20240903IPC to Staff 74-84_Redacted.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
September 3, 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
Eleventh 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
RECEIVED
Tuesday, September 3, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
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. 74,75, 76, 77, and 78 to Idaho
Power Company’s Response to the Eleventh Production Request of the Commission
Staff dated September 3, 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 3rd day of September 2024.
LISA D. NORDSTROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 1
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: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS
ASSOCIATED WITH INCREMENTAL
CAPITAL INVESTMENTS AND
CERTAIN ONGOING OPERATIONS
AND MAINTENANCE EXPENSES.

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CASE NO. IPC-E-24-07

IDAHO POWER COMPANY’S
RESPONSE TO THE ELEVENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Eleventh Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated August 19, 2024, herewith supplements the
following information:
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 2
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 74:
a. New Business budget IDs are used to track the capital investments in infrastructure
to support customer requests for electric service that require the installation,
alteration, relocation, removal, or attachment of Company owned facilities (i.e.,
requests governed by Rule H of Idaho Power’s tariff). Examples could include new
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 3
subdivisions or customer requested line extensions. These budget ID's capture
the costs of material, labor, outside services, vehicles, general overheads, other
related charges, and credits (Contributions in Aid of Construction (“CIACs”),
Terminal Facilities, Unusual Conditions, etc.). Each region has budget IDs for New
Business (separated by Overhead and Underground).
b. For requests received under Rule H, the Company prepares a Cost Quote that
must be paid for by the customer before construction begins. That Cost Quote is
based on a work order cost estimate, is net of Allowances, and represents the
contribution required from the customer.
The “June YTD Amount” represents all charges and credits that have accumulated
on the work order through June 2024. The work orders include all costs net of any
payments received from the customer.
c. Allowances are defined in Rule H as “the portion of a Word Order Cost’s Terminal
Facilities funded by the Company.” Allowances are not a “credit” on the work order
because they are expenditures that were not offset by a CIAC.
d. Please see Response to Staff Request No. 74 – Confidential Attachment for a
detail of charges and credits for each of the work orders listed in d. i. through iii.
above. Payments received from customers on New Business work orders are
recorded in the following Detailed Cost Elements (“DCEs”):
411 Vested Interest Payments
412 CIACs
413 Terminal Facilities, Taxable
414 Terminal Facilities, Non-Taxable
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 4
457 Design Engineering Fees
e. “New Business” Budget IDs with “FC” in the title refer to work orders used to track
the capital investments in infrastructure to support Facilities Charge customers’
requests for electric service that require the installation, alteration, relocation,
removal, or attachment of Company owned facilities beyond the Point of Delivery
for Schedule 9 or Schedule 19 customers. The Company’s Facilities Charge
service is provided under IPUC No. 30, Tariff No. 101, Rule M, Facilities Charge
Service.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 75: Please provide a narrative explanation
of the need and the scope of work for Budget ID BCWO240001 “NAS Storage Systems”.
Please provide the underlying invoices for this project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 75: The following provides
the need and scope of work for Budget ID BCWO240001, the Network Attached Storage
(“NAS”) Systems:
SCOPE: The Dell EMC Isilon primary storage array(s) store Idaho Power
unstructured data, including user “home” directories, department files, and file share
infrastructure for supporting critical upstream applications. There are two arrays tied to
this Budget ID: one at Idaho Power’s primary production datacenter is replicated to
another at the Company’s secondary failover/disaster recovery site. These two arrays
support nearly a petabyte of storage between the two locations.
NEED: The older primary storage arrays came to the end of their life per the vendor
on March 1, 2024, with no options to extend maintenance. These arrays were purchased
in 2016 and had been in service their entire useful life of seven years, including an
additional year while Idaho Power negotiated the next replacement. This expenditure
purchased new arrays to ensure the continuity of the business purpose of storing and
providing the vast amounts of data provided by these NAS systems.
INVOICES: Please see the Response to Staff Request No. 75 – Confidential
Attachment for the invoice associated with the NAS system. Note, the purchase of
hardware and most software includes mandatory software and maintenance costs;
therefore, the invoice includes both capital and operations and maintenance (“O&M”)
expenses.
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 6
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 76: Please provide a narrative explanation
of the need and the scope of work for Budget ID B01100010 “Network Infrastructure
Lifecycle”. Please provide the underlying invoices for this project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 76: The following provides
the need and scope of work for Budget ID B01100010, the Network Infrastructure
Lifecycle project:
SCOPE: The network infrastructure lifecycle project replaces corporate network
physical hardware that is approaching the end of its useful life, which is between five and
seven years depending on the asset.
NEED: The primary items replaced are Cisco switches and routers, associated
powers supplies and modules, and the embedded management software licensing to use
them. In 2024, 57 switches and 18 routers were at the end of their life and have been
replaced. These technologies allow the Company to maintain data and voice connectivity
amongst all Idaho Power offices, remote sites and Operations Centers.
INVOICES: Please see the Response to Staff Request No. 76 – Confidential
Attachments 1 through 4 for the invoices associated with the network infrastructure
lifecycle project. Note, the purchase of hardware and most software includes mandatory
software and maintenance costs; therefore, the invoices include both capital and O&M
expenses.
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 8
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 77: The following provides
the need and scope of work for Budget ID PLZ1230013, the Outage Alert Auto Enrollment:
NEED: Idaho Power is focused on continually improving the customer experience.
Recent customer feedback, survey results, research, and benchmarking have
consistently indicated a need to increase outage-related communication. Customers are
asking to receive consistent and timely updates on outages.
SCOPE: This project was targeted on enrolling all qualifying residential customers
(customers with a mobile phone or email address on file that had not previously opted
out) in automated outage alerts. Prior to the completion of this project, customers could
only enroll in outage alerts through the Company’s My Account web and mobile
applications. Enabling the ability to enroll customers without a My Account profile required
a re-design of the underlying data structure; conversion of existing data to the new
structure; development of new alerts for all existing alerts (outage, payment, past due,
and bill threshold); a new structure that allowed for enrolling of qualifying customers;
changes to the My Account web and mobile applications; development of an internal
application to provide Customer Service Representatives the ability to manage customer
contact, preference, and enrollment information; scaling and tuning of enterprise
messaging services to ensure message delivery met performance requirements; and
testing and implementation of all referenced changes.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 9
INVOICES: Please see the Response to Staff Request No. 77 – Confidential
Attachments 1 – 9 for the invoices associated with contract payments to the vendor. All
other costs were associated with internal labor or Allowance for Funds Used During
Construction (“AFUDC”).
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 10
REQUEST FOR PRODUCTION 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”.
RESPONSE TO REQUEST FOR PRODUCTION NO. 78: In general, Idaho Power
has the following criteria for replacing vehicles though the targets are subject to change
based on usage and current business needs:
 1000 series – 165,000 miles or 20 years
 4000 series – gas engine – 165,000 miles or 20 years
 4000 series – diesel engine – 200,000 miles or 20 years
 6000 series – service buckets – 200,000 miles or 10,000 hours
 6000 series – large buckets and diggers – 15,000 hours or 18 years
 5000 Side-by-Side and Utility Task Vehicles – 10 years or 1,500 hours
 5000 Snowmobile Cloud Seeding – 175 hours and they are cascaded into lower
use applications.
 5000 Crew Snowmobile – 350 hours or 10 years
 7000 series – small – 200,000 miles or 20 years
 7000 series – over the road large – 500,000+ miles or 25 years
 8000 series (over the road) – 15,000 hours or 25 years
 8000 series (off road large) – 10,000 hours 18 years

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 11
 8000 series (off road small) – 5,000 hours 18 years
 Boats – 20 years
a. Work order 27603505 is associated with the replacement of Unit 8379 with Unit
8542. The new vehicle, Unit 8542, is a truck mounted four drum line puller, with
approximately 15,000 feet of line for each reel, allowing for pulls of four spans for
up to three miles of line. See Response to Staff Request No. 78 – Attachment 1
for a picture of Unit 8542. This unit replaced Unit 8379, see the Response to Staff
Request No. 78 – Attachment 2 for a picture of Unit 8379. Unit 8379 had previously
replaced Unit 8156, which included a critical piece of equipment, a puller. Idaho
Power owned a 1970 Pengo puller that was originally mounted on a 1974 truck,
see the Response to Staff Request No. 78 – Attachment 3, but in early 2005 was
remounted on a used 1998 Kenworth the Company had purchased. With a puller
over 50 years old and a truck that was 26 years old, Unit 8379 was approaching
its end of life. See Response to Staff Request No. 78 – Confidential Attachments
4-7 for a quote for Unit 8542, detailing the equipment parts and accessories, and
the final invoices for the unit.
b. Work Order 27603529 is associated with the replacement of Unit 6762 with Unit
6998. Vehicle 6762 was a 2009 Terex digger derrick that averaged 980 hours a
year in use over its life, see Response to Staff Request No. 78 – Attachment 8 for
a picture of Vehicle 6762. It was replaced in 2023 by Unit 6998 which is a 2023
Altec D3060 E digger derrick, see Response to Staff Request No. 78 - Attachment
9. Idaho Power was having ongoing reliability issues with Unit 6762 due to the
hours on the vehicle. The decision to replace the vehicle with the Altec digger was

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 12
to avoid the tear down in year 7 required by the Terex diggers. Please see
Response to Staff Request No. 78 – Confidential Attachment 10 for the Unit 6998
Altec invoice.
c. Work order 27642614 is associated with the replacement of Unit 7538 with Unit
7011. Unit 7538, see Response to Staff Request No. 78 – Attachment 11 for a
picture of the unit, played a crucial role in the Company’s ability to haul and place
transformers, but, at 31 years old, was becoming unreliable. Unit 7011, a picture
of the unit is included in the Response to Staff Request No. 78 – Attachment 12,
will allow for the hauling of large transformers without the use of a trailer, allows
for maneuvering into tighter places for the placement of transformers, and has a
rear mount crane which provides Idaho Power the ability to haul a trailer, and to
load and unload without additional equipment. See Response to Staff Request No.
78 – Confidential Attachments 13-15 for a quote for Unit 7011, detailing the
equipment parts and accessories, and the final invoices for the unit.
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 13
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 79: Please see Response
to Staff Request No. 79 – Attachment 1 for the Build Transfer Agreement (“BTA”)
Certificate of Mechanical Completion for the 60 megawatt (“MW”) Franklin Battery Energy
Storage System (“BESS”). Mechanical completion was achieved on April 5, 2024, ahead
of the Guaranteed Mechanical Completion Date of April 7, 2024, in accordance with
Appendix B of the Build Transfer Agreement dated as of January 20, 2023, by and
between Idaho Power Company and Duke Energy Renewables Solar, LLC, as amended
April 26, 2023 (“Franklin BESS BTA”). There are no liquidated damages attributable to
this milestone.
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 14
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 80:
a. Capital Project BID FRBS230001, the 60 MW Franklin BESS, has not achieved
Substantial Completion. However, please see Response to Staff Request No. 80
– Attachment 1 for documentation supporting the backfeed date of May 2, 2024.
b. Guaranteed Substantial Completion Date is anticipated by August 31, 2024, with
Final Acceptance in September 2024. Liquidated damages will apply but the value
is unknown until the project is substantially complete and the parties agree to the
delay damages and the various obligations governed by the Build Transfer
Agreement and the Engineering, Procurement and Construction Agreement. Any
liquidated damages assessed will be applied as a credit to net power supply
expenses and therefore will flow back to customers through the Power Cost
Adjustment mechanism (“PCA”).

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 15
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 16
REQUEST FOR PRODUCTION 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 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 81:
a. See Response to Staff Request No. 81 – Attachment 1 which includes the Bill of
Lading identifying the Delivery of Collection Segments was completed on January
30, 2024. There are no liquidated damages associated with this Milestone as the
Guaranteed Collection Segment Delivery Date was April 2, 2024.
b. See Response to Staff Request No. 81 – Attachment 2 which includes the Bill of
Lading identifying the Delivery of PCS/MVT was completed on April 22, 2024, and
April 23, 2024. There are no liquidated damages associated with this Milestone
as the Guaranteed PCS/MVT Sets Delivery Date was May 10, 2024.
c. See Response to Staff Request No. 81 – Attachment 3 which includes the Bill of
Lading identifying the Delivery of Energy Segments was completed on May 20,
2024. Of the 240 Energy Segments due by the Guaranteed Energy Segment
Delivery Date of May 3, 2024, 40 were delayed. The liquidated damages
associated with this Milestone amount to approximately . The liquidated

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 17
damages will be applied as a credit to net power supply expenses and therefore
will flow back to customers through the PCA.
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 18
REQUEST FOR PRODUCTION NO. 82: Please clarify if Capital Project BID
HMWY230002 - 36 MW Hemingway 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 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 82:
a. Capital Project BID HMWY230002, the 36 MW Hemingway BESS, has not
achieved the Commissioning milestone. Thus, the Form of Commissioning
Certificate is not available.
b. Commissioning is anticipated in September 2024 with Final Acceptance in October
2024. Liquidated damages will apply but the value is unknown until the parties
agree to the delay damages and the various obligations governed by the Battery
Energy Storage Agreement. Any liquidated damages assessed will be applied as
a credit to net power supply expenses and therefore will flow back to customers
through the PCA.
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 19
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 83:
a. See Response to Staff Request No. 83 – Attachment 1 which includes the Bill of
Lading identifying the Delivery of Collection Segments was completed between
April 3, 2023, and May 3, 2023. All 13 Collection Segments were delayed beyond
the Guaranteed Collection Segment Delivery Date of February 10, 2023, and
liquidated damages amount to approximately . The liquidated damages
will be applied as a credit to net power supply expenses and therefore will flow
back to customers through the PCA.
b. See Response to Staff Request No. 83 – Attachment 2 which includes the Bill of
Lading identifying the Delivery of PCS/MVT was completed on January 30, 2023,
and January 31, 2023. There are no liquidated damages associated with this
Milestone as the Guaranteed PCS/MVT Sets Delivery Date was February 3, 2023.
c. See Response to Staff Request No. 83 – Attachment 3 which includes the Bill of
Lading identifying the Delivery of Energy Segments was completed on July 26,

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 20
2023. All 260 Energy Segments due by the Guaranteed Energy Segment Delivery
Date of March 29, 2023, were delayed. The liquidated damages associated with
this Milestone amount to approximately . The liquidated damages will
be applied as a credit to net power supply expenses and therefore will flow back
to customers through the PCA.
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 21
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 84:
a. Capital Project BID BMSU220002, the 40 MW Black Mesa BESS, has not
achieved the Commissioning milestone pursuant to the contract because Idaho
Power will not accept the commissioning certificate until all required items
identified in the commissioning checklist have been completed. Thus, the Form of
Commissioning Certificate is not available. Note, however, the project is in-service
and operational.
b. Commissioning is anticipated prior to the end of August 2024 with Final
Acceptance in September. Liquidated damages will apply but the value is unknown
until the parties agree to the delay damages and the various obligations governed
by the Battery Energy Storage Agreement. Any liquidated damages assessed will
be applied as a credit to net power supply expenses and therefore will flow back
to customers through the PCA.
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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 22
DATED at Boise, Idaho, this 3rd day of September 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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 23
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 3rd day of September 2024, I served a true and
correct copy of Idaho Power Company’s Response to the Eleventh 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
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

Hand Delivered
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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 24
Idaho Conservation League
Brad Huesinkveld
710 N. 6th Street
Boise, Idaho 83702
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701

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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 25
Steven Hubble
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Federal Executive Agencies
Peter Meier
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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Stacy Gust
Regulatory Administrative Assistant