20240819Staff 74-84 to IPC.pdf

RECEIVED
Monday, August 19, 2024 9:27:05 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS )
ASSOCIATED WITH INCREMENTAL ) ELEVENTH PRODUCTION
CAPITAL INVESTMENTS AND CERTAIN ) REQUEST OF THE
ONGOING OPERATIONS AND ) COMMISSION STAFF
MAINTENANCE EXPENSES ) TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY, SEPTEMBER 2, 2024.'
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0314.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 19, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 74: Attachment 1 to the Company's response to Production Request
No. 5 contains several Blanket Budget IDs with the phrase "New Business" in the title. For
example, Budget ID B08872 is titled"Capital UG New Business," and Budget ID B09900777 is
titled"Canyon UG New Business". Please answer the following questions about this group of
projects:
a. Please clarify the nature of the work the Company includes in these Blanket Budget
IDs.
b. Please explain how the "June YTD Amount" is calculated for each work order. Does
the total include only Company expenditures, or does it net the expenditures with
standard allowances and contributions in aid of construction("CIAC")?
c. If it represents only expenditures,please explain how the Company nets the
expenditures with allowances and CIAC. Please provide an example.
d. If it represents the net expenditure,please provide documentary evidence showing the
underlying netting of expenditures for the following work orders:
i. 27584162—Rosti Farms #5;
ii. 27587029—Cresta Del Sol#3; and
iii. 27603302—Red River Logistics Center.
e. Please explain the purpose of the "New Business" Budget IDs with"FC" in the title.
REQUEST NO. 75: Please provide a narrative explanation of the need and the scope of
work for Budget ID BCW0240001 "NAS Storage Systems". Please provide the underlying
invoices for this project.
REQUEST NO. 76: Please provide a narrative explanation of the need and the scope of
work for Budget ID 1301100010 "Network Infrastructure Lifecycle". Please provide the
underlying invoices for this project.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 19, 2024

REQUEST NO. 77: Please provide a narrative explanation of the need and the scope of
work for Budget ID PLZ1230013 "Outage Alert Auto Enrollment". Please provide the
underlying invoices for this project.
REQUEST NO. 78: For Blanket Budget ID B00900517 "IPC Companywide Vehicle
Purchases—Current yr budget", please provide a narrative explanation of the need and the scope
of work, along with supporting invoices, for the following work orders:
a. Work order 27603505 "Replace 8379 with 8542—BI 38155";
b. Work order 27603529 "Replace 6762 with 6998 —BI 38022"; and
c. Work order 27642615 "New Unit 7011 Replaced 7538 CLRS 2024-600119".
REQUEST NO. 79: Please provide the Certificate of Mechanical Completion for
Capital Project BID FRBS230001 - 60 MW Franklin BESS. If the guaranteed Mechanical
Completion date shown in the Build Transfer Agreement -Appendix B as amended April 26,
2024, was not met, please include the actual completion date, associated liquidated damages that
incurred for that milestone, and how the damages will be credited in customer rates.
REQUEST NO. 80: Please clarify if Capital Project BID FRBS230001 - 60 MW
Franklin BESS has achieved the Substantial Completion milestone shown in the Build Transfer
Agreement -Appendix B as amended April 26, 2024, and documentation of the date that Idaho
Power Transmission provided backfeed power to the project.
a. If so,please provide the Form of Substantial Completion Funds Flow Statement; or
b. If not, please provide new estimated dates for the remaining unmet milestones as
outlined in the Build Transfer Agreement-Appendix B as amended April 26, 2024,
associated liquidated damages expected to be incurred by the new estimated dates,
and how the damages will be credited in customer rates.
REQUEST NO. 81: Please provide documentation verifying the date each of the
following milestones were met for Capital Project BID HMWY230003 - 36 MW Hemingway
BESS. If the guaranteed date shown in IDP0061 —Hemingway Expansion- Exhibit D was not
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 19, 2024

met,please include the actual completion date, associated liquidated damages incurred for that
milestone, and how the damages will be credited in customer rates.
a. Delivery of Collection Segment;
b. Delivery of PCS/MVT Sets; and
c. Delivery of Energy Segments.
REQUEST NO. 82: Please clarify if Capital Project BID HMWY230003 - 36 MW
Hemingway BESS has achieved the Commissioning milestone.
a. If so,please provide the Form of Commissioning Certificate; or
b. If not, please provide new estimated dates for all remaining unmet milestones as
outlined in IDP0061 —Hemingway Expansion - Exhibit D of the Battery Energy
Supply Agreement, associated liquidated damages expected to be incurred by the new
estimated dates, and how the damages will be credited in customer rates.
REQUEST NO. 83: Please provide documentation verifying the date each of the
following milestones were met for Capital Project BID BMSU220002 40 MW Black Mesa
BESS. If the guaranteed date shown in IDP0090—Black Mesa- Exhibit D was not met,please
include the actual completion date and associated liquidated damages incurred for that milestone,
and how the damages will be credited in customer rates.
a. Delivery of Collection Segment;
b. Delivery of PCS/MVT Sets; and
c. Delivery of Battery Segments.
REQUEST NO. 84: Please clarify if Capital Project BID BMSU220002 40 MW Black
Mesa BESS has achieved the Commissioning milestone.
a. If so,please provide the Form of Commissioning Certificate; and
b. If not, please provide new estimated dates for all remaining unmet milestones as
outlined in IDP0090—Black Mesa- Exhibit D of the Battery Energy Supply
Agreement, associated liquidated damages expected to be incurred by the new
estimated dates, and how the damages will be credited in customer rates.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 AUGUST 19, 2024

DATED at Boise, Idaho, this 19th day of August 2024.
r
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#1I.docx
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 AUGUST 19, 2024

CERTIFICATE OF SERVICE
h
I HEREBY CERTIFY THAT I HAVE THIS `ZDAY OF AUGUST 2024,
SERVED THE FOREGOING ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-07,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: lnordstrom(Lidahopower.com E-MAIL: ttatumLcyidahopower.com
dwalkerLaddahopower.com caschenbrenner,c,idahopower.com
mgoicoecheaallen idahopowCr.com mlarkin.ddahopower.com
dockets c idahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance�ae i sinsight.com
E-MAIL: eloLechohawk.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreading c;mindsprina.com
E-MAIL: etp ers�crichardsonadams.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nvkiel.c gmail.com E-MAIL:
heusinkveld(��idahoconservation.org
PETER MEIER EMILY W MEDLYN
US DEPT OF ENERGY US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585 WASHINGTON DC 20585
E-MAIL: ep ter.meier!(Lho.doe.gov_ E-MAIL: Emily.medlvn(Lthq.doe.gov
CERTIFICATE OF SERVICE

JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 KRISTINE A.K. ROACH
E-MAIL: jswier��umicron_ �tisz� HOLLAND &HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoffchollandhart.com
tnelsonchollandhart.com
aw'ensenchollandhart.com
karoach;thollandhart.com
aclee c hollandhart.com
mamemillen( ) ollandhart.co m
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubbleccitvofboise.or
E-MAIL: ejewell(Lcitvofboise.ora
boisecitvattorneyc cityofboise.oro
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE