20240903IPC to Staff 21 Supplemental.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 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: [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
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

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

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Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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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
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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 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

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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