HomeMy WebLinkAbout20240806IPC to Staff 51-58.pdf 0-10AM POWER.
LISA D. NORDSTROM
Lead Counsel
Inordstrorn(Widahopower.com
RECEIVED
August 6, 2024 Tuesday, August 6, 2024
IDAHO PUBLIC
VIA ELECTRONIC FILING UTILITIES COMMISSION
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
Seventh 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.
If you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
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 the attachment in Response to Request No. 58 to Idaho Power Company's
Response to the Seventh Production Request of the Commission Staff dated August 6,
2024, contains 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 6th day of August 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(aMdahopower.com
dwalker idahopower.com
mgoicoecheaallenCabidahopower.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 SEVENTH
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 Seventh Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated July 30, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 1
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 51: The Company records
all fines and penalties to FERC account 426.3 Penalties, which is an account that is
excluded from operating expenses for recovery in a rate case. The Company has not
been assessed any fines or penalties related to Capital Project activities impacting any
Public Right-of-Way.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 2
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 52: Yes, the Company has
criteria in place to determine if Contractors are ineligible to bid on or be awarded a
contract with the Company. Common factors that may render a contractor ineligible to
participate in a competitive bid or be the successful respondent include financial
instability, past performance issues (i.e., quality, safety), conflicts of interest, unresolved
litigation claims, inability to provide licenses or certifications pertaining to the specific
work, services, and material requested.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 3
REQUEST FOR PRODUCTION 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
("W BS").
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:
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER -4
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. 53:
a. Budget ID CHQB190012 is associated with a multi-year project that will upgrade
the bathrooms on each floor of the Corporate Headquarters ("CHQ") building. The
costs identified in the Company's Response to Request for Production No. 5 —
Confidential Attachment are specific to the remodel of the CHQ basement
bathrooms. There is no project plan document however the following provides
more information related to the project:
i. The costs associated with Budget ID CHQB190012 included in the Company's
request in this case are associated with the remodel of the CHQ basement
bathrooms due to a large water leak caused by excessive rain and the
overpowering of the city storm water system. This caused a 10" drain line to fail
in the CHQ basement above both bathrooms and locker rooms. This project
was scheduled and budgeted for 2026 but due to the extreme damage it was
moved forward and completed in 2024. While the CHQ basement bathroom
was not originally scheduled for a remodel until 2026, the original scope of
refurbishing the restrooms with new tile, plumbing fixtures, toilet partitions,
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 5
lighting and ceiling tile remained the same. The circulation core area of each
floor was to receive new lighting and floor covering.
ii. This was an unscheduled, unbudgeted project for the year it occurred. It was
scheduled for 2026 with a budget of $600,000 but needed to be accelerated
and completed earlier due to the extensive damage that was caused by the
failed drain piping. Once identified as needed in 2023, the project was bid out
to multiple contractors, and the lowest bid awarded the project.
iii. The initial schedule was to have the restrooms and core area completed by
February 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. This project was
approved in Budget Update 4 during the fourth quarter of 2023 with a total
budget of $602,895 due to the failure of the drain piping.
b. There is no construction project plan document as construction plans have not
changed since the initial scope.
i. The project scope did not change following identification in the initial scope.
ii. There is no Microsoft Project Schedule WBS associated with this project. As
an alternative, the following is a summary of the actual project costs by year,
through July 31, 2024, and by detailed cost element, similar to the WBS
function in Microsoft Project Schedule. Please note, the chart below excludes
Allowance for Funds Used During Construction and overheads.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 6
ACTUAL Column Labels
Row Labels 2023 2024 Grand Total
General Plant
Cost Elements Excl Power Supply
• Labor 21,S69.38 8,747.60 30,316.98
+ Materials 8,169.68 5,513.20 13,682.88
Purchased Services 417,136.60 48,228.60 465,365.20
• Other Expenses 11.18 11.18
Grand Total 446,875.66 62,500.58 509,376.24
iii. See part (b)(ii).
iv. See the Response to Request for Production No. 53 — Attachment for a copy
of the initial construction schedule for the remodel of the CHQ basement
bathroom. There were no deviations between the initial schedule and the
construction schedule.
v. There were no status reports associated with this project.
vi. There were no change orders associated with this project.
c. i. Not applicable. See part (b)(ii).
ii. Not applicable. See part (b)(ii).
iii. Not applicable. The remodel of the CHQ basement bathrooms scheduled for
2026 had an initial budget of $600,000 and actual project costs are
approximately $500,000.
iv. There were two schedule deviations during construction. First, during the main
drain line replacement, Idaho Power discovered the check valve to the Boise
city storm water system had failed in the open position and required
replacement. The lead time for this item caused the schedule to slip by 10
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 7
weeks. The second was related to the main drain line which was changed from
schedule 40 PVC to schedule 80 PVC for durability reasons.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 8
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 54: The Non-Criteria Based
Equipment identification is associated with the purchase of equipment that is part of Idaho
Power's critical business function and used in day-to-day operations. The costs of
$287,746 closed to plant during the January 1, 2024 through June 30, 2024, as reflected
in the Response to Request for Production No. 5, are the result of two equipment
purchases: (1) the replacement of a trailer mounted four drum puller for $268,396, and
(2) the purchase of an additional zero-turn lawn mower for $19,350. In 2023, a member
of the public hit and totaled one of the 2,000 pound four-drum pullers utilized by the
Canyon and Payette operations centers. The four drum puller is a critical piece of line
equipment. A puller is used to pull wire through carriers so it can be placed on the cross
arms of a pole. The four drum puller allows for four power lines to be installed at one time.
Power is diffused from the engine to the reels over a hydraulic drive train.
The Company evaluated two four drum puller replacement options, one diesel-
powered with the same specifications as the totaled unit for approximately $175,000, and
an all-electric stringing equipment version for approximately $245,000. Due to the
immediate availability and its ability to charge on-board requiring fewer trips to the
operations center for fuel, diesel pullers had lead times of 10 to 12 months, the decision
was made to purchase the all-electric drum puller. The electric version includes safeguard
limits for the wire size and length that can be pulled, providing prevention of line breakage
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 9
and damage, while also operating at a quieter level than the diesel counterpart. In
addition, the Company received approximately $82,000 in insurance proceeds from
damage to the old drum puller, helping to offset the costs of the new drum puller. Note,
the insurance proceeds are recorded in Account 108 — Accumulated Provision for
Depreciation, offsetting the costs recorded in Account 101 — Electric Plant in Service.
Finally, the purchase also supports Idaho Power's movement towards electrification of its
fleet.
The second Non-Criteria Based Equipment purchase was a zero-turn lawn mower
for use at the CJ Strike parks complex. The CJ Strike parks complex includes over 100
campsites between the three parks, North Park and Scout Park, and Cottonwood Park,
consisting of over 60 acres of turf that needs mowed weekly. The complex is staffed with
three full time employees and one seasonal employee between the months of April and
September. The employees provide customer service, as well as grounds and facilities
maintenance seven days per week.
The turf was being managed with two zero-turn mowers, taking approximately 25
hours per week to mow the turf. With the addition of a third mower, that time will be cut
by approximately 30 percent, while also enabling an additional staff member to assist in
managing mowing when other work is complete. Also, the additional mower provides a
backup unit if one mower goes down and needs repair. Further, the Company purchased
an Exmark mower, the same manufacturer of the mowers used at CJ Strike and the
Oxbow parks currently because of familiarity with the units, interchangeable parts,
exceptional reliability, and excellent customer support from Horizon, the Exmark dealer.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 10
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 11
REQUEST FOR PRODUCTION 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.
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 55:
a. The Avtec console system was installed in 2018 as part of the project to replace
the Idaho Power two-way radio communication system. The purchase price of the
system at that time was $604,988. The Avtec consoles are comprised of hardware
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 12
peripherals connected to dispatcher workstations, with software installed on the
workstations that allows dispatchers to manage communications with field
employees. In 2017, an RFP was issued soliciting multiple console system
manufacturers. Avtec was the successful respondent due in part to technical
deficiencies of competitor solutions that were required to interface with the
Company's two-way radio system.
The $171,995 that closed to plant year to date June 2024 was due to the
replacement of a portion of the Avtec console system that had been discontinued.
Rather than replacing the entire system, which would include the replacement of
the hardware and software, the completion and testing of the required
communications systems integrations, and the training of dispatchers in the new
system, at a much higher cost, Idaho Power replaced only the part of the system
that was discontinued. Further, the upgrade extended the life of other components
that did not require replacement. Given the system initially cost $604,988 in 2017,
the partial replacement at $171,995 was a more cost-effective solution.
b. The contract was known and planned to expire at five years and both parties
anticipated a renewal to maintain support services although it was not planned that
the console hardware would need to be upgraded as the previous equipment
would no longer be supported. Avtec had communicated this to customers, but
Idaho Power inadvertently excluded the project costs in the 2024 budget. The
Company and Avtec have developed an annual process to review the published
end-of-life/end-of-support dates for communications systems to understand
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 13
manufacturer's technology roadmaps and inform Idaho Power's future strategy
and resulting budget.
C. (i). Yes, the hardware and software were changed simultaneously with the
upgrades of the dispatcher workstations.
(ii). The efficiencies referenced are in small part financial and in larger part due to
the reduced dispatcher operations impact of a single disruption versus multiple
disruptions. The update cadence of Avtec hardware and software products do
not always align with the cadence of workstation replacements. Idaho Power
was able to accomplish both tasks by coordinating the work.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 14
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 56:
a. The existing furniture was disposed of due to age and quality.
b. There were separate Budget ID's for the CHQ Restroom/Core upgrades and the
CHQ Conference Room Upgrades, BIDs CHQB190012 and CHQB190014,
respectively. The conference room upgrades were designed and bid along with the
restroom and core upgrades in order to reduce costs by combining scopes into a
larger project and providing better pricing on lighting orders. The consolidation also
caused less disruption on each floor as both projects could be completed at one
time.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 15
REQUEST FOR PRODUCTION 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
e. Please explain the roles and responsibilities of each of the seasonal workers at
HCC referenced in the response.
RESPONSE TO REQUEST FOR PRODUCTION NO. 57:
a. There is no business case document specific to this project, the purchase of three
trailers for seasonal workers at the Hells Canyon Complex ("HCC"). Idaho Power
continually investigates lowest-cost housing options for employees working in
remote locations and explored RV hook up sites for the HCC seasonal workers.
However most seasonal workers do not have access to an RV. In the past, the
Company rotated seasonal employees through other field houses but was having
conflicts with other Idaho Power crews using the houses.
b. Idaho Power does not currently charge rent to the seasonal employees however
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 16
seasonal employees are responsible for replacing the propane they use and
providing upkeep on the unit they occupy.
c. The trailers will be winterized at this time however the Company anticipates they
will be used, year-round, post- HCC license issuance, because work will
intermittently continue into the fall and winter (e.g. fish weir monitoring, recreation
use surveys, and construction projects at our parks).
d. The trailers are used for seasonal employees who work at any of Idaho Power's
four major overnight parks: Hells Canyon Park, Copperfield Park, McCormick Park,
and Woodhead Park. In addition, they will be used at less-developed sites like
Carter's Landing, Copperfield Boat Launch and Oxbow Boat Launch.
e. Seasonal employees conduct maintenance including plumbing, irrigation, mowing,
pruning, weed control, light carpentry including painting, repairing park amenities,
and replacing signs. Employees also provide customer service, such as explaining
rules, access information, and liaising between law enforcement and the
Company. They also monitor systems, including sewer lift pump status, irrigation
timers, irrigation intakes, and public drinking water.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 17
REQUEST FOR PRODUCTION 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 1 has an in-service date of 7/31/2020 for "IVVC GridMod Project
Phase 4";
ii. In response to Production Request No. 36 in the 2023 Rate Case, Confidential
Attachment 1 has an in-service date of 1/31/2023 for "GridMod Single Vendor
Platform"; 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.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 18
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.
f. Please explain how this new platform will integrate with the existing software
systems used for wildfire mitigation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 58:
a. The two projects, while both the results of Idaho Power's grid modernization
efforts, are different. In the 2023 Rate Case, the test year included the replacement
of an Automated Capacitor Control ("ACC") system with the development of a new
integrated volt-var control ("IVVC") system. The IVVC system replaced a 22-year-
old DOS-based system that was nearing its end of life and was unable to provide
direct and coordinated voltage control offered by more modern systems such as
the IVVC system. Replacing the ACC with the IVVC provided the Company with
the ability to better control devices and gather data in real-time, allowing the
Company to improve power quality and voltage levels, optimize efficiency, and
provide visibility and control to engineers and operators to better manage the
distribution system. The IVVC was placed in service in July 2020.
The single vendor platform, also a project that is a part of Idaho Power's
grid modernization initiative, included the consolidation of three vendor solutions,
into one. The Company currently leverages three stand-alone grid control systems
for managing the bulk electric system, optimizing distribution assets, and
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 19
responding to customer outages. The systems are the (1) Energy Management
("EMS")/Supervisory Control and Data Acquisition ("SCADA") system, (2) Outage
Management System ("OMS"), and the (3) IVVC, a Distribution Management
System ("DMS").
Because these systems are independent, they require three sets of
hardware, three network models, three support organizations, and complex
integrations between the systems. Consolidating the disparate systems will reduce
total cost of ownership, lower cyber security threats, and improve user proficiency
and organizational support. The three systems will still exist but under one
platform. The common architecture will allow Idaho Power to optimize internal
support structures through shared resources and reduce the Company's total cost
of ownership through bundling support and licensing costs.
The single vendor platform project, assigned Budget ID BOBN220002, is
anticipated to be placed in service in October 2024 and, as evidenced by the Work
Breakdown Structure provided in the Company's Response to Request for
Production No. 32(b)—Attachment 1 work began in 2023. Specific tasks necessary
for the project are assigned work order numbers and once completed and the
product is used and useful, the work order is placed in service, which may be prior
to the entire project being completed. The costs identified in the 2023 Rate Case
in the Response to Production Request No. 36 — Confidential Attachment 1,
included as the Response to Production Request No. 58(a) — Confidential
Attachment in this proceeding, with an in-service date of January 2023 were
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 20
associated with three work orders under Budget ID BOBN220002 that had been
placed in service.
b. The following summarizes the annual O&M expenses specific to the software
related to the EMS, OMS and IVVC services for the past three years:
2021 2022 2023
EMS 243,816 258,552 271,478
OMS 222,157 237,469 236,740
IVVC 143,793 175,023 182,587
Grand Total 609,766 671,043 690,805
c. See the Company's Response to Request for Production No. 32(a) — Confidential
Attachment 2 for the business case for the project. The estimated capital costs are
presented in Table 19 — Estimated project costs on Page 33 of the business case
while the annual O&M expenses are presented in Table 20 — Estimated ongoing
annual costs. Option C details the costs specific to the vendor selected for the
single vendor platform project.
d. The Company received a $1.5 million grant from the State of Idaho under the
Energy Resiliency Grant Program for the foundation phase of the single vendor
platform project.
e. See the Company's Response to Request for Production No. 32(a) — Confidential
Attachment 2 for the business case for the project. As presented on page 19, the
financial analysis results indicate expected revenue requirement savings of
approximately $3 million on a net present value basis.
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 21
f. Phase one of the single vendor platform project will allow for the operation of the
SCADA devices for control during a Public Safety Power Shutoff ("PSPS"). Phase
two will integrate to the outage map and drive customer communication for any
outages, including during a PSPS event.
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 SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 22
DATED at Boise, Idaho, this 6th day of August 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 SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of August 2024, 1 served a true and correct
copy of Idaho Power Company's Response to the Seventh 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(c�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. 27' Street FAX
Boise, Idaho 83702 FTP Site
X Email peterC@richardsonadams.com
Dr. Don Reading Hand Delivered
280 Silverwood Way U.S. Mail
Eagle, Idaho 83616 Overnight Mail
FAX
FTP Site
X Email dreading(@mindspring.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 _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 SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 24
Idaho Conservation League Hand Delivered
Matthew A. Nykiel U.S. Mail
710 N. 6t" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email matthew.nykiel(Dgmail.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 17' Street, Suite 3200 darueschhoff(c)_hol land hart.com
Denver, CO 80202 tnelson(a)-hol land hart.com
awjensen _hol land hart.com
karoach(a)hollandhart.com
acleeC@hollandhart.com
mamcmillen(a-),hollandhart.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
iswier(a)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 BoiseCityAttorneyCa�cityofboise.org
ejewell cityofboise.org
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 25
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
sh u bbleCcDcityofboise.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(o-)hg.doe.gov
emily.medlyn(a-),hg.doe.gov
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 26