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HomeMy WebLinkAbout20240903IPC to Staff 21 Supplemental.pdfLISA D. NORDSTROM Lead Counsel lnordstrom@idahopower.com 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 Supplemental Response to the Fourth 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. Given the significant time and resources required to individually label each confidential document contained in the confidential attachments, Idaho Power has instead marked the entirety of the contents contained within Production Response No. 21(c) Confidential Attachment 2 and Confidential Attachment 3, confidential by designating the Attachment folder and individual file name as “CONFIDENTIAL”. When downloading the zip folder, please save the zip file to your desktop to avoid any errors with the lengthy file names. RECEIVED Tuesday, September 3, 2024 IDAHO PUBLIC UTILITIES COMMISSION Commission Secretary Idaho Public Utilities Commission September 3, 2024 Page 2 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 No. 21 to Idaho Power Company’s Supplemental Response to the Fourth 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 and/or business records of a private enterprise required by law to be submitted to or inspected by a public agency 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 SUPPLEMENTAL RESPONSE TO THE FOURTH 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: (208) 388-5825 Facsimile: (208) 388-6936 lnordstrom@idahopower.com dwalker@idahopower.com mgoicoecheaallen@idahopower.com 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. ) ) ) ) ) ) ) ) ) CASE NO. IPC-E-24-07 IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Fourth Production Request of the Commission Staff (“Commission” or “Staff”) to Idaho Power Company dated July 10, 2024, herewith supplements the following information: IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2 REQUEST FOR PRODUCTION NO. 21: Please provide the following information for the “Rebuild of Line 902” project referenced by Colburn Direct at 7. Please include any available workpapers with formulas intact. 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 detailed explanation for the need of the project including the analysis justifying the need; b. Please provide a list of all the potential alternatives the Company considered to fulfill the need and explain why the project was selected among the alternatives supported by the Company’s economic analysis (costs and benefits) comparing them; c. If a RFP or RFQ was submitted, please provide the following information: i. A copy of the RFP or RFQ that was submitted; ii. A detailed explanation of the selection process including the scorecard and list of the criteria used to select the project; iii. The short-list bidder scorecard; and iv. A copy of the winning bid. d. Please provide the approved Initial Project Plan including the 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. IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3 e. Please provide the following for the Baseline Construction Project Plan including the following: i. Baseline project scope; ii. Baseline project budget broken down by WBS; 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. f. Please provide the following related to completion of the project: 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. SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 21: Subsequent to the Company’s response to this request, it was determined that some of the attachments provided were associated with a different Line 902 project and should be IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 4 ignored. Idaho Power is providing the following revised files as new supplemental attachments supporting this project:  See the Supplemental Response to Request for Production No. 21(c) – Attachment 1 for the RFP for construction services which replaces Response to Request for Production No. 21(c) – Attachment 1.  See the Supplemental Response to Request for Production No. 21(c) – Confidential Attachment 2 for the summaries of the pricing and non-pricing responses and an executive summary of the bid evaluation results for construction services which replaces Response to Request for Production No. 21(c) – Confidential Attachment 4.  See the Supplemental Response to Request for Production No. 21(c) – Confidential Attachment 3 for the winning bid for construction services which replaces Response to Request for Production No. 21(c) – Confidential Attachment 6.  See the Supplemental Response to Request for Production No. 21(e) – Attachment 1 for the Work Breakdown Structures specific to the Rattlesnake to DRAM line rebuild portion of the project which replaces Response to Request for Production No. 21(e) – Attachment 1. The response to this Request is sponsored by Mitch Colburn, Vice President of Planning, Engineering and Construction, Idaho Power Company. IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 5 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 SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 6 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 Supplemental Response to the Fourth 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 Chris.Burdin@puc.idaho.gov 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 peter@richardsonadams.com Dr. Don Reading 280 Silverwood Way Eagle, Idaho 83616 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email dreading@mindspring.com 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 U.S. Mail Overnight Mail FAX FTP Site X Email elo@echohawk.com Lance Kaufman, Ph.D. 2623 NW Bluebell Place Corvallis, OR 97330 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email lance@aegisinsight.com IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 7 Idaho Conservation League Brad Heusinkveld 710 N. 6th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email bheusinkveld@idahoconservation.org 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 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com karoach@hollandhart.com Jim Swier Micron Technology, Inc. 8000 South Federal Way Boise, ID 83707 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email jswier@micron.com City of Boise Ed Jewell Deputy City Attorney Boise City Attorney’s Office 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email BoiseCityAttorney@cityofboise.org ejewell@cityofboise.org IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 8 Steven Hubble Boise City Dept. of Public Works 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email shubble@cityofboise.org Federal Executive Agencies Peter Meier Emily W. Medlyn U.S. Department of Energy 1000 Independence Ave., S.W. Washington, DC 20585 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter.meier@hq.doe.gov emily.medlyn@hq.doe.gov Stacy Gust Regulatory Administrative Assistant