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HomeMy WebLinkAbout20240815Staff 34-50 to IPC.pdf RECEIVED a-10AM F"A IC UTILITIES COMMISSION LISA D. NORDSTROM Lead Counsel Inordstrorn(Widahopower.com August 15, 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 Sixth 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 some of the attachments to Request Nos. 35, 36, 43, 44, and 48 to Idaho Power Company's Response to the Sixth Production Request of the Commission Staff dated August 15, 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 15th 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 mgoicoecheaallen(abidahopower.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 SIXTH 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 Sixth Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated July 25, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 1 REQUEST FOR PRODUCTION NO. 34: Please provide a detailed description of the Company's revenue normalization method including the process for weather normalization. In the description, please identify any changes in the method from Case No. IPC-E-23-11. Please provide any workpapers and models supporting the revenue and weather normalization methods, in electronic format with links intact and formulae enabled. In addition, please provide all model outputs including model coefficients, statistics, and residuals. RESPONSE TO REQUEST FOR PRODUCTION NO. 34: At a high level, the Company's 2024 test year normalized revenue forecast is calculated by multiplying the forecast weather normalized energy sales by base rates in effect as of 1/1/2024. The methodology for forecasting normalized revenue for the 2024 Limited Issue Rate Case did not change from the Company's 2023 General Rate Case ("GRC") filing. Please see the Company's response to Request No. 35 for additional information on the 2024 test year revenue forecast model. Lastly, please see the following attachments supporting the Company's weather normalization process: - Attachment 1 — Weather Normalization Methodology - Attachment 2 — Irrigation Weather Adjustment Model — Canyon - Attachment 3 — Irrigation Weather Adjustment Model — Capitol - Attachment 4 — Irrigation Weather Adjustment Model — Eastern - Attachment 5 — Irrigation Weather Adjustment Model — Oregon - Attachment 6 — Irrigation Weather Adjustment Model — Payette - Attachment 7 — Irrigation Weather Adjustment Model — Southern - Attachment 8 — Oregon Commercial Weather Adjustment Model - Attachment 9 — Oregon Residential Weather Adjustment Model - Attachment 10 — System Commercial Weather Adjustment Model - Attachment 11 — System Residential Weather Adjustment Model - Attachment 12 — Heating Degree Day and Cooling Degree Day Calculation IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2 The response to this Request is sponsored by Jordan Prassinos, Principal Economist and Load Forecasting Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 35: Please provide a detailed description of the Company's method for forecasting energy sales and revenue in 2024. In the description, please identify any changes in the method for forecasting load growth from Case No. IPC-E-23-11. Please provide any workpapers or models supporting the forecasting method, in electronic format with links intact and formulae enabled. In addition, please provide all model outputs including model coefficients, statistics, and residuals. RESPONSE TO REQUEST FOR PRODUCTION NO. 35: Please see Attachment 1 provided with this response for a description of the methodology used to develop the 2024 test year sales forecast. There were no methodological changes from the Company's 2023 GRC filing. In addition, please see Attachments 2-9 provided with this response for the load forecasting model output data. - Attachment 1 — Load Forecasting Methodology - Attachment 2 — Commercial Manufacturing - Attachment 3 — Commercial Services - Attachment 4 — Industrial Manufacturing - Attachment 5 — Industrial Services - Attachment 6 — Irrigation - Attachment 7 — Residential Customer Forecast - Attachment 8 — Residential Use Per Customer - Attachment 9 — Regression Mnemonic Lastly, please see Confidential Attachment 10 for the 2024 test year revenue forecast workbook. Below is a description of the hard-coded inputs contained in the "Input" tab: - Rows 13 — 395: 2023 actual usage and billing data - Rows 401 — 450: 2023 actual customer counts - Rows 457—497: 2024 test year forecast customer counts (methodology described in Attachment 1) - Rows 505 — 560: 2024 test year forecast energy sales (methodology described in IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 4 Attachment 1) - Rows 565 — 570: 2024 test year forecast special contract demand - Rows 578 — 918: base rates effective 1/1/2024 The response to this Request is sponsored by Jordan Prassinos, Principal Economist and Load Forecasting Manager, and Jessi Brady, Senior Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 5 REQUEST FOR PRODUCTION NO. 36: Please provide normalized 2024 actual retail sales revenue and billing determinants for the months of January through June 2024. Please provide all workpapers used to determine the normalized 2024 actual retail sales revenue and billing determinants, in electronic format with links intact and formulae enabled. RESPONSE TO REQUEST FOR PRODUCTION NO. 36: Please see the confidential attachment for normalized sales, revenue, billing determinants, and associated workpapers for January — June 2024. Please note that this is a mid-year approximation, and it is subject to change when the final weather models are developed. - Green tabs contain the finalized requested data. - Red tabs contain hard-coded 2024 actuals data. - Blue tabs organize data from the red tabs. The response to this Request is sponsored by Jessi Brady, Senior Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 6 REQUEST FOR PRODUCTION NO. 37: Please explain and reconcile the $5,442,401 difference between the $9,954,229 January adjusted closing amount contained in cell k:84, Tab: "Elec Plant In Service," and the sum of amount $9,951,314 in cell c:44, Tab: "Capital WO Closings < $8M" and the amount $5,445,316 in cell G:19, Tab: "Capital WO Closing > $8M," having a total of $15,396,630, all of which are contained in workpaper "Staff No. 3 Attachment 3 — Larkin Workpaper 3 — Incremental Plant Determination.xlsx." Please provide any documents or workpapers to explain the difference. RESPONSE TO REQUEST FOR PRODUCTION NO. 37: The $9,954,229 January adjusted closing amount contained in cell k:84, tab "Elec Plant in Service," reflects actual plant closing activity for the month and is the amount that was used in the 2024 Limited Issue Rate Case filing. The combined total of $15,396,630 shown in c:44, tab: "Capital WO Closings < $8M" and cell g:19, tab: "Capital WO Closing > $8M is not reflective of amounts included in the Company's request in this case. This value reflects the projected January 2024 plant closings utilizing the methodology discussed in Mr. Larkin's testimony, but as discussed above, actual plant closings for January 2024 were available at the time this filing was prepared. Therefore, the Company utilized these actual values rather than projected amounts for this month. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 7 REQUEST FOR PRODUCTION NO. 38: In Larkin's direct testimony, page 13, he states, "the intent of the incremental revenue requirement request is to determine the amount of incremental revenue necessary to account for increases to capital and O&M Labor between the results of the 2023 Stipulation and expectation for 2024." Please reconcile the starting point for incremental 2024 capital between the 2023 GRC Settled amount of $6,323,823,741 contained in cell C:78, Tab "Incremental Plant," and the $6,571,067,568 amount contained in cell G:84, Tab: "Elec Plant In Service" in workpaper "Staff No. 3 Attachment 3 — Larkin Workpaper 3 — Incremental Plant Determination.xlsx." Please include any documents or workpapers to illustrate your explanations. RESPONSE TO REQUEST FOR PRODUCTION NO. 38: Please see the table provided in the attached Excel file containing a reconciliation of the figures that comprise the incremental net plant requested for recovery in this case. As noted in the above- referenced excerpt from Mr. Larkin's testimony, the incremental request in this case is comprised of the difference between amounts currently reflected in rates from the stipulated result of Case No. IPC-E-23-11 ("2023 GRC") and expected plant closings as of year-end 2024. As detailed in the attached Excel file, the settled plant amount from the 2023 GRC was $6,323,823,711, as compared to an actual year-end 2023 plant balance of$6,571,067,568. The difference in these values is $247,243,827. Next, expected 2024 plant closings of $717,410,173 were layered onto this figure, net of expected 2024 retirements of $104,287,453, for a net total of $613,122,721. The total incremental plant requested for recovery in this case is $860,366,548, which is the sum of the net difference between the settled 2023 GRC plant amount and actual year-end 2023 plant amounts ($247,243,827), projected 2024 plant closings ($717,410,173), less projected 2024 IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 8 retirements (-$104,287,453). This number can also be calculated by subtracting the settled 2023 GRC plant amount of $6,323,823,711 from the projected year-end 2024 plant balance of $7,184,190,289. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 9 REQUEST FOR PRODUCTION NO. 39: Regarding the Company's determination of incremental 2024 capital, Company Witness Larkin states, "The Company then estimated 2024 capital closings utilizing the same general method applied in the 2023 GRC (i.e, by bifurcating expected plant closing into projects above and below $8 million) ...." Larkin Direct at 14 (emphasis added). Please explain why and when the Company selected the $8 million threshold for tracking individual projects. The $8 million threshold captures approximately $323 million of the forecasted $860 million of incremental plant in service. Please estimate the project dollar threshold that would be necessary to capture 80 percent of the highest cost projects (i.e. approximately $688 million) out of the incremental plant in service being sought for recovery in this case. Please provide a worksheet with formulae intact showing how this was estimated. RESPONSE TO REQUEST FOR PRODUCTION NO. 39: The $8 million threshold was first implemented by Idaho Power in January 2023 and was presented in the 2023 GRC. At the time of preparing the 2023 GRC, the project threshold for board approval was $15 million; however, this threshold would have resulted in only four projects being presented. The Company determined a lower threshold — $8 million — would provide a reasonable representation of the Company's large projects during the test year. Idaho Power maintained that threshold for the 2024 Limited Issue Rate Case. Idaho Power projected total 2024 plant closings to be $717 million (see Larkin Workpaper 3 — Incremental Plant Determination.xlsx tab "Elec Plant In Service"). The projects over $8 million represent 45 percent of the total. Due to the methodology used to develop the forecast of projects under $8 million Idaho Power is unable to identify individual projects in this forecast and is therefore unable to determine what the dollar IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 10 threshold would need to be to capture 80 percent of the total plant closings forecast. However, Idaho Power evaluated 2023 actual plant closings and determined that Budget IDs over $1.6 million accounted for 80 percent of the actual 2023 plant closings. Please see Response to Staff Request No. 39 —Attachment. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 11 REQUEST FOR PRODUCTION NO. 40: Company Witness Larkin describes the method the Company used to forecast the 2024 plant closing for projects less than $8 million. Larkin Direct at 15. Please provide the worksheets (with formulae enabled) the Company used to calculate this forecast. RESPONSE TO REQUEST FOR PRODUCTION NO. 40: Please see Response to Staff Request No. 40 — Attachment. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 12 REQUEST FOR PRODUCTION NO. 41: Please provide a detailed comparison of actual plant closings for projects to forecasted plant closings for 2023 by project/budget ID. For each project, please include: (a) budget ID or project unique identifier; (b) project name; (c) project description; (d) project type; (e) planned and actual in-service dates; (f) budgeted cost vs actual cost, and whether the project was completed by Company or Contractor. RESPONSE TO REQUEST FOR PRODUCTION NO. 41: Please see Response to Staff Request No. 41 —Attachment. Due to the methodology used to develop the 2023 forecast of projects under $8 million, Idaho Power cannot identify individual projects in this forecast and is therefore unable to provide a detailed comparison at the project level. For projects under $8 million Idaho Power is providing a detailed comparison of forecasted plant closings versus actual plant closings by month, plant account and plant type. Year-to-date differences between actual plant closings and forecast plant closings can be reflective of monthly timing differences within the test period and not an indication of the accuracy of the full-year forecast. To illustrate this point, it is important to consider that actual electric plant in service ("EPIS") on December 31, 2023, was $6,571 million (see Larkin Workpaper 3, cell g:84, tab "Elec Plant in Service") which was $18.3 million higher than the forecasted EPIS balance of $6,553 million used in the 2023 general rate case rate base determination (see P. Jeppsen Exhibit No. 22, page 15, row 13, column 11, Case No. IPC-E-23-11) due to lower than projected plant retirements, providing evidence that Idaho Power's EPIS forecast methodology overall provided a conservative estimate. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 13 However, actual plant closings under $8 million were $4.7 million higher than forecasted. Actual plant closings over $8 million were $27.6 million lower than forecasted for a total of $22.9 million lower than forecasted. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 14 REQUEST FOR PRODUCTION NO. 42: Please provide a detailed description of the Company's method for developing, managing, executing, and completing Capital Projects that ensures that the projects are procured or built in a least cost manner. Please provide a copy of the Company's policies and procedures documenting the process. RESPONSE TO REQUEST FOR PRODUCTION NO. 42: 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 Idaho Power Board of Directors. Because Idaho Power has an obligation to serve and most projects are required to maintain reliability or serve load, there is not one standard way the Company evaluates each project. Individual facts and circumstances determine how projects are executed in a prudent manner. Additionally, Idaho Power has a Procurement Policy and a Procurement Standard, provided as the Response to Request for Production No. 20(c) — Confidential Attachment 17, in place to provide guidance for procurement activities including competitive bidding practices and to help ensure that procurement decisions are made based on the best overall value to Idaho Power and its customers. In addition, IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 15 many goods are stock items in Idaho Power warehouses and are not bid through a Request for Proposal ("RFP") on a project basis, but rather as wholesale purchases. 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 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 IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 16 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 overwrite previous plans. Baseline schedule comparisons to actual schedule delivery is 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 constantly 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 constantly evaluated and monitored within the overall portfolio of projects. The Company's efforts ensure all projects are completed in a least- cost, least-risk manner. 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 17 REQUEST FOR PRODUCTION NO. 43: Please provide a table of each Idaho program category for Wildfire Mitigation ("WM") operational and maintenance expenses for 2023 through 2024 similar to the Company's 2024 Wildfire Mitigation Plan ("WMP") - Table No. 7. For 2023 and 2024, please provide the forecasted costs and actual cost of each program category. Please identify any proforma adjustments for 2024 and any amount deferred. Additionally, please explain any discrepancies between the forecasted costs estimate and the actual expenses. RESPONSE TO REQUEST FOR PRODUCTION NO. 43: Please note that Idaho Power has not requested a change to the allowed deferral items or the base amounts for insurance or vegetation management in the 2024 Limited Issue Rate case. Attached is an updated schedule, "Attachment 1 — Response to Staff Request No. 43," in the same format as the 2024 Wildfire Mitigation Plan ("WMP") - Table No. 7. The table has been updated with 2023 actual costs for each program category, and a current forecast for 2024 costs. In addition, discrepancies have been explained in the attached table. As of YTD June 30, 2024, Idaho Power has deferred $7,000,519. The 2024 deferral included incremental vegetation management and insurance over the 2022 base, and the cost of pilot programs for aerial inspection and covered wire. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 18 REQUEST FOR PRODUCTION NO. 44: Please provide a table of each Idaho program category for all WM capital expenses for 2023 through 2024. For 2023 and 2024, please provide the forecasted cost and actual cost of each program category. Please identify any proforma adjustments for 2024. Additionally, please explain any discrepancies between the forecasted cost estimate and the actual expenses. RESPONSE TO REQUEST FOR PRODUCTION NO. 44: Please refer to "Confidential Attachment 1 — Response to Staff Request No. 44" for a table of WM capital expenditures for 2023 through June 2024. After budget update 3, the estimate for weather stations as part of Budget ID CHQB220022 increased to $1.5 million. The Company is accelerating the installation of weather stations throughout the service area in wildfire risk zones, with a goal of installing 85 by the end of the year to gain situational awareness for Public Safety Power Shutoff ("PSPS") decision making. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 19 REQUEST FOR PRODUCTION NO. 45: Please provide all funding sources that the Company has explored and received for its WM capital projects since the last rate case. Please provide supporting documentation including applications, funding award notifications, disbursement, and demonstrate where funds were applied to in this rate case. RESPONSE TO REQUEST FOR PRODUCTION NO. 45: Idaho Power is actively reviewing and seeking grants in support of infrastructure and resiliency. The Company continues to partner with the States of Idaho and Oregon as they support the DOE's Formula Grant for Preventing Outages and Enhancing the Resilience of the Electric Grid, 40101(d). It is the Company's intent to continue to apply when/if states open application windows for additional rounds of funding. There are no capital projects in-service that the company has received grant funding for related to Wildfire Mitigation. 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 20 REQUEST FOR PRODUCTION NO. 46: Please describe any occurrences where the Company undergrounded any transmission and/or Idaho distribution lines for WM since the last rate case. Please answer the following: a. Please provide the Company's undergrounding project guidelines; b. Please explain the location selection process for undergrounding; and c. For any completed undergrounding project, please provide a supporting worksheet detailing the initial budget, the actual cost, project start date, date in-service, location (inside or outside of a Red Risk Zone), and a cost-benefit analysis. RESPONSE TO REQUEST FOR PRODUCTION NO. 46: No underground projects associated with the Wildfire Mitigation Plan have been completed since the 2023 GRC. a. Guidelines used for considering candidate circuits for underground conversion include the following: • Wildfire risk modeling and quantification, showing areas having a high risk of wildfire spread and structure impacts. • Fire history where overhead powerlines may be susceptible to repeated wildfire events over their lifetime. • Areas with minimal egress or evacuation routes. • Areas with limited ingress and/or fire suppression resources. • Circuits have a high likelihood of ignition due to risk drivers such as vegetation contact, contact from foreign objects, lightning, and equipment failure. • Areas with historic weather patterns that increase the potential of repeated Public Safety Power Shutoff (PSPS) events. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 21 • Areas within wildfire risk zones that have access issues or difficulties in performing ongoing inspections or maintenance. • Feedback from local officials or fire agencies on topography and fuels in areas conducive to rapid fire spread that may impact highly valued resources, watersheds, or critical facilities. b. Please see the Company's response to Part a. c. Please see the Company's response to 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 22 REQUEST FOR PRODUCTION NO. 47: Please describe any occurrences where the Company installed covered conductor lines for WM in Idaho. Please answer the following: a. Please provide the Company's covered conductor project guidelines; b. Please explain the location selection process for installing covered conductor; and c. For any completed covered conductor projects, please explain the need, location installed (inside or outside of a Red Risk Zone), the need, the actual cost, the total miles installed, and any cost-benefit analysis completed prior to installation. RESPONSE TO REQUEST FOR PRODUCTION NO. 47: The Company has not installed covered conductor on the primary distribution system and continues to work through the evaluation and implementation phase of the pilot. Plans are in place to install approximately one mile of covered conductor in Pocatello in September 2024 as part of a field trial to validate design complexities and installation methods. a. The Company continues to work through evaluating the benefits of covered conductor and building implementation and training plans for field personnel and Distribution Designers. Guidelines for the locations where covered conductor will be deployed are still under development and will be based on lessons learned during the field trial. b. Currently, covered conductor is only installed in the Company's Skills Training Facility, off Franklin Road in Boise to provide a controlled and safe location for hands on evaluations, training, and tool use. c. To date, there have not been any completed covered conductor projects on the system. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 23 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 24 REQUEST FOR PRODUCTION NO. 48: On page 23 of the 2024 WMP, the Company stated it issued a RFP in 2023 for a wildfire detection camera pilot project. Please explain if the Company has awarded the RFP to a bidder to date. If so, please provide the following: a. A copy of the selected bid; b. The status of the wildfire detection cameras pilot; c. A total number of cameras installed; and d. The total costs of installation. RESPONSE TO REQUEST FOR PRODUCTION NO. 48: After a review of the RFP, the Company selected AlertWest as the primary supplier and software vendor for wildfire detection cameras. Installations are scheduled to begin in the summer of 2024. a. Please see the following confidential attachments for RFP details: • Response to Staff Request No. 48 — Confidential Attachment 1 - Wildfire Camera RFI • Response to Staff Request No. 48 — Confidential Attachment 2 - Wildfire Detection Camera RFI Capabilities • Response to Staff Request No. 48 — Confidential Attachment 3 - AlertWest Pilot Proposal • Response to Staff Request No. 48 — Confidential Attachment 4 - AlertWest Cost Breakout • Response to Staff Request No. 48 — Confidential Attachment 5 - Pano Pilot Proposal IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 25 b. Year to date, the Company has performed tower/site analysis and selected six locations for camera installation in 2024. c. No cameras have been installed as of 7/29/2024. d. While no costs have been incurred yet, the Company estimates that each location will cost approximately $18,000 on average for camera purchase and installation. 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 26 REQUEST FOR PRODUCTION NO. 49: How does the Company rate contractors based on past experience? RESPONSE TO REQUEST FOR PRODUCTION NO. 49: Idaho Power reviews contractors' experience as applicable, and/or on a per project basis as part of the RFP process. Depending on the services/materials being procured (i.e., professional services, construction) this review may include such items as project specific experience, applicable certifications, licenses, safety records, work plans, or qualifications to ensure the contractor is able to adequately perform the services, or provide the materials requested. This review varies based on the nature of work being performed, which informs the importance of past experience (e.g., level of complexity, level of specialization required, etc.). 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 27 REQUEST FOR PRODUCTION NO. 50: What is the Company's criteria for rating contractors? RESPONSE TO REQUEST FOR PRODUCTION NO. 50: Idaho Power monitors contractor performance based on several key factors to ensure quality work, reliable service, and fair and competitive pricing. These key performance factors may include items such as safety events, competitive pricing, adherence to contract terms and deliverables, schedule adherence and ability to meet deadlines, on-time material delivery, quality of services or materials provided, and supplier corrective actions. Overall, the Company's rating criteria is specific to the category or type of work, material or service the contractor is providing. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. DATED at Boise, Idaho, this 15th 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 28 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 15th day of August 2024, 1 served a true and correct copy of Idaho Power Company's Response to the Sixth 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 29 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 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 aclee(a)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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 30 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 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(a�hg.doe.gov emily.medlyn(o)_hg.doe.gov Stacy Gust, Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 31