget forecasts are also regularly evaluated and monitored within the overall portfolio of projects. The creation of the BID FRBS230001 for the 60 MW Franklin BESS and corresponding original approved budget reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet, is evidence of approval of the initial budget. b. See part (a) above. Because Idaho Power is acquiring the 60 MW Franklin BESS from Duke upon mechanical completion, there are no additional project plans. i. Not applicable. The project scope did not change from what was first identified in the Franklin BESS BSA. ii. As explained in part (a)(iv), the 60 MW Franklin BESS project is continuously managed and scrutinized on a monthly basis through MS Project Server scheduling software. Any changes in scope, budget, or schedule, are approved in real-time based on the overall portfolio limits. The changes, as appropriate, are documented by revising the scope, design drawings, construction IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 6 specifications, and other pertinent documents and the budget and schedule are updated in MS Project related to forward action items that overwrite previous plans. Therefore, the only WBS the Company can provide for the project is reflective of the most recent budget and schedule. Please see the Response to Request for Production No. 17(b) — Confidential Attachment 1 for the 60 MW Franklin BESS project WBS. iii. See part (b)(ii). iv. Please see Appendix B of the Amendment to Build Transfer Agreement, provided as the Response to Request for Production No. 17(b) — Confidential Attachment 2, for the project schedule update amended as of April 26, 2023. The baseline construction project scope and budget have not changed significantly, but some schedule changes occurred, as detailed in part (c)(iv) below. v. Please see the Response to Request for Production No. 17(b) — Confidential Attachment 3 for the Progress Reports associated with the 60 MW Franklin BESS. Note, the Progress Reports are reporting on the status of the combined 100 MW solar PV facility and the 60 MW Franklin BESS. vi. There have been no change orders associated with the Franklin BESS BTA. Please note, the progress reports reference change orders however those are change orders between Duke and their subcontractors, not change orders associated with the agreement with Idaho Power. c. i. As explained in part (a), because the 60 MW Franklin BESS is a full turn-key project from design and engineering to procurement and construction, Idaho IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 7 Power is not constructing the project but rather makes payments to Duke for the BESS in accordance with the Franklin BESS BTA. These are reflected on the WBS in the Purchased Services category provided as the Response to Request for Production No. 17(b) — Confidential Attachment 1 . ii. Not applicable. See part (b)(ii). iii. As explained in part (a)(iv), throughout the year, capital projects are evaluated and re-forecasted as necessary to increase or reduce forecasted spend during the remaining life of the project. The changes are monitored monthly through variance analysis reporting and quarterly through budget update analysis and reporting. The budget updates reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet are evidence of approval of the updated budget amounts associated with the project. For the 60 MW Franklin BESS, which was managed through MS Project Schedule, Idaho Power has pulled the variance notes documenting the reason for the change in budget update, if one occurred. See the Response to Request for Production No. 17(c) —Attachment for the 60 MW Franklin BESS project budget update Variance Notes. iv. The following table presents the adjustments to the Guaranteed Substantial Completion Date and Final Acceptance Date, caused by unforeseen project challenges. Specifically, complications from network equipment problems and a failure of the site's auxiliary transformer, resulting in delays to the BESS site's energization process. Consequently, this has deferred the commissioning schedule of the BESS equipment. Presently, the site has entered the IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 8 commissioning phase, with the BESS undergoing active charge and discharge cycles. Construction Schedule BTA Milestone Forecasted Milestone Completion Date Completion Date Guaranteed Substantial Completion Date 6/1/2024 8/12/2024 Final Acceptance 8/1/2024 I 9/10/2024 The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 9 REQUEST FOR PRODUCTION 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; 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; IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 10 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 18: a. As described in Case Nos. IPC-E-23-05 and IPC-E-23-20, Idaho Power's requests for a Certificate of Public Convenience and Necessity ("CPCN") associated with the 36 MW Hemingway BESS, for which the Commission issued Certificate Nos. 544 and 547, the Company experienced a rapid change in the 2024 capacity position, first identifying the June 2024 deficiency in May 2021 . To meet its obligation to reliably serve customer load and fill the 2024 capacity deficiency, the Company conducted a competitive solicitation through a Request for Proposal ("RFP") soliciting proposals for the acquisition of 85 MW of electric energy and capacity to be online by June of 2024. The procurement process resulted in the acquisition of least-cost, least-risk resources necessary to fill the 2024 capacity, including the 36 MW Hemingway BESS. The scope and project plan are primarily comprised of preliminary design drawings which were adapted throughout the design and construction phase. The Energy Sales Agreement ("ESA") dated June 8, 2023, provided as Response to Request for Production No. 18(a)— Confidential Attachment, provides many of the items typically discussed in a project plan. In addition to the ESA, typical scope items include supporting infrastructure and IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 11 ancillary equipment such as foundations, conduit, grounding, medium-voltage transformers, cables, and electrical equipment. i. Please see Exhibit A to the Hemingway ESA for the initial project scope. ii. Please see Response to Request for Production No. 17(a) — Confidential Attachment 2 for the Budget Update — Authorized to Spend spreadsheet that identifies the original approved budget amount of$28.6 million. Note, when the BID was established, the project was initially envisioned as a 12 MW BESS and the $28.6 million budget established. However, as described in the Company's request in Case No. IPC-E-23-20,1 for which Idaho Power was granted a CPCN, the capacity deficiency in 2024 increased, necessitating the 36 MW Hemingway BESS, and an increase in the budget of approximately $36.9 million, for a total original approved budget of $65.5 million. iii. Please see Exhibit D to the Hemingway ESA for the initial project schedule. iv. Please see the Company's Response to Request for Production No. 17(a)(iv) for the project budget approval process. The creation of the BID HMWY230003 for the 36 MW Hemingway BESS and corresponding approved budget amounts reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet, is evidence of approval of the initial budget. b. i. Not applicable. The project scope did not change from what was first identified in the Hemingway ESA. In the Matter of Idaho Power Company's Application for a Certificate of Public Convenience and Necessity to Acquire Resources to be Online in Both 2024 and 2025 and for Approval of an Energy Storage Agreement with Kuna BESS LLC, Case No. IPC-E-23-20, Application at 5 and Ellsworth DI testimony. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 12 ii. As explained in part (a)(iv), the 36 MW Hemingway BESS project is continuously managed and scrutinized on a monthly basis through MS Project Server scheduling software. Any changes in scope, budget, or schedule, are approved in real-time based on the overall portfolio limits. The changes, as appropriate, are documented by revising the scope, design drawings, construction specifications, and other pertinent documents and the budget and schedule are updated in MS Project related to forward action items that overwrite previous plans. Therefore, the only WBS the Company can provide for the project is reflective of the most recent budget and schedule. Please see the Response to Request for Production No. 18(b) — Confidential Attachment 1 for the 36 MW Hemingway BESS project WBS. iii. See part (b)(ii). iv. Aside from the delay in delivery discussed in part (c)(iv) below, there have been no significant changes to the construction project scope, budget or schedule as envisioned initially. v. Please see the Response to Request for Production No. 18(b) — Confidential Attachment 2 for status updates provided by Idaho Power personnel currently managing the project as well as the Response to Request for Production No. 18(b) — Confidential Attachment 3 for the Powin contractor field logs. vi. There have been no change orders associated with the Hemingway ESA. c. i. Not applicable. See part (b)(ii). ii. Not applicable. See part (b)(ii). IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 13 iii. As explained in part (a)(iv), throughout the year, capital projects are evaluated and re-forecasted as necessary to increase or reduce forecasted spend during the remaining life of the project. The changes are monitored monthly through variance analysis reporting and quarterly through budget update analysis and reporting. The budget updates reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet are evidence of approval of the updated budget amounts associated with the project. For the 36 MW Hemingway BESS, which was managed through MS Project Schedule, Idaho Power has pulled the variance notes documenting the reason for the change in budget update, if one occurred. See the Response to Request for Production No. 18(c) —Attachment for the 36 MW Hemingway BESS project budget update Variance Notes. iv. Delayed delivery of the battery equipment has resulted in delayed plant operation. However, all battery equipment has now arrived at the project site, with battery segment deliveries occurring between April 2, 2024, and May 20, 2024. Field commissioning activities by Powin continue and plant operation is expected to occur late summer 2024. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 14 REQUEST FOR PRODUCTION 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; IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 15 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 19: a. As described in Case No. IPC-E-22-13, Idaho Power's Application for a Certificate of Public Convenience and Necessity to Acquire Resources to be Online by 2023 to Secure Adequate and Reliable Service to its Customers, for which the Commission issued Certificate No. 538, the Company experienced a rapid change in the 2023 capacity position, first identifying the June 2023 deficiency in May 2021 . To meet its obligation to reliably serve customer load and fill the 2023 capacity deficiency, the Company conducted a competitive solicitation through an RFP seeking to acquire up to 80 MW of peak capacity resources, to be online by June of 2023. The procurement process resulted in the acquisition of least-cost, least-risk resources necessary to fill the 2023 capacity, including the 40 MW Black Mesa BESS. The scope and project plan are primarily comprised of preliminary design drawings which were adapted throughout the design and construction phase. The Battery Energy Supply Agreement between Idaho Power Company, as Buyer and Powin, LLC, as Supplier, Black Mesa Project, February 28, 2022, ("Black Mesa BESX), provided as Response to Request for Production No. 19(a) — Confidential Attachment 1 , as well as Change Order#01, included as Response IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 16 to Request for Production No. 19(a) — Confidential Attachment 2, which define additional contract provisions and provide general information requested. In addition to the Black Mesa BESA, typical scope items include supporting infrastructure and ancillary equipment such as foundations, conduit, grounding, medium-voltage transformers, cables, and electrical equipment. i. Idaho Power entered into agreements to purchase peak capacity resources for up to 120 MW of electric generating capacity to be online by June of 2023. Please see Exhibit A to the Black Mesa BESA, which is included in Change Order#01 , for the initial project scope. ii. The budget was established as a result of a Request for Quotes as well as design estimates. Please see Response to Request for Production No. 17(a) — Confidential Attachment 2 for the Budget Update — Authorized to Spend spreadsheet that identifies the original approved budget amount of $68.9 million. iii. The project was first identified in 2021 and was anticipated to be commercially operational in the third quarter of 2023. Please see Exhibit D to the Black Mesa BESA for the initial project schedule. iv. Please see the Company's Response to Request for Production No. 17(a)(iv) for the project budget approval process. The creation of the BID BMSU220002 for the 40 MW Black Mesa BESS and corresponding original approved budget reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet, is evidence of approval of the initial budget. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 17 b. i. Not applicable. The project scope did not change from what was first identified in the Black Mesa BESA. ii. See the Company's Response to Request for Production No. 17(b)(ii). The only WBS the Company can provide for the project is reflective of the most recent budget and schedule. Please see the Response to Request for Production No. 19(b) — Confidential Attachment 1 for the 40 MW Black Mesa BESS project WBS. iii. Not applicable. See part (b)(ii). iv. For the 40 MW Black Mesa BESS project, which was managed through MS Project Server, Idaho Power has pulled the variance notes documenting the reason for the change in budget update, if one occurred. See the Response to Request for Production No. 19(b) — Attachment 2 for the 40 MW Black Mesa BESS project budget update Variance Notes. Schedule deviation is discussed in part (c)(iv). v. Please see the Response to Request for Production No. 19(b) — Confidential Attachment 3 for status updates provided by Idaho Power personnel currently managing the project as well as Response to Request for Production No. 19(b) — Confidential Attachment 4 for Powin contractor field logs. vi. Please see the Response to Request for Production No. 19(a) — Confidential Attachment 2 for the Black Mesa BESA Change Order No. 1. In addition, see the Response to Request for Production No. 19(b) — Confidential Attachment 5 for additional change orders associated with the 40 MW Black Mesa BESS. c. i. Not applicable. See part (b)(ii). IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 18 ii. Not applicable. See part (b)(ii). iii. Not applicable. However, see the Variance Notes provided in part (b)(iv) for an explanation of variances driving the budget updates. iv. Delayed delivery of the battery equipment resulted in delayed plant commissioning and full operation. As identified in Exhibit D to the Black Mesa BESA, the anticipated operation date was in the third quarter 2023. The plant operated in limited capacity throughout 2023 and is now fully operational. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 19 REQUEST FOR PRODUCTION 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 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 IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 20 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 20: a. Line 423 is a 138-Kilovolt("kV") line that runs from Ontario to the Quartz substation, south of Baker City in Oregon. This project rebuilt the Huntington to Quartz 138- IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 21 kV portion of Line 423 ("Huntington-Quartz line") due to the age of the existing line and resulting reliability issues. When evaluating potential outage sources it was noted that due to the age of the lines, shield wires had not been installed on the lines and therefore lightning was likely contributing to the performance issues. Thus, the Company engaged POWER Engineers, Inc. ("POWER Engineers"), to perform a study to analyze the entire Ontario to Quartz 138-kV line, and specifically the Huntington to Quartz section to determine if a rebuild on the line would increase reliability. POWER Engineers used a lightning performance software, analyzing three cases, each with two different footing resistance assumptions: (1) the existing wood structure with no shield wires, (2) a new wood structure with two shield wires, and (3) a new steel structure with two shield wires. The results indicated that the overall line performance would be significantly improved with the addition of shield wires and further improvement is expected if steel structures were used in combination with the addition of shield wires. Please see Response to Request for Production No. 20(a) — Confidential Attachment for a copy of the POWER Engineers study. b. Absent the rebuild, the Company anticipated high maintenance and repair costs and reduced reliability. In addition, equipment failure could lead to an extensive outage and possible property damage. The Huntington-Quartz line rebuild involved the replacement of 286 structures from the Huntington substation to the Quartz substation with tubular steel 138-kV structures with shield wire and optical ground wire for fiber optic communications. The majority of the existing wood structures IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 22 were installed in 1951 and therefore did not have space for the addition of shield wires. Shield wires are installed above the conductors for the purpose of channeling lightning strikes to ground, which helps to prevent or minimize damage to power lines and equipment, avoid major outages on the line, and mitigate maintenance and repair costs. Moreover, because the Huntington-Quartz line was identified as being in a wildfire prone area, the project was prioritized, and grid hardening performed as part of the rebuild. Grid hardening includes the use of steel structures for resiliency against wildfires and improved customer reliability. The project is identified in Table 13 of the Company's 2024 Wildfire Mitigation Plan, which lists the transmission line rebuild projects planned over the next five years and necessitating steel structures in wildfire prone areas.2 The rebuild of the Huntington-Quartz line was necessary to ensure Idaho Power continues providing safe, reliable electric service to its customers. c. Numerous competitive solicitations exist for this project. Five key bid events were conducted for services to be provided to Idaho Power including construction services, design and engineering, environmental services, geotechnical services, and materials. The Light Detection and Ranging ("LIDAR"), steel pole inspection and hardline inspection services were sole sourced. The following bid events and detailed information regarding specifications, requirements, and other pertinent RFP information can be found in the following attachments: i. See the Company's Response to Request for Production No. 20(c) — Attachment 1 for a copy of the RFP for construction services, Company's 2 2024 Wildfire Mitigation Plan at 90 (filed in Case No. IPC-E-22-27). IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 23 Response to Request for Production No. 20(c) —Attachment 2 for a copy of the Request for Bids for design and engineering services, Company's Response to Request for Production No. 20(c) — Attachment 3 for a copy of the RFP for environmental services, Company's Response to Request for Production No. 20(c) — Attachment 4 for a copy of the RFP for geotechnical services, Company's Response to Request for Production No. 20(c) — Attachment 5 for a copy of the RFP for steel poles, and Company's Response to Request for Production No. 20(c)—Attachment 6 for a copy of the Sole Source Procurement Justifications. ii. For construction services, see the Response to Request for Production No. 20(c) — Confidential Attachment 7 for the summaries of the pricing and non- pricing responses. For design and engineering services, see the Response to Request for Production No. 20(c) — Confidential Attachment 8 for the summaries of the pricing and non-pricing responses. For environmental services, see the Response to Request for Production No. 20(c) — Confidential Attachment 9 for the summaries of the pricing and non-pricing responses. For geotechnical services, see the Response to Request for Production No. 20(c) — Confidential Attachment 10 for the summaries of the pricing and non-pricing responses. For steel poles, see the Response to Request for Production No. 20(c) — Confidential Attachment 11 for the bid evaluation results. iii. See part (c)(ii). iv. For construction services, see the Response to Request for Production No. 20(c) — Confidential Attachment 12. For design and engineering services, see IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 24 the Response to Request for Production No. 20(c) — Confidential Attachment 13. For environmental services, see the Response to Request for Production No. 20(c) — Confidential Attachment 14. For geotechnical services, see the Response to Request for Production No. 20(c) — Confidential Attachment 15. For steel poles, see the Response to Request for Production No. 20(c) — Confidential Attachment 16. In addition to competitive bid events, Idaho Power purchases many minor and ancillary materials and services in accordance with the Idaho Power Procurement Policy and Procurement Standard, provided as Response to Request for Production No. 20(c)— Confidential Attachment 17. Many goods are stock items in Idaho Power warehouses and are not bid through an RFP on a project basis, but rather as wholesale purchases. d. A specific project plan document could not be located. However, the following provides more information related to the project: i. The Huntington-Quartz line rebuild involved the replacement of 286 structures from the Huntington substation to the Quartz substation with tubular steel 138- kV structures with shield wire and optical ground wire for fiber optic communications. Please see Response to Request for Production No. 20(d) — Attachments 1 , 2 and 3 for detailed scope associated with the Huntington- Quartz line rebuild, the necessary foundation for the line, and the design of the project. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 25 ii. Please see Response to Request for Production No. 17(a) — Confidential Attachment 2 for the Budget Update — Authorized to Spend spreadsheet that identifies the original approved budget amount of$26.2 million. iii. The project was first identified in 2018 with permitting scheduled to begin in 2019, engineering and design work to occur in 2020, and construction to take place in 2021 through 2022. Construction however was deferred until 2023. iv. See the Company's Response to Request for Production No. 17(a)(iv) for an explanation of the capital project budget approval processes. The creation of the BID T423190001 for the Huntington-Quartz line rebuild and corresponding original approved budget reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet, is evidence of approval of the initial budget. e. There is no construction project plan document as construction plans have not changed since the scope and design documents were created. i. The project scope did not change following completion of the scope documents provided in Response to Request for Production No. 20(d) — Attachments 1, 2 and 3. ii. See the Company's Response to Request for Production No. 17(b)(ii). The only WBS the Company can provide for the project is reflective of the most recent budget and schedule. Please see the Response to Request for Production No. 20(e)—Attachment 1 for the Huntington-Quartz line rebuild project WBS. Note, the remaining work, identified as Construction 2024 on the WBS, is primarily IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 26 related to the line construction costs which would fall in the Materials and Labor categories upon completion. iii. See part (e)(ii). iv. See the Company's Response to Request for Production No. 17(a)(iv) and (c)(iii). The budget updates reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet are evidence of approval of the updated budget amounts associated with this project. For the Huntington-Quartz line rebuild, which was managed through MS Project Schedule, Idaho Power has pulled the variance notes documenting the reason for the change in budget update, if one occurred. See the Response to Request for Production No. 20(e) — Attachment 2 for the Huntington-Quartz line rebuild project budget update Variance Notes. v. Please see the Response to Request for Production No. 20(e) — Attachment 3 for the inspection reports that have been prepared during construction. vi. Please see the Response to Request for Production No. 20(e) — Confidential Attachment 4 for the change orders associated with the project. f. i. Not applicable. See part (e)(ii). ii. Not applicable. See part (e)(ii). iii. Not applicable. However, see the Variance Notes provided in part (e)(iv) for an explanation of variances driving the budget updates. iv. There have been no deviations in the schedule from the initial schedule which identified commencement of construction in 2023. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 27 The response to this Request is sponsored by Mitch Colburn, Vice President of Planning, Engineering and Construction, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 28 REQUEST FOR PRODUCTION 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. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 29 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 21: a. Line 902 is one of the three 230-kV transmission lines that run from the Boise Bench substation to the Midpoint substation in areas prone to wildfire. Line 902 has been connected to and split into many line sections by station additions over IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 30 the years, and is now comprised of the Midpoint to Justice, Justice to Mountain Air Wind Tap, Mountain Air Wind Tap to Rattlesnake, Rattlesnake to DRAM, and finally DRAM to Boise Bench segments. Line 902 was originally built over 70 years ago, with 478 of the original structures from 1947 in place. The Company follows transmission maintenance and inspection practices in accordance with Western Electricity Coordinating Council and the North American Electric Reliability Corporation ("NERC") requirements to ensure compliance with applicable safety and reliability standards and takes proactive steps to repair or replace transmission line components on an ongoing basis as part of asset management and aging infrastructure assessments. Pursuant to its Transmission Maintenance and Inspection Plan ("TMIP"), the Company performs line inspections to identify conditions or defects and inform, prioritize, and schedule maintenance activities. Routine line patrols are conducted annually and comprehensive maintenance inspections are generally performed every 10 years, and include a detailed inspection of all transmission line components and a pole inspection and ground-line treatment of all wood poles in the line. When inspected, many poles and cross arms on Line 902 were found to be in poor condition and as a result of this process, Line 902 was identified as needing to be rebuilt. Please see the Company's Response to Request for Production No. 21(a) — Attachment for the Line 902 structures overview and the resulting maintenance recommendations. The rebuild project will occur in four phases, the first of which is included in the Company's request in this case, approximately 36-mile Rattlesnake substation to DRAM substation section ("Rattlesnake to DRAM"). IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 31 b. There were no alternatives to the rebuild of the line. Delaying the rebuild of Line 902 could result in higher maintenance and repair costs should the structures need replacement individually, while also potentially reducing reliability. Further, the Company's Integrated Resource Plan has repeatedly identified the need for resource additions east of the Treasure Valley and rebuilding the line with larger conductors is the most cost-effective way to integrate those resources. Further, the Company's inspection and maintenance activities helps inform consideration of wildfire risk and the resulting prioritization of transmission line rebuild projects. All four phases of the Line 902 rebuild fall within the wildfire prone areas as identified in Idaho Power's 2024 Wildfire Mitigation Plan, including the Rattlesnake to DRAM section.3 Therefore, the line rebuild will utilize steel structures for resiliency against wildfires and to improve customer reliability. c. Several competitive solicitations exist for this project for material, design consulting service, and construction. Two key bid events were conducted for services to be provided to Idaho Power including design and construction services. The purchase of steel poles was sole sourced. i. See the Response to Request for Production No. 21(c) — Attachment 1 for the RFP for construction services, the Response to Request for Production No. 21(c) — Attachment 2 for the RFP for design services, and the Response to Request for Production No. 21(c) — Attachment 3 for the Sole Source Procurement Justification for the steel poles. 3 2024 Wildfire Mitigation Plan at 90 (filed in Case No. IPC-E-22-27). IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 32 ii. For construction services, see the Response to Request for Production No. 21(c) — Confidential Attachment 4 for the summaries of the pricing and non- pricing responses and an executive summary of the bid evaluation results. For design services, see the Response to Request for Production No. 21(c) — Confidential Attachment 5 for the summaries of the pricing and non-pricing responses. iii. See part (c)(ii). iv. For construction services, see Response to Request for Production No. 21(c) — Confidential Attachment 6 and for design services see Response to Request for Production No. 21(c) — Confidential Attachment 7. d. A specific project plan document could not be located. However, the following provides more information related to the project: i. Line 902, which runs from the Boise Bench substation to the Midpoint substation, was originally built over 70 years ago through wildfire prone areas and many poles and cross arms were found to be in poor condition. The Rattlesnake to DRAM rebuild is the first phase of the Line 902 rebuild. Please see Response to Request for Production No. 21(d) — Attachment for the detailed scope and design associated with the Rattlesnake to Dram line rebuild project. ii. Please see Response to Request for Production No. 17(a) — Confidential Attachment 2 for the Budget Update — Authorized to Spend spreadsheet that identifies the original approved budget amount of$21.4 million. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 33 iii. The project was first identified in late 2021 with construction anticipated to commence in 2023 and conclude in 2024. iv. See the Company's Response to Request for Production No. 17(a)(iv) for an explanation of the capital project budget approval processes. The creation of the BID T902220002 for the Rattlesnake to DRAM line rebuild and corresponding original approved budget reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet, is evidence of approval of the initial budget. e. There is no construction project plan document as construction plans have not changed since the scope and design document was created. i. The project scope did not change following completion of the scope documents provided in Response to Request for Production No. 21(d) — Attachment 1. ii. See the Company's Response to Request for Production No. 17(b)(ii). The only WBS the Company can provide for the project is reflective of the most recent budget and schedule. Please see the Response to Request for Production No. 21(e) — Attachment 1 for the Rattlesnake to DRAM line rebuild project WBS. iii. See part (e)(ii). iv. See the Company's Response to Request for Production No. 17(a)(iv) and (c)(iii). The budget updates reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet are evidence of approval of the updated budget amounts associated with this project. For the Rattlesnake to DRAM line rebuild, which was managed through MS Project Schedule, Idaho Power has pulled the IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 34 variance notes documenting the reason for the change in budget update, if one occurred. See the Response to Request for Production No. 21(e)—Attachment 2 for the Rattlesnake to DRAM line rebuild project budget update Variance Notes. v. Please see Response to Request for Production No. 21(e) — Attachment 3 for inspection reports prepared during construction. vi. Please see Response to Request for Production No. 21(e) — Confidential Attachment 4 for the change orders associated with the project. f. i. Not applicable. See part (e)(ii). ii. Not applicable. See part (e)(ii). iii. Not applicable. However, see the Variance Notes provided in part (e)(iv) for an explanation of variances driving the budget updates. iv. Due to material availability, steel pole deliveries, initially scheduled for 2023 were delayed until 2024. In addition, construction contractors encountered a significant amount of mud during the winter, delaying structure replacements in January 2024 but have increased manpower and equipment to keep the project on schedule. The response to this Request is sponsored by Mitch Colburn, Vice President of Planning, Engineering and Construction, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 35 REQUEST FOR PRODUCTION 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; 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. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 36 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 22: a. The series capacitor bank at the Midpoint Station was over 40 years old, having been installed in 1980 and needed replacement. While the asset life of a series capacitor bank can be longer, major components need to be replaced every 15 to IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 37 30 years, depending on the part. However, new parts for the series capacitor bank at the Midpoint Station were difficult to procure and some parts had become obsolete, including certain relay parts, control potential transformers, un-balance current transformers, spark gaps, and the triggering circuit for the spark gap. Further, a typical series capacitor replacement takes approximately 7 years to complete, once the need is identified. Please see the Company's Response to Request for Production No. 22(a) — Attachment for a report that summarizes the results of the Powerflow case studies performed on the series capacitor bank prior to replacement. b. There were no alternatives to the replacement of the Midpoint Station series capacitor bank. This series capacitor bank is necessary to achieve the path rating and as such its continued reliability is critical. A failure of a trigger or spark gap or a loss of a critical relay could disable either one or both of the series capacitor bank segments indefinitely. The bank ensures the Midpoint Station transformer is not overloaded and prevents derating the transmission paths at Midpoint up to 280 MW's, which is critical to the continued reliability. c. Several competitive solicitations exist for this project. Three key bid events were conducted for services to be provided to Idaho Power including for materials and construction services, both for the capacitor bank and the control room. The purchase of fencing and the bird abetment lasers was sole sourced. i. See the Response to Request for Production No. 22(c) — Attachment 1 for the RFP for the capacitor bank, the Response to Request for Production No. 22(c) —Attachment 2 for the RFP for construction services, the Response to Request IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 38 for Production No. 22(c) — Attachment 3 for the RFQ for construction of the control building, the Response to Request for Production No. 22(c) — Attachment 4 for the Sole Source Procurement Justification for fencing, and the Response to Request for Production No. 22(c) — Attachment 5 for the Sole Source Procurement Justification for the bird abetment lasers. ii. For the capacitor bank, see the Response to Request for Production No. 22(c) — Confidential Attachment 6, for an executive summary of the bid evaluation results. For construction services, see the Response to Request for Production No. 22(c)—Confidential Attachment 7 for the summaries of the pricing and non- pricing responses and an executive summary of the bid evaluation results. For construction of the control room, see the Response to Request for Production No. 22(c)—Confidential Attachment 8 for the summaries of the pricing and non- pricing responses. iii. See part (c)(ii). iv. For the capacitor bank, see the Response to Request for Production No. 22(c) — Confidential Attachment 9, for construction services, see the Response to Request for Production No. 22(c) — Confidential Attachment 10 and for construction of the control room, see the Response to Request for Production No. 22(c) — Confidential Attachment 11. d. A specific project plan document could not be located. However, the following provides more information related to the project: i. The existing capacitor bank will be removed in entirety and the new capacitor bank will be installed in the same location. In addition, a new control building IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 39 will be constructed near the new capacitor bank. See the Response to Request for Production No. 22(d)—Attachment for the series capacitor bank replacement scope of work. ii. Please see Response to Request for Production No. 17(a) — Confidential Attachment 2 for the Budget Update — Authorized to Spend spreadsheet that identifies the original approved budget amount of$8.5 million. iii. Replacement of the series capacitor bank was first considered in 2015 but deferred as work that required the bank to be out of service required coordination with PacifiCorp to maintain reliability. In 2021 the initial scope was completed, which identified design completion in late 2022, with construction to commence in 2023 and completion to occur in 2024. iv. See the Company's Response to Request for Production No. 17(a)(iv) for an explanation of the capital project budget approval processes. The creation of the BID MPSN210001 for the Midpoint Station series capacitor bank replacement and corresponding original approved budget reflected in the Response to Request for Production No. 17(a)— Confidential Attachment 2, the Budget Update —Authorized to Spend spreadsheet, is evidence of approval of the initial budget. e. Please see the Response to Request for Production No. 22(e) — Attachment 1 for the pre-construction summary document. i. The project scope did not change following completion of the scope document provided in Response to Request for Production No. 22(d) — Attachment. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-40 ii. See the Company's Response to Request for Production No. 17(b)(ii). The only WBS the Company can provide for the project is reflective of the most recent budget and schedule. Please see the Response to Request for Production No. 22(e) — Attachment 2 for the Midpoint Station series capacitor bank replacement project WBS. iii. See part (e)(ii). iv. See the Company's Response to Request for Production No. 17(a)(iv) and (c)(iii). The budget updates reflected in the Response to Request for Production No. 17(a) — Confidential Attachment 2, the Budget Update — Authorized to Spend spreadsheet are evidence of approval of the updated budget amounts associated with this project. For the Midpoint Station series capacitor bank replacement, which was managed through MS Project Schedule, Idaho Power has pulled the variance notes documenting the reason for the change in budget update, if one occurred. See the Response to Request for Production No. 22(e) — Attachment 3 for the Midpoint Station series capacitor bank replacement project budget update Variance Notes. v. Please see Response to Request for Production No. 22(e) — Attachment 4 for an inspection report prepared during construction. vi. Please see Response to Request for Production No. 22(e) — Confidential Attachment 5 for the change orders associated with the project. f. i. Not applicable. See part (e)(ii). ii. Not applicable. See part (e)(ii). IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-41 iii. Not applicable. However, see the Variance Notes provided in part (e)(iv) for an explanation of variances driving the budget updates. iv. As evidenced in the Variance Notes provided in part (e)(iv), there were no deviations in the construction schedule. The response to this Request is sponsored by Mitch Colburn, Vice President of Planning, Engineering and Construction, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-42 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 23: a. In 2015, at 35 years old, the Company was experiencing difficulties keeping the Midpoint Station series capacitor bank online when parts failed. Note, a typical series capacitor replacement takes approximately 7 years to complete, once the need is identified. Series capacitor banks supply line compensation, allowing for the transmission of more electricity over the line. Only so much line compensation at one location can occur, typically a maximum of 70 percent at one location, or the line will be unstable. To increase the line compensation, series capacitor banks are typically installed at both ends of the line. At the time, it was thought that both Idaho Power and PacifiCorp would bid IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-43 the series capacitor banks for both the Midpoint Station and the Burns Station, the capacitor bank at the other end of the Midpoint line. Because the existing Burns series capacitor bank, owned entirely by PacifiCorp, was identical to the Midpoint Station series capacitor bank, which had spark gaps and slow bypass breakers, it was important that both were replaced, and both utilized the newer metal oxide varistor technology with fast bypass breakers. The project was deferred to allow time for PacifiCorp to budget for their series capacitor bank at Burns. As discussions with PacifiCorp ("PAC") continued, Idaho Power determined that requirements for the Midpoint to Burns series capacitor banks would differ with the anticipated additions of B2H and Gateway West. The replacement of the projects would need to coordinate with 500-kV buildout plans and allow for optimized transfer capability. The additional budgeting time for PAC also allowed time for Idaho Power's planning department to verify what configuration the new series capacitor bank at the Midpoint Station would be, it was determined that, in the interim, the Midpoint Station series capacitor bank bypass breakers could be replaced because failures of the bypass breakers were 80 percent of the problem with keeping the series capacitor bank online at the time. The BID for the breaker replacement was established in 2016, with work completed in 2018, and the complete replacement of the Midpoint Station series capacitor bank was deferred until the 2023 to 2024 time period. In 2020, the reconfigured series capacitor bank that more closely aligned with the requirements determined by the planning department was identified and the project scheduled for work to commence in 2023. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-44 Please see the Response to Request for Production No. 23 —Attachment 1 for the scoping kick-off meeting notes with Idaho Power and PacifiCorp that discuss the replacement of the series capacitor bank bypass breakers as an interim solution to the replacement of the series capacitor bank. Idaho Power does not have any additional documentation that discusses the deferment of the project however has included as the Response to Request for Production No. 23 — Attachment 2 the request for approval sent to PacifiCorp in 2021 for the replacement of the Midpoint Station series capacitor bank once the reconfigured series capacitor bank was identified. b. See part (a). The response to this Request is sponsored by Mitch Colburn, Vice President of Planning, Engineering and Construction, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-45 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 24: Please see the table below, which details the monthly service level of the Company's Customer Service Center between 2023 and 2024 YTD. The provided monthly service level percentages reflect the percentage of calls answered within 60 seconds. Service Level Month 2023 2024 Jan. 88.9% 85.1% Feb. 84.6% 80.5% Mar. 89.1% 82.9% Apr. 86.3% 72.3% May 80.8% 77.0% Jun. 86.6% 76.6% Jul. 86.7% Aug. 84.3% Sep. 89.4% Oct. 81.5% Nov. 87.8% Dec. 90.9% Year 86.3% 78.9% The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-46 REQUEST FOR PRODUCTION NO. 25: Please provide the number of incoming calls handled by the Customer Service Center by month for the year 2023 and YTD 2024. RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Please see the table below which details the number of monthly incoming calls between 2023 and 2024 YTD that were handled by the Company's Customer Service Center. Incoming calls Month 2023 2024 Jan. 45,447 48,242 Feb. 44,556 47,632 Mar. 60,574 58,167 Apr. 50,628 57,138 May 54,893 56,125 Jun. 51,244 50,695 Jul. 48,411 Aug. 57,230 Sep. 53,305 Oct. 55,558 Nov. 47,565 Dec. 41,804 Year 611,215 317,999 The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-47 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Please see the table below, which details the number of monthly calls received between 2023 and 2024 YTD that were routed to the Company's Customer Service Center but subsequently abandoned prior to being connected with an agent. Abandoned Calls Month 2023 2024 Jan. 1,044 2,904 Feb. 1,461 2,147 Mar. 1,966 3,588 Apr. 1,810 3,605 May 2,346 3,972 Jun. 1,888 2,867 Jul. 1,431 Aug. 2,166 Sep. 1,546 Oct. 2,332 Nov. 1,600 Dec. 1,431 Year 21,021 19,083 The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-48 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 27: Please see the table below, which details the Company's Customer Service Center's monthly average speed of answer for calls received between 2023 and 2024 YTD. Average Speed of Answer (in seconds) Month 2023 2024 Jan. 31 49 Feb. 41 50 EMar. 30 58 Apr.E38 72 May 52 63 Jun. 38 62 Jul. 34 Aug. 38 Sep. 28 Oct. 46 Nov. 33 Dec. 24 Year 1 36 59 The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-49 REQUEST FOR PRODUCTION 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). RESPONSE TO REQUEST FOR PRODUCTION NO. 28: Please see the table below, which details the Company's Customer Service Center's monthly average handling time, including all respective "off-line" work, for calls received between 2023 and 2024 YTD. Average Handling Time (in seconds) Month 2023 2024 Jan. 360 371 Feb. 374 384 Mar. 373 379 Apr. 372 386 May 376 379 Jun. 369 370 Jul. 357 Aug. 365 Sep. 361 Oct. 359 Nov. 360 Dec. 360 Year 360 371 The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 50 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 29: Please see the table below, which details the Company's Customer Service Center's monthly first call resolution rate for all calls received between 2023 and 2024 YTD. The Company's "first call resolution rate" is defined as the percentage of phone numbers that do not place more than one call to the Company's Customer Service Center within a 24-hour period (midnight to midnight MST). The calculation collectively considers representative and IVR handled calls. First Call Resolution Rate Month 2023 2024 Jan. 77.2% 75.2% Feb. 77.6% 76.3% Mar. 75.3% 72.8% Apr. 75.3% 74.6% May 75.6% 74.7% Jun. 75.5% 74.3% Jul. 75.2% Aug. 75.5% rOct. 75.6% 75.6% 76.4% Dec. 76.6% Year 75.9% 74.6% The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 51 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 30: Please see the table below, which details the Company's Customer Service Center's average monthly response time for email transactions received between 2023 and 2024 YTD. Of note, the average response times provided below encompass the entire duration from the moment an email is received, including times outside of the Customer Service Center's operating hours. Average Email Response Time (in hours:minutes:seconds) Month 2023 2024 Jan. 5:30:48 13:49:08 Feb. 8:10:23 17:07:26 Mar. 4:27:42 21:38:04 Apr. 15:11:24 23:19:22 May 26:13:03 10:00:13 Jun. 16:52:59 8:11:03 Jul. 10:13:43 Aug. 9:41:21 Sep. 8:29:56 Oct. 19:47:30 Nov. 6:15:27 Dec. 6:57:35 Year 11:29:19 15:40:53 The response to this Request is sponsored by Tim Tatum, VP of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 52 DATED at Boise, Idaho, this 31 st day of July 2024. LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 53 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 31st day of July 2024, 1 served a true and correct copy of Idaho Power Company's Response to the Fourth Production Request of the Commission Staff to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Chris.Burdin(a-),puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Industrial Customers of Idaho Power Hand Delivered Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27t" Street FAX Boise, Idaho 83702 FTP Site X Email peter _richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dread ing(@ mindsprinq.com Idaho Irrigation Pumpers Association, Hand Delivered Inc. U.S. Mail Eric L. Olsen Overnight Mail ECHO HAWK & OLSEN, PLLC FAX 505 Pershing Avenue, Suite 100 FTP Site P.O. Box 6119 X Email elo(o)_echohawk.com Pocatello, Idaho 83205 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance aegisinsight.com IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 54 Idaho Conservation League Hand Delivered Matthew Nykiel U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email Matthew.n kiel mail.com Brad Heusinkveld Hand Delivered Idaho Conservation League U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email bheusinkveld(a)_idahoconservation.org Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach FTP Site Holland & Hart LLP X Email 555 17t" Street, Suite 3200 darueschhoff(a)_hollandhart.com Denver, CO 80202 tnelson hollandhart.com awiensen(o)-hollandhart.com karoach(ahol land hart.com Jim Swier Hand Delivered Micron Technology, Inc. U.S. Mail 8000 South Federal Way Overnight Mail Boise, ID 83707 FAX FTP Site X Email swierC@.micron.com City of Boise Hand Delivered Ed Jewell U.S. Mail Deputy City Attorney Overnight Mail Boise City Attorney's Office FAX 150 N. Capitol Blvd. FTP Site P.O. Box 500 X Email Boise, Idaho 83701 BoiseCityAttorney(a-).cityofboise.org eiewel I(a)cityofboise.org IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 55 Steven Hubble Hand Delivered Boise City Dept. of Public Works U.S. Mail 150 N. Capitol Blvd. Overnight Mail P.O. Box 500 FAX Boise, Idaho 83701-0500 FTP Site X Email shubble(a_cityofboise.org Federal Executive Agencies Hand Delivered Peter Meier U.S. Mail Emily W. Medlyn Overnight Mail U.S. Department of Energy FAX 1000 Independence Ave., S.W. FTP Site Washington, DC 20585 X Email Pete r.meier(cDhq.doe.gov emily.medlyn(cD_hg.doe.gov Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 56