20240826Staff 106-112 to IPC.pdf

RECEIVED
Monday, August 26, 2024 12:28:27 PM
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 ) 13th PRODUCTION REQUEST
CAPITAL INVESTMENTS AND CERTAIN ) OF THE COMMISSION STAFF
ONGOING OPERATIONS AND ) TO IDAHO POWER COMPANY
MAINTENANCE EXPENSES )
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 9, 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.
13th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 26, 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. 106: Please provide a narrative explanation of the need, scope of work,
and other solutions considered for Budget ID "UNTY220002 -UNTY Install Satellite to Reduce
Ongoing Expenses - Preliminary Scope". Please also provide copies of the invoices for any
charges incurred for this project.
REQUEST NO. 107: Please provide a narrative explanation of the need, scope of work,
and competitive bids submitted for Budget ID `BOBN200005 —Station Perimeter Security
Fence". Please also provide copies of the invoices for any charges incurred for this project.
REQUEST NO. 108: Please provide a narrative explanation of the need, other solutions
considered, and competitive bids submitted for Budget ID `1301000304—Multifunction devices,
plotters,printers". Please explain what was done with the existing devices and provide copies of
any invoices for charges incurred for this project.
REQUEST NO. 109: Please provide an Excel workbook which identifies all software
licenses addressed under Budget ID "PLZ1150014—2024 Microsoft Licensing True-Up". For
each software, please provide the quantity of existing and newly purchased licenses, individual
purchase price, quantity assigned, and explanation for any unassigned licenses and how this
aligns with business needs since January 1, 2024.
REQUEST NO. 110: Please provide a narrative explanation of the need, scope of work,
and other solutions considered for Budget ID "CHQB 180060—IEE License Expansion 2024".
Please provide the invoices for this project.
REQUEST NO. 111: As a follow-up to Production Request No. 53 for Budget ID
"CHQB 190012 Bathroom/Core Upgrade Each Floor At CHQ",please provide the following:
13th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 26, 2024

a. Narrative explanation of the storm water damage;
b. Bids submitted;
c. All related invoices; and
d. Insurance coverage amount received by the Company and how it was applied to the
total project costs.
REQUEST NO. 112: In reference to the Company's response to Staff Production
Request No. 36,please provide normalized actual monthly sales, revenues, and billing
determinants from August 2023 through July 2024. Please treat this as an ongoing request,
supplementing it for subsequent months when actual amounts for each month are known.
DATED at Boise, Idaho, this 261h day of August 2024.
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#I3.docx
13th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 26, 2024

CERTIFICATE OF SERVICE
��Y OF AUGUST 2024
I HEREBY CERTIFY THAT I HAVE THIS � ,
SERVED THE FOREGOING THIRTEENTH 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 cr,idahopower.com E-MAIL: ttatumcidahopower.com
dwalkercidahopower.com caschenbrennercidahopower.com
mgoicoecheaallencidahopower.com mlarkincidahopower.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 c ae isg insi hg t.com
E-MAIL: elo(ct echohawk.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: dreadincmindspring com
E-MAIL: peter Larichardsonadams.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.nykielcgmail.com E-MAIL:
heusinkveld Laidahoconservation.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: peter.meier cthd.doe.gov E-MAIL: Emily.medlyn a hq.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: jswierLamicron.com HOLLAND &HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoffkhollandhart.com
tnelsonLwhollandhart.com
awjensen cthollandhart.com
karoachLchollandhart.com
aclee,hollandhart.com
mamcmillen a,hollandhart.com
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubble,c cityofboise.org
E-MAIL: ejewell(ct)cityofboise.org
boisecityattorney cc cityofboise.org
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE