20240909IPC to Staff 85-105 - Redacted Response.pdf

-UIQAW POWER,
LISA D. NORDSTROM
Lead Counsel RECEIVED
Inordstrom(WJdahopower.com Monday, September 09, 2024
IDAHO PUBLIC
September 9, 2024 UTILITIES COMMISSION
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
Twelfth 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. When downloading the zip folder, please save the
zip file to your desktop to avoid any errors with the lengthy file names.
If you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
p"0l "P. 0ta(Crh�.r.�
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. 85, 86, 87, 88, 89, 90,93,
94, 95, 96, 97, 98, 99, 100, 101, 102, and 105 to Idaho Power Company's Response to
the Twelfth Production Request of the Commission Staff dated September 9, 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 9t" day of September 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: [phone]
Facsimile: [phone]
Inordstrom(aMdahopower.com
dwalker idahopower.com
mgoicoecheaallenCabidahopower.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 TWELFTH
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 Twelfth Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated August 26, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 1

REQUEST FOR PRODUCTION NO. 85: In reference to the Company's response
to Staff Production Request No. 31 b — Attachment 4, for the bid scorecard for the
Engineering Design Oxbow Hatchery Renovation Project, please provide a detailed
explanation and evidence for each of the criteria to arrive at a final score for each of the
bids. Please also provide the price for each of the bids.
RESPONSE TO REQUEST FOR PRODUCTION NO. 85: Evaluation of
engineering design bids was led by Idaho Power employees no longer with the Company
therefore detailed explanations and justifications for why each score was assigned to
each criterion is not available. However, Idaho Power can provide an explanation based
on standard bid evaluation practices.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 2

1
1
1
1
1
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 3

—Please see the Response to Request for Production No. 85 —
Confidential Attachments 1 and 2 for a copy of the bids with pricing.
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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER-4

REQUEST FOR PRODUCTION NO. 86: In reference to the Company's response
to Staff Production Request No. 31(b)(i) for construction inspection work of the Oxbow
Hatchery Renovation Project, please provide the bid price information, bid scorecard, and
criteria and any other documentation for the three vendors the Company contacted
directly to perform the work.
RESPONSE TO REQUEST FOR PRODUCTION NO. 86: As explained in the
Company's Response to Request for Production No. 31(b)(i), a formal Request for Bids
was not issued for construction inspection services because of the specialized services
required. Rather, Idaho Power contacted three known vendors directly, requesting a bid
for the work necessary. However, the bid information received for construction inspection
services from Schnabel Engineering was provided as the Response to Request for
Production No. 31(b) — Confidential Attachment 6. Schnabel Engineering's proposal for
construction inspection support is identified as Tasks 1 through 3. Work outlined in Tasks
1 and 3 is specific to Construction support work, while Task 2 is specific to the work
referred to as Construction Inspection for this project.
Please see the Response to Request for Production No. 86 — Confidential
Attachment for bid information received from River Structures Consulting, which includes
correspondence associated with the rate, construction experience, and a resume for
inspector that was proposed to be onsite. The Company planned to proceed with River
Structures Consulting for construction inspection services for the hatchery renovation, but
the resource was allocated to another project and no additional inspectors were available.
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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 5

REQUEST FOR PRODUCTION NO. 87: In reference to the Company's response
to Production Request No. 31(d) — Confidential Attachment 4 — COs — Engineering
Design, please explain why Change Order #2 is for work contracted with SCHNABEL
engineering for construction support when the engineering design was originally assigned
to Deere & Ault Consultants Inc. Additionally, please provide a detailed breakdown (i.e.
engineering staff rate and hours, subcontractors' work, etc.) of the $44,210 increase.
RESPONSE TO REQUEST FOR PRODUCTION NO. 87: Deere & Ault changed
names during the design process of the project therefore Change Order #2 reflects the
new company name, Schnabel Engineering. Note, the same engineering firm and project
team completed the work. Please see the Response to Request for Production No. 87 —
Confidential Attachment for the Change Order Request from Schnabel Engineering that
initiated Change Order #2. The attachment includes a narrative that discusses the
proposed design changes and a schedule of values based on engineering man hours
supporting the increase.
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 TWELVTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 6

REQUEST FOR PRODUCTION NO. 88: In reference to the Company's response
to Staff Production Request No. 31(d) — Confidential Attachment 5 — COs — Construction
for the Oxbow Hatchery Renovation Project, please explain the escalation cost included
in Change Order #1 attributed to the FERC permission delay (i.e. Rebar Escalation,
Overhead Door Escalation, Crowder Control Panel Escalation, Structural Steel
Escalation, and Permitting Delay Related Costs), even though Change Order #2 was
attributed to an increase in the contract amount due to the FERC permission delay.
RESPONSE TO REQUEST FOR PRODUCTION NO. 88: Change Order No. 1
was associated with the additional costs resulting from the escalation of rebar, overhead
door, crowder control panels, and structural steel costs. These were incurred by the
contractor when purchasing material at time of procurement for construction relative to
the costs provided at time of bid. While the project was delayed for FERC permitting, the
contractor continued to procure certain materials for the project. Please see the Response
to Request for Production No. 88 — Confidential Attachments 1 through 4, for the change
order requests from the contractor specific to rebar, overhead door, crowder control
panels, and structural steel escalation costs supporting Change Order#1.
The escalation cost included in Change Order #1 titled Permitting Delay Related
Costs are addressed in Change Directive ("CD") 016, included as the Response to
Request for Production No. 88 — Confidential Attachment 5. CD 016 pertains to the delay
in the start of the river intake construction as a result of the FERC permitting taking longer
than anticipated. A scope of work summarized as constructing the river water intake
structure was scheduled to begin March 1, 2022, but was not authorized to begin until
June 20, 2022. Costs for allocated manpower, equipment, and resources were committed
IDAHO POWER COMPANY'S RESPONSE TO THE TWELVTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 7

to this project by contractor. CD 016 - Intake Permit Delays and the Change Order
Request #16 — Intake Construction Start Delay Costs include a narrative and cost
breakdown outlining the reasoning for the costs incurred with delay.
Change Order #2 also addresses costs incurred by contractor for the one-year
delay for the entire hatchery renovation scope but is associated with committed
resources, equipment, a full mobilization, and other efforts put forth for the start of
construction that resulted from the majority of the scope being put on hold for one year.
Additionally, material escalation costs for other material purchases not captured in
Change Order#1 are included in Change Order#2 as well. For clarification, CD 016 within
Change Order #1 addresses permitting delay costs solely for the intake structure portion
of work. Change Order #2 addresses permitting delay costs associated with remaining
scope of the project which is described as a complete hatchery and site renovation.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 8

REQUEST FOR PRODUCTION NO. 89: In reference to the Company's response
to Staff Production Request No. 31(d)- Confidential Attachment 6 — COs — Construction
Support for Construction Support in the Oxbow Hatchery Project, please explain the
contract increase Order #2 and provide any additional information
and documents to support the increase.
RESPONSE TO REQUEST FOR PRODUCTION NO. 89: Change Order #2
addresses additional engineering support for the construction phase of the project.
Requested changes in design determined during construction, and labor rate increases
due to inflation, contributed to the need for a change order. Please see the Response to
Request for Production No. 89 — Confidential Attachment, which includes a breakdown of
the increased costs proposed by Schnabel Engineering for the estimated time and cost
to support the remaining duration of construction. Page 3 details the estimated services
and quantity of site visits, shop visits for fabrication items, and assumptions of remaining
volume of documents that will require engineering review for construction support.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 9

REQUEST FOR PRODUCTION NO. 90: In reference to the Company's response
to Staff Production Request No.31(d)- Confidential Attachment 6 — COs — Construction
Support for the Oxbow Hatchery Renovation Project, please explain the —
increase in Change Order#4 (i.e. RFI, invoices, cost estimates from subconsultants, etc.)
and provide any additional information and documents to support the increase.
RESPONSE TO REQUEST FOR PRODUCTION NO. 90: Change Order #4
addresses costs for the construction support services from the engineer of record for the
remaining duration of construction. The costs are attributed to higher than anticipated
labor and time spent on construction support. Throughout construction, changes to the
original design drawings were necessary, requiring revisions by Schnabel Engineer to
move forward and construct. Construction support includes but is not limited to submittal
review, Request for Information review, design clarifications, drawing revisions, and
additional engineering design for requested changes. Please see the Response to
Request for Production Request No. 90 — Confidential Attachment for Schnabel
Engineering's proposal of the estimated time and cost to support the remaining duration
of construction, ultimately resulting in Change Order#4.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 10

REQUEST FOR PRODUCTION NO. 91: In reference to the Company's response
to Staff Production Request No. 31(d) — Confidential Attachment 7 — COs - Construction
Inspection for the Oxbow Hatchery Renovation Project, please justify the —
increase in cost in Change Order #1. Please include any documentation showing a
change in the Scope of Work and the incremental cost from the original contract.
RESPONSE TO REQUEST FOR PRODUCTION NO. 91: Change Order #1
addresses the costs for the remaining construction inspection services for the duration of
the desired inspection. The costs are attributed to higher than anticipated labor and time.
Additionally, the contractor providing construction inspection services was contracted to
complete materials testing (concrete, compaction, and welding tests)for the project which
was not initially contemplated. Idaho Power requested an estimated monthly cost for the
remainder of the project— which was then multiplied by the estimated 10 months
remaining for the total change order request. Additional documentation is not available as
a proposal was submitted for this change.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 11

REQUEST FOR PRODUCTION NO. 92: In reference to the Company's response
to Staff Production Request No. 31(d) —Attachment 1 —WBS the total cost for the Oxbow
Hatchery Renovation Project is $25,506,884.63 and the cost of the remaining work is
$3,807,331.62. However, in Response to Production Request No. 3 Attachment 3 —
Larkin Workpaper 3 — Incremental Plant Determination, $26,209,352.45 is required for
total projected closing. Please reconcile the difference between the two amounts.
Additionally, the total contract cost as shown in Response to Production Request No.
31(d) — Confidential Attachments 4 through 7 is with change orders, as
shown in the below table. Please reconcile it with the total projected closing cost reflected
in Response to Production Request No. 3.
Categories Final Cost
Engineering Design
Construction
Construction Support
Construction Inspection
Total
RESPONSE TO REQUEST FOR PRODUCTION NO. 92: Please note, the total
project cost presented in Mr. Larkin's Workpaper 3 includes Allowance for Funds Used
During Construction ("AFUDC") and overheads while the Work Breakdown Structure
("WBS") and Change Orders do not. Further, the amounts presented in Mr. Larkin's
Workpaper 3 were estimates at the time Idaho Power developed the test year presented
in this case. The costs included in the WBS would be more representative of the current
project cost estimate, excluding AFUDC and overheads. Note, the Company anticipates
an additional $200,000 in project costs prior to conclusion of construction that is not
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 12

reflected within the WBS. Finally, the total contract cost shown in the Response to
Request for Production No. 31(d) — Confidential Attachments 4 through 7 includes on
those costs associated with contracted purchased services for engineering design,
construction contractor, construction support (engineer of record), and construction
inspection and does not include internal Idaho Power labor, material purchases directly
made by Company for the project, and other expenses associated with project incurred
by Idaho Power. These costs are reflected in the WBS on lines 2, 3, and 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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 13

REQUEST FOR PRODUCTION NO. 93: Please provide the following information
for the AFPR Controls Modernization (AFPR140005) project referenced by Secondary
Supplemental Response to Production Request No. 5. Please include any available
workpapers with formula 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 Request for Proposal ("RIFF') or Request for Quote ("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 following:
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
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 14

appropriate level.
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 Work-Breakdown Structure ("WBS");
iii. Baseline project schedule broken down by the 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 the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 93:
a. The American Falls Power Plant ("AFPR") is the sixth highest generating facility in
Idaho Power's hydroelectric fleet. This project involved the modernization of the
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 15

control and power distribution networks on all three units including installation of a
new Plant Control System ("PLC") at the AFPR, including the protection system,
the governor, the remote terminal unit ("RTU"), the graphical user interface ("GUI"),
the human-machine interface ("HMI") and the control switchboard. The unit PLC
controls the unit operation, the governor, the governor oil system, intake gate and
auxiliary equipment. Further, the new balance of plant PLC will control local
service, station air compressors, spill gates, station sump pumps, unwatering
pumps, fire water pump strainer, monitoring the line relaying, the aeration system
and the diesel generator. The primary need for the project was related to the age
of the equipment, which required increased maintenance and tuning. Upgrading
the equipment will result in decreased frequency of required testing and
maintenance, increased performance and unit efficiency, as well as better insight
into plant conditions and operations. Please see the attachment provided in
response to part (b) for a discussion of the consequences that would occur if the
Company did not proceed with this project.
b. Please see Response to Request for Production No. 93(b) — Confidential
Attachment - AFPR140005 Alternatives Analysis.
c. Please see the responses below.
i. There were no competitive bidding solicitations for this project as it is standard
equipment the Company uses across its hydro-fleet so the majority of the work
was performed by Idaho Power personnel. However, the Company contracted
the work required for assistance with the removal of old equipment and the
installation of the new equipment (physical connections and equipment
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 16

placement). To do so, Idaho Power prepared a Contractor Summary of the
work to be performed and the proposed project schedule and sent the summary
to seven vendors. Please see Response to Request for Production No. 93(c) -
Attachment 1 - AFPR140005 Contractor Summary.
ii. The contractor summary was submitted to seven vendors, but only one vendor
bid the project. The Company compared the bid price to the price of internal
wiring crews, and determined the prices were comparable.
iii. Not applicable. The Company only received one bid.
iv. Please see Response to Request for Production No. 93(c) - Confidential
Attachment 2 - AFPR140005 Bid.
d. Please see the responses below.
i. Please see Response to Request for Production No. 93(d) - Attachment 1 -
AFPR140005 Project Plan and Response to Request for Production No. 93(d)
- Confidential Attachment 2 - AFPR140005 Contract SOW.
ii. Please see part (d)(i).
iii. Please see part (d)(i).
iv. Please see the Company's Response to Request for Production No. 17(a)(iv)
for the project budget approval process. The creation of the AFPR Controls
Modernization Budget ID AFPR140005 and corresponding approved budget
amounts reflected in Response to Request for Production No.93(f) —
Confidential Attachment 1 - AFPR140005 Completion Budget to Actual is
evidence of approval of the initial budget.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 17

e. Please see the responses below.
i. Please see Response to Request for Production No. 93(d) — Attachment 1
— AFPR14005 Project Plan. There were no changes to the scope following
creation of the project plan.
ii. Please see Response to Request for Production No. 93(e) — Attachment 1
— AFPR140005 Baseline Construction WBS.
iii. Please see Response to Request for Production No. 93(e) — Attachment 1
— AFPR140005 Baseline Construction WBS.
iv. Please see Response to Request for Production No. 93(e) — Attachment 2
— AFPR140005 Baseline Construction Variance Notes.
V. Please see Response to Request for Production No. 93(e) — Attachment 3
— AFPR140005 Baseline Construction Summary Report and Response to
Request for Production No. 93(e) — Attachment 4 — AFPR140005
Construction Checklist.
vi. Not applicable. There were no change orders.
f. Please see the responses below.
i. Please see Response to Request for Production No.93(f) — Confidential
Attachment 1 - AFPR140005 Completion Budget to Actual.
ii. Please see Response to Request for Production No.93(f) - Attachment 2-
AFPR140005 Completion Schedule to Actual.
iii. Not applicable. However, see the Variance Notes provided in part (e)(iv) for
an explanation of variances driving the budget updates.
iv. Please see Response to Request for Production No. 93(e) — Attachment 3
— AFPR140005 Baseline Construction Summary Report.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 18

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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 19

REQUEST FOR PRODUCTION NO. 94: Please provide the following information
for the HCPR Controls Modernization — Unit 3, Unit 1, BOP, Unit 2 (HCPR190001)
project referenced by Secondary Supplemental Response to Production Request No.
5. Please include any available workpapers with formula 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 following:
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
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 20

appropriate level.
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 the WBS;
iii. Baseline project schedule broken down by the 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 the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 94:
a. This project replaced a portion of the equipment at Hells Canyon Complex
("HCC"), including governors, unit controls, and balance of plant ("BOP"). The
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 21

primary need for the project was related to the age of the equipment, which
required increased maintenance and tuning. Upgrading the equipment will result
in decreased frequency of required testing and maintenance, increased
performance and unit efficiency, as well as better insight into plant conditions and
operations. Please see the attachment provided in response to part (b) for a
discussion of the consequences that would occur if the Company did not proceed
with this project.
b. Please see "Response to Request for Production No. 94(b) - Confidential
Attachment - HCPR190001 Alternatives Analysis".
c. Not applicable. Internal resources were utilized for this project.
d. Please see the responses below.
i. Please see "Response to Request for Production No. 94(d) - Attachment -
HCPR190001 Project Plan".
ii. Please see part (d)(i).
iii. Please see part (d)(i).
iv. Please see the Company's Response to Request for Production No. 17(a)(iv)
for the project budget approval process. The creation of the HCPR Controls
Modernization — Unit 3, Unit 1, BOP, Unit 2 (HCPR190001) project and
corresponding approved budget amounts reflected in Response to Request
for Production No. 94(f) — Confidential Attachment 1 - HCPR190001
Completion Budget to Actual is evidence of approval of the initial budget.
e. Please see the responses below.
i. Please see "Response to Request for Production No. 94(d) - Attachment -
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 22

HCPR190001 Project Plan.pdf".
ii. Please see "Response to Request for Production No. 94(e) — Attachment 1 —
HCPR190001 Baseline Construction WBS.pdf".
iii. Please see "Response to Request for Production No. 94(e) — Attachment 1 —
HCPR190001 Baseline Construction WBS.pdf".
iv. Please see "Response to Request for Production No. 94 (e) — Attachment 2 —
HCPR190001 Baseline Construction Variance Notes.pdf".
V. Please see "Response to Request for Production No.94(e) —Attachment 3 -
HCPR190001 Baseline Construction Monthly Summary.pdf" for the monthly
summary report. Please see "Response to Request for Production No. 94(e) -
Attachment 4 - HCPR190001 UNIT 1 Commissioning.zip", "Response to
Request for Production No. 94(e) - Attachment 5 - HCPR190001 UNIT 2
Commissioning.zip", and "Response to Request for Production No. 94(e) -
Attachment 6 - HCPR190001 BOP Commissioning.zip" for commissioning
plans and action items.
vi. Not applicable. No contractors were used with this project.
f. Please see the responses below.
i. Please see "Response to Request for Production No.94(f) — Confidential
Attachment 1 - HCPR190001 Completion Budget to Actual.pdf'.
ii. Please see "Response to Request for Production No.94(f) - Attachment 2 -
HCPR190001 Completion Schedule to Actual.pdf".
V. Not applicable. However, see the Variance Notes provided in part (e)(iv) for an
explanation of variances driving the budget updates.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 23

vi. Please see "Response to Request for Production No.94(e) —Attachment 3 -
HCPR190001 Baseline Construction Monthly Summary.pdf".
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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 24

REQUEST FOR PRODUCTION NO. 95: Please provide the following information
for the MLPR Units 1-2 AVR Upgrade (MLPR200001) project referenced by Secondary
Supplemental Response to Production Request No. 5. Please include any available
workpapers with formula 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 following:
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 RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 25

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 the WBS;
iii. Baseline project schedule broken down by the 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 the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 95:
a. In the continued effort to standardize the excitation systems in Idaho Power's hydro
fleet, the Milner automatic voltage regulators ("AVR") are among the last to be
updated. The existing AVRs have had frequent equipment failures and are
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 26

becoming more expensive and difficult to maintain. Updated AVR equipment will
standardize the units with other Idaho Power plants, reduce maintenance time, and
mitigate potential failure of old equipment. In addition, updated AVR equipment will
result in improved voltage response and performance.
b. Please see "Response to Request for Production No. 95(b) — Confidential
Attachment - MLPR200001 Alternatives Analysis.pdf".
c. Please see the responses below.
i. Please see "Response to Request for Production No. 95(c) - Attachment 1 -
MLPR200001 Electrical Bid SOW.pdf" for the statement of work provided to
bidders.
ii. The statement of work was submitted to four vendors, but only one vendor bid
the project. The Company compared the bid price to the price of internal wiring
crews, and determined the prices were comparable.
iii. Not applicable. The Company only received one bidder.
iv. Idaho Power does not possess a copy of the bid. However, the signed
statement of work (Request for Production No. 95(d)— Confidential Attachment
2 - MLPR200001 Contract SOW) utilized the contractor's schedule of rates, as
shown in Exhibit A of the document, reflecting the terms of the winning bid."
d. Please see the responses below.
i. Please see Response to Request for Production No. 95(d) — Attachment 1 -
MLPR200001 Project Plan and Response to Request for Production No. 95(d)
— Confidential Attachment 2 - MLPR200001 Contract SOW.
ii. Please see part (d)(i).
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 27

iii. Please see part (d)(i).
iv. Please see the Company's Response to Request for Production No. 17(a)(iv)
for the project budget approval process. The creation of the MLPR Units 1-2
AVR Upgrade Budget ID AFPR140005 and corresponding approved budget
amounts reflected in Response to Request for Production No.95(f) —
Confidential Attachment 1 - MLPR200001 Completion Budget to Actual is
evidence of approval of the initial budget.
e. Please see the responses below.
i. Please see "Response to Request for Production No. 95(d) - Attachment -
MLPR200001 Project Plan.pdf'.
ii. Please see "Response to Request for Production No. 95(e) — Attachment 1 -
MLPR200001 Baseline Construction WSB.pdf".
iii. Please see "Response to Request for Production No. 95(e) - Attachment 1 -
MLPR200001 Baseline Construction WSB.pdf".
iv. Please see "Response to Request for Production No.95(e) - Attachment 2 -
MLPR20001 Baseline Construction Variance Notes.pdf".
V. Please see "Response to Request for Production No.95(e)(v) - Attachment 3 —
MLPR200001 Baseline Construction Monthly Summary.pdf" for monthly
summary reports. Please see in "Response to Request for Production No. 95(e)
- Attachment 4 — MLPR200001 UNIT 1 Commissioning.zip" and "Response to
Request for Production No. 95(e) - Attachment 5 — MLPR20001 UNIT 2
Commissioning.zip" for commissioning plans and action items.
vi. Not applicable. There was not contractor change orders for this project.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 28

f. Please see the responses below.
i. Please see "Response to Request for Production No.95(f) — Confidential
Attachment 1 - MLPR200001 Completion Budget to Actual.pdf".
ii. Please see "Response to Request for Production No.95(f) - Attachment 2 -
MLPR200001 Completion Schedule to Actual.pdf".
iii. Not applicable. However, see the Variance Notes provided in part (e)(iv) for an
explanation of variances driving the budget updates.
iv. Please see "Response to Request for Production No.95(e)(v) - Attachment 3
— MLPR200001 Baseline Construction Monthly Summary.pdf".
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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 29

REQUEST FOR PRODUCTION NO. 96: Please provide the following information
for the Grand View Sprinkler Conversion Capital Early Implementation
(CHQB190001) project referenced by Secondary Supplemental Response to
Production Request No. 5. Please include any available workpapers with formula 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 following:
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
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 30

appropriate level.
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 the WBS;
iii. Baseline project schedule broken down by the 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 the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 96:
a. The Grand View Sprinkler Conversion Capital Early Implementation
(CHQB190001) program is included as a requirement of the Clean Water Act§401
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 31

water quality certifications issued in 2019 by both the Oregon and Idaho
Departments of Environmental Quality ("IDEQ" and "ODEQ"). In that certification,
the program is referred to as the Grand View Sediment Reduction Program. The
purpose of the Grand View Sediment Reduction Program is to reduce sediment
run-off directly into the Snake River from agricultural drains created from flood
irrigation practices. The program works with landowners to provide financial
incentive to convert from flood irrigation to pressurized sprinkler systems.
In the §401 water quality certifications, it is included as part of a
phosphorous reduction program to improve oxygen conditions in Brownlee
Reservoir. Measures included in the §401 water quality certifications are products
of significant consultation between Idaho Power, IDEQ, ODEQ, and other
agencies. Measures included in the final certifications are mandatory and are
deemed by the state as necessary to comply with state water quality standards. In
addition, the Federal Energy Regulatory Committee ("FERC") at minimum will
include these measures as conditions of the new Hells Canyon Complex license
relative to water quality.
b. As outlined in part (a), this project is part of a Total Phosphorous reduction program
developed in order to meet Idaho and Oregon state water quality standards. As a
result, there were not alternatives explored for this project.
c. An RFP or RFQ was not included in the implementation of the Grand View
Sediment Reduction Program. The program is implemented by Idaho Power
soliciting interest from landowners in the Grand View project area who have fields
that meet the eligibility criteria established to convert from flood irrigation to
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 32

pressurized sprinkler irrigation in the area defined in the certification. A funding
agreement is signed between Idaho Power and the landowner. It is the
responsibility of the landowner to work with vendors to install the pressurized
sprinkler system.
d. Please see the responses below.
i. The project scope was described in the application for §401 Water Quality
Certification - Exhibit 7.2-8. Please see "Response to Production Request No.
96(d) — Attachment 1— Water Quality Certification.pdF. The Grand View
Sediment Reduction Program assumes a 90% efficiency of the model
estimated sediment reduction and targets 80% of the furrow-irrigated lands in
the Grand View Irrigation District for conversion to sprinklers. Based on current
landowner recruitment rate, the 80% goal is estimated to be achieved by 2040.
ii. An initial project budget and schedule of$500,000 per year was determined to
meet the goal of 80% conversion of furrow-irrigated lands in a reasonable
trajectory of annual landowner recruitment toward the program goal. However,
dollars spent within the year are variable and dependent upon landowner
recruitment of projects to be completed within the calendar year. In some
instances, based on the progression of recruitment, the dollar amount
anticipated for the following year budget was known and approved budget
dollars reflected the known amount. Deviations in baseline ($500,000 annual
budget) are best explained by variability in landowner recruitment and the size
of projects recruited.
iii. Not applicable. It is the responsibility of the landowner to work with vendors to
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 33

install the pressurized sprinkler system.
iv. Please see the Company's Response to Request for Production No. 17(a)(iv)
for the project budget approval process. The creation of Grand View Sprinkler
Conversion Capital Early Implementation (CHQB190001) and corresponding
approved budget amounts reflected in the "Response to Request for Production
No. 96(d) — Confidential Attachment 2 — Budget to Actuals.xlsx" is evidence of
approval of the initial budget.
e. Please see the responses below.
i. Not applicable. See part (d)(iii).
ii. Please see the "Response to Request for Production No. 96(d) —Confidential
Attachment 2 - Budget to Actuals.xlsx" for the annual budget and actual dollars
spent by WBS for the years 2019-present.
iii. Not applicable. See part (d)(iii).
iv. Program variances from the annual $500,000 budget are reflective of the size
of the projects that were successfully recruited and implemented that year.
V. Not applicable. See part (d)(iii).
vi. Not applicable. See part (d)(iii).
f. Please see the responses below.
i. Please see "Response to Request for Production No. 96(d) — Confidential
Attachment 2 - Budget to Actuals.xlsx" for the annual budget and actual dollars
spent by WBS for the years 2019-present.
ii. Not applicable. See part (d)(iii).
iii. Please see part (e)(iv).
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 34

iv. Not applicable. See part (d)(iii).
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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 35

REQUEST FOR PRODUCTION NO. 97: Please provide the following information
for the HCC Rockfall Mitigation Program (OBSP180003) project referenced by
Secondary Supplemental Response to Production Request No. 5. Please include
any available workpapers with formula 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 following:
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
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 36

appropriate level.
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 the WBS;
iii. Baseline project schedule broken down by the 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 the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 97:
a. At the direction of legal counsel and in anticipation of litigation, a confidential
engineering analysis was generated by an outside engineering firm ("Engineering
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 37

Analysis") that identified several sites with existing rock slopes along Hells Canyon
Road between Oxbow, Oregon and the Hells Canyon Dam that, in the interests of
public safety, would benefit from reinforcement to mitigate the risk of rockfall. The
Engineering Analysis is strictly confidential and has not been provided due to risk
of potential litigation and to preserve attorney-client privilege. Please contact Lead
Counsel Lisa Nordstrom at [phone] if further information is desired.
b. This project was identified based on the Engineering Analysis and evaluated in
comparison with other sites to be addressed in future years. Given the need to
address public safety, there were no alternatives to completing this project.
c. No RFP or RFQ was submitted for this specific project. Idaho Power determined it
was in the best interest of the Company to single source this project based on the
selected contractor's specific knowledge of the area and its successful completion
of another competitively bid rockfall mitigation project the previous year that was
also identified in the Engineering Analysis. Please see Response to Request for
Production No. 97(c) —Attachment 1 — Single Source Contract Request.
i. Not applicable. See part (c).
ii. Not applicable. See part (c).
iii. Not applicable. See part (c).
iv. Please see Response to Request for Production No. 97(c) — Confidential
Attachment 2 — Bid Proposal for a copy of the bid proposal.
d. There is no specific project plan. However, the following provides more information
related to the project:
i. Please see Response to Request for Production No. 97(d) — Confidential
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 38

Attachment 1 — Design Package for the design package for site PP189, which
contains the initial project scope and mitigation plan.
ii. Please see Response to Request for Production No. 97(d) — Confidential
Attachment 2 — Budget to Actuals for the project budget.
iii. Please see Response to Request for Production No. 97(d) —Attachment 3 —
2023 Proposed Schedule and Response to Request for Production No. 97(d)
—Attachment 4—2024 Proposed Schedule for the proposed project schedules.
iv. Please see the Company's Response to Request for Production No. 17(a)(iv)
for the project budget approval process. The creation of the BID OBSP180003
for the Rockfall Mitigation Program and corresponding approved budget
amounts reflected in Response to Request for Production No. 97(d) —
Confidential Attachment 2 — Budget to Actuals is evidence of approval of the
initial budget.
e. There is no construction project plan document as construction plans have not
changed since the scope and design documents were created.
i. Please see part (d)(i). This did not change from the initial project scope.
ii. See the Company's Response to Request for Production No. 97(d)(ii). The
project is not managed in MS Project Server therefore the only WBS the
Company can provide for the project is reflective of the most recent budget and
schedule.
iii. See part (e)(ii).
iv. Please see the Response to Request for Production No. 97(e) — Attachment 1
— Project Updates.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 39

V. Please see part (e)(iv).
vi. Please see the Response to Request for Production No. 97(e) — Confidential
Attachment 2 — Change Order and Response to Request for Production No.
97(e) — Confidential Attachment 3 — Change Order.
f. Please see the responses below.
i. Not applicable. See part (e)(ii).
ii. Not applicable. See part (e)(ii).
iii. The budget for 2024 is reflective of the entire year whereas actuals are through
July 2024. Accordingly, the Company's budget to actuals analysis is focused
on only 2023. Actual spend on labor was less than budget due to less internal
oversite and project management labor required. Actual purchased services
were higher than budget due to some unanticipated rock blasting work that was
required to remove some hazard rocks that were not scalable with hand
methods, as well as a mobilization fee for the work to re-commence and to
mobilize blasting equipment. Also, the price for drilled dowels was adjusted
slightly for inflation between work stop in 2023 and re-initiation in 2024.
iv. Deviations from baseline schedule are common for this work. Often site
conditions change, or aspects of the work vary in length from the estimated
schedule. Because these are stand-alone projects without interdependencies,
Idaho Power has flexibility to work with the contractor's schedule.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 40

REQUEST FOR PRODUCTION NO. 98: The Company's Second Supplemental
Response to Staff Production Request No. 5 lists the following Transmission project:
"T404200001 - T404 LNDN Convert Source From a Tap to a Loop Feed" for a total plant-
in-service amount of $1,162,731 . Please provide the following information regarding this
project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget
line item.
RESPONSE TO REQUEST FOR PRODUCTION NO. 98:
a. The Linden, Hill, and Skyway substations serve 22,736 customers and had an
actual coincident summer 2022 peak load of 103 MW. With the addition of several
new business projects and growth-related load transfers, the 2024 forecasted peak
load of 147 MW will be served from the Caldwell to Nampa 138-kV Line#404 which
serves the Linden, Hill, and Skyway substations. The Hill, Linden, and Skyway
substation loads were at risk for extended outages. Industry best practices include
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 41

installing transmission breakers when the combined peak load is projected to
exceed approximately 80 MW. Limiting the loss of load is most efficiently provided
by installing 138-kV breakers at the Linden substation and extending the existing
transmission line to the substation. Budget ID T404200001 is associated with the
extension of the existing transmission line to the Linden substation and Budget ID
LNDN190001, discussed in Response to Request for Production No. 99, is
associated with the installation of the 138-kV breakers at the Linden substation.
b. The following work was done to support local area load management and defer
the T404200001 project until absolutely necessary:
• A load transfer of 1.8 MW from the Linden substation to the Hill substation
occurred in 2022,
• A load transfer of 1.5 MW from the Linden substation to the Hill substation
occurred in early 2024,
• A load transfer of 4.0 MW from the Linden substation to the Vallivue
substation occurred in 2023, and
• A load transfer of 1 .15 MW from the Caldwell substation to the Linden
substation occurred in early 2024.
No additional alternatives would alleviate authorization of this project.
c. A specific project plan could not be located. However, the following provides more
information related to the project:
i. The project scope included reconstructing the existing radial single circuit 138-
kV transmission line as a double circuit 138-kV transmission line to route
multiple transmission circuits into the existing Linden substation. The result
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 42

provides sources to Linden where new breakers would be installed to reduce
loss of load on the Linden distribution feeders. New transmission line switches
and dead-end steel structure will be required. To support communication
needs, a fiber optic line overhead will be added on the distribution circuits.
ii. The original budget, approved by executive management during the annual
budget cycle in September 2021, was $439,000 with an expected completion
date in May 2023. The anticipated schedule included scoping in 2021, design
in 2022, and construction in 2023. A detailed schedule was not developed until
after the project was approved and a project manager and design team were
assigned. The schedule and cost prepared at the beginning of construction
when the project was designed, can be found in Response to Request for
Production No. 98 — Confidential Attachment 1. Note, the costs and schedule
presented in the attachment are for the entire project Budget ID, which is
inclusive of more work orders and work than what has been placed in service
as of July 2024 and was presented in the Company's Second Supplemental
Response to Staff Production Request No. 5.
iii. See part ii above.
iv. See the Company's Response to Request for Production No. 17(a)(iv) for an
explanation of the capital project budget approval processes. The creation of
Budget ID T404200001 for the reconstruction of the transmission line as well
as the Customer Load and Research Information System ("CLRIS") screenshot
provided as the Response to Request for Production No. 98 —Attachment 2, is
evidence of approval of the initial budget.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 43

d. See Response to Request for Production No. 98—Confidential Attachment 3 which
shows the forecasted project costs each quarter with supporting notes
characterizing any variances. Note, the attachment includes information for the
entire project Budget ID, which is inclusive of more work orders and work than
what has been placed in service as of July 2024 and was presented in the
Company's Second Supplemental Response to Staff Production Request No. 5.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 44

REQUEST FOR PRODUCTION NO. 99: The Company's Second Supplemental
Response to Staff Production Request No. 5 lists the following Transmission project:
"LNDN190001 - ADD 138KV BREAKERS" for a total plant-in-service amount of
$3,954,411. Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget
line item.
RESPONSE TO REQUEST FOR PRODUCTION NO. 99:
a. The Linden, Hill, and Skyway substations serve 22,736 customers and had an
actual coincident summer 2022 peak load of 103 MW. With the addition of several
new business projects and growth-related load transfers, the 2024 forecasted peak
load of 147 MW will be served from the Caldwell to Nampa 138kV Line #404 which
serves the Linden, Hill, and Skyway substations. The Hill, Linden, and Skyway
loads were at risk for extended outages. Best practices include installing
transmission breakers when the combined peak load is projected to exceed
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 45

approximately 80 MW. Limiting the loss of load is most efficiently provided by
installing 138-kV breakers at the Linden substation and extending the existing
transmission line to the substation. Budget ID LNDN190001 is associated with the
installation of the 138-kV breakers at the Linden substation and Budget ID
T40420001, discussed in the Response to Request for Production No. 98, is
associated with the extension of the existing transmission line to the Linden
substation.
b. The following work was done to support local area load management and defer
the LNDN190001 project until absolutely necessary:
• A load transfer of 1.8 MW from the Linden substation to the Hill substation
occurred in 2022,
• A load transfer of 1.5 MW from the Linden substation to the Hill substation
occurred in early 2024,
• A load transfer of 4.0 MW from the Linden substation to the Vallivue
substation occurred in 2023, and
• A load transfer of 1 .15 MW from the Caldwell substation to the Linden
substation occurred in early 2024.
No additional alternatives would alleviate authorization of this project.
c. A specific project plan could not be located. However, the following provides more
information related to the project:
i. The project scope included the following:
• Installing new 138-kV breakers at Linden to break up the existing 138-
kV Line #404.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 46

• Feeder relay replacements for Linden 011A, 013A, 015A, 017A and
replacement of T132 with a larger (44.8 MVA) transformer. The feeder
relay replacements entail removal of the 1999 vintage SEL-251 relays
installed in the metalclad #2 feeder bay door panels for Linden 011A,
013A, 015A, and 017A, as well as removal of the feeder control panel
in metalclad #2.
• Installing two new CF9 (125V Direct Current) dual feeder panels in the
Linden control building with SEL-351A primary and backup relays.
• Installing new cables from the feeder metalclad bays to the new dual
feeder panels.
• For Supervisory Control and Data Acquisition ("SCADA") upgrades, an
SEL-2032 or a Real Time Automation Controller may be needed.
SCADA should include, at a minimum, the following points for
distribution operation: Feeder level = 3-phase MW, ground amps, by-
phase amps, and by-phase VARs and voltage.
ii. The original budget, approved by executive management during the annual
budget cycle in September 2021, was $1,948,000 with an expected completion
date in May 2023. The anticipated schedule included scoping in 2021, design
in 2022, and construction in 2023. A detailed schedule was not developed until
after the project was approved and a project manager and design team were
assigned. The schedule and cost prepared at the beginning of construction
when the project was designed, can be found in the Response to Request for
Production No. 99 — Confidential Attachment 1.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 47

iii. See part ii above.
iv. See the Company's Response to Request for Production No. 17(a)(iv) for an
explanation of the capital project budget approval processes. The creation of
Budget ID LNDN190001 for the installation of the 138-kV breakers as well as
the CLRIS screenshot provided as the Response to Request for Production No.
99 —Attachment 2 is evidence of approval of the initial budget.
d. See Response to Request for Production No. 99—Confidential Attachment 3 which
shows the forecasted project costs each quarter with supporting notes
characterizing any variances.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 48

REQUEST FOR PRODUCTION NO. 100: The Company's Second Supplemental
Response to Staff Production Request No. 5 lists the following Transmission project:
"T409210001 - 10-YEAR INSPECTION REPAIRS, BRADY-FREMONT-KINPORT" for a
total plant-in-service amount of $1,383,573. Please provide the following information
regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget
line item.
RESPONSE TO REQUEST FOR PRODUCTION NO. 100:
a. This project was needed to correct issues on the Brady-Fremont-Kinport line
identified during detailed aerial inspection, ground line inspection, and outstanding
Priority 2 and 3 defects identified by patrolman. Line #409 was originally built in
1943. The 10-year maintenance plan for this line began in 2022 with the pole
inspection and groundline treatment, followed by design in 2023 and construction
in 2024.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 49

b. When defects on existing lines are identified, repairs must be implemented to
correct those defects. There are no other alternatives available.
c. A specific project plan could not be located. However, the following provides more
information related to the project:
i. The project scope included repairing or replacing deteriorated poles,
crossarms, and insulators identified during the pole inspection and ground line
treatment program and the annual routine line patrols. After inspection and
preparation of the corrective action plan, 58 defects were found requiring
replacement of insulators, crossarms, and poles.
ii. The original budget, approved by executive management during the annual
budget cycle in September 2021, of $531,000 was a high-level estimate
because the inspection was to be conducted the following year (2022) with an
expected completion date in December 2024. The budget was subsequently
updated once the inspection and corrective action plan were complete. The
updated estimate of $1,190,000 was set in July 2023 and reviewed and
approved by the Company's executive management. The anticipated original
schedule included scoping in 2022, design in 2023, and construction in 2024.
A detailed schedule was not developed until after the project was approved and
a project manager and design team were assigned. The schedule and cost
estimate prepared at the beginning of construction after the project was
designed, can be found in Response to Request for Production No. 100 —
Confidential Attachment 1.
iii. See part ii above.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 50

iv. See the Company's Response to Request for Production No. 17(a)(iv) for
an explanation of the capital project budget approval processes. The
creation of Budget ID T409210001 for the work on Line #409 as well as the
CLRIS screenshot provided as Response to Request for Production No.
100 — Attachment 2 is evidence of approval of the initial budget.
d. See Response to Request for Production No. 100 —Confidential Attachment 3
which shows the forecasted project costs each quarter with supporting notes
characterizing any variances.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 51

REQUEST FOR PRODUCTION NO. 101: The Company's Second Supplemental
Response to Staff Production Request No. 5 lists the following Transmission project:
"GINT240629 - INTERCONNECT FOR 36 MW BESS AT HMWY" for a total plant-in-
service amount of $782,813. Please provide the following information regarding this
project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget
line item.
RESPONSE TO REQUEST FOR PRODUCTION NO. 101:
a. Budget ID GINT240629 was associated with Idaho Power's interconnection
request to support the 36 MW Hemingway Battery Energy Storage System
("BESS") project, the resource for which the Company received a Certificate of
Public Convenience and Necessity'. The applicant, Idaho Power Power Supply, is
identified by queue number 629 in the Company's Generation Interconnection
Case No. IPC-E-23-05, Certificate No. 544 and Case No. IPC-E-23-20, Certificate No. 547.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 52

Queue. The application for the Hemingway Energy Storage 2 was made in January
2022 for a total size of up to 85 MW at the point of interconnection and a Generator
Interconnection Agreement ("GIA") was executed in January 2023 and provided
notice to proceed in October 2023. The upgrades described in the GIA are required
to interconnect the 36 MW Hemingway BESS project in 2024.
b. Idaho Power must comply with the GIA provisions under the Company's Open
Access Transmission Tariff ("OATT") to accommodate interconnection requests
therefore there are no feasible alternatives to this project.
c. There is no specific project plan for GIA projects because the scope of work is
included in the GIA. However, the following provides more information related to
the project:
i. See the Response to Request for Production No. 101 — Confidential
Attachment 1 which includes the GIA (and amendments) inclusive of the scope
of work for this project.
ii. The GIA provided as Response to Request for Production No. 101 —
Confidential Attachment 1 includes the initial estimated costs.
iii. The GIA provided as Response to Request for Production No. 101 —
Confidential Attachment 1 includes the initial proposed schedule.
iv. Upon unsuspension of the GIA in October 2023, Idaho Power immediately
began executing the required interconnection facilities design and construction
of the project. The schedule and cost estimate prepared at the beginning of
construction after the project was designed, can be found in Response to
Request for Production No. 101 — Confidential Attachment 2. Because
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 53

interconnection facilities are required under the Company's GATT, there is no
approval of the scope, budget or schedule as part of the capital budgeting
process.
d. See Response to Request for Production No. 101 — Attachment 3.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 54

REQUEST FOR PRODUCTION NO. 102: The Company's Second Supplemental
Response to Staff Production Request No. 5 lists the following Transmission project:
"T215210001 10-year inspection repairs, Ontario-Weiser 69kV" for a total plant-in-service
amount of $1,073,384. Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget
line item.
RESPONSE TO REQUEST FOR PRODUCTION NO. 102:
a. This project was needed to correct issues on the Ontario-Weiser 69-kV line
identified during detailed aerial inspection, ground line inspection, and outstanding
Priority 2 and 3 defects identified by patrolman. Line #215 was originally built in
1950. The 10-year maintenance plan for this line began in 2022 with the pole
inspection and groundline treatment, followed by design in 2023 and construction
in 2024.
b. When defects on existing lines are identified, repairs must be implemented to
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 55

correct those defects. There are no other alternatives available.
c. A specific project plan could not be located. However, the following provides more
information related to the project:
i. The project scope included repairing or replacing deteriorated poles,
crossarms, and insulators identified during the pole inspection and ground line
treatment program and the annual routine line patrols. After inspection and
preparation of the corrective action plan, 114 defects were found requiring
either the replacement of poles or the addition of wood stubs to support existing
poles.
ii. The original budget, approved by executive management during the annual
budget cycle in September 2021, of $270,000 was a high-level estimate
because the inspection was to be conducted the following year (2022) with an
expected completion date in December 2024. The budget was subsequently
updated once the inspection and corrective action plan were complete. The
updated estimate of $1,115,000 was set in July 2023 and reviewed and
approved by the Company's executive management. The anticipated original
schedule included scoping in 2022, design in 2023, and construction in 2024.
A detailed schedule was not developed until after the project was approved and
a project manager and design team were assigned. The schedule and cost
estimate prepared at the beginning of construction after the project was
designed, can be found in Response to Request for Production No. 102 —
Confidential Attachment 1.
iii. See part ii above.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 56

iv. See the Company's Response to Request for Production No. 17(a)(iv) for an
explanation of the capital project budget approval processes. The creation of
Budget ID T215210001 for the work on Line #215 as well as the CLRIS
screenshot provided as Response to Request for Production No. 102 —
Attachment 2 is evidence of approval of the initial budget.
d. See Response to Request for Production No. 102 — Confidential Attachment 3
which shows the forecasted project costs each quarter with supporting notes
characterizing any variances.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 57

REQUEST FOR PRODUCTION NO. 103: The Company's response to Staff
Production Request No. 20 included several attachments in which the total Transmission
Line 423 project budget and completion date is different from the costs and dates
identified in Colburn's Direct at 6. Please answer the following:
a. Please provide actual spend to date by year and total in-service expenditures by
year for this project.
b. Please explain if any of this project was recovered in the previous rate case. If so,
please provide the amount that was recovered.
c. Please identify the total cost of the project that the Company is seeking recovery
of this project in this rate case.
d. Please reconcile the project budget from the following:
i. Colburn Direct at 6: $15 million;
ii. Response to Request No. 20(e) -Variance Notes: $29,150,509;
iii. Response to Request No. 20(e) — WBS: $29,323,195; and
iv. Response to Request No. 17(a) — Confidential Attachment 2:
e. Please identify each component of the budget to include each winning RFP bids,
materials, AFUDC, etc. Additionally, please identify the updated costs of
construction, design, steel poles, labor, etc. from the latest Change Orders.
f. Please reconcile the following two expected project completion dates with
Colburn's testimony of October 2024:
i. Response to 20(e) — Attachment 1 WBS: 1/17/25; and
ii. Response to 20(c) - Confidential Attachment 12- Construction Winning Bid —
Schedule: _.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 58

RESPONSE TO REQUEST FOR PRODUCTION NO. 103:
a. Please see the Response to Request No. 17(a) Confidential Attachment 2, the
Budget Update — Authorized to Spend file, for actuals through June 30, 2024. No
work orders associated with this Budget ID have been placed in service in 2024
yet.
b. Two work orders associated with this Budget ID have been placed in service prior
to 2024, WO 27601981 was placed in service in 2022 for $14,854 and WO
27567260 for$93,471. However, these amounts are not a part of the $14.98 million
in project costs requested in this case.
c. See Larkin Workpaper 3. Idaho Power is seeking recovery of project costs of
$14.98 million in this case. Note, the project costs included in the Company's
request in this case are associated with only one work order though the entire
project Budget ID is inclusive of multiple work orders.
d. The following is a reconciliation of the project amounts presented in various
documents:
i. Colburn Direct at 6: $15 million; This amount references the 2024 Wildfire
Mitigation Plan which reflects the rounded version of project costs presented in
Larkin's Workpaper 3.
ii. Response to Request No. 20(e) - Variance Notes: $29,150,509; See part (c)
above. The Variance Notes include project costs associated with the Budget
ID, which is inclusive of multiple work orders, including the one associated with
the amounts presented in Larkin Workpaper 3. Because the project is managed
in MS Project Server at the Budget ID level, Idaho Power is unable to provide
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 59

notes specific to just the one work order.
iii. Response to Request No. 20(e) — WBS: $29,323,195; See part (d)(ii) above.
The WBS includes costs associated with the entire Budget ID.
iv. Response to Request No. 17(a)—Confidential Attachment 2: This
is the sum of the original approved annual budget amounts. Recall, 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. Therefore, summing the original approved annual budget
amounts is not an accurate reflection of the approved budget in totality.
e. The Variance Notes provided as the Response to Request for Production No. 20(e)
— Attachment 2 show the first budget established was $15,601,701 with 2019
Recast 3. However, the level of budget detail requested was not available until the
2022 Recast 3, performed in July 2022. The following chart summarizes the 2022
Recast 3 budget of $26,420,797, by component. It also includes the budget by
component for each subsequent budget update as well as actual project costs by
component as of August 23, 2024. Note, AFUDC is not included in budget
estimates as it is not tracked in MS Project Server, therefore the actual costs to
date presented below also do not include AFUDC.
Category Budget Budget Budget Budget Actual Cost
Jul 2022 Apr 2023 Jan 2024 Apr 2024 To Date
Labor $723,181 $923,440 $443,835 $459,561 _
Materials $10,537,400 $10,414,272 $12,330,441 $12,829,743 -
Purchased Services $15,065,506 $15,205,125 $14,726,855 $15,578,627 -
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 60

Other Expenses $94,709 $97,860 $203,361 $282,577 _
Total $26,420,797 $26,640,697 $27,704,492 $29,150,509 -
f. The following is a reconciliation of two expected project completion dates provided
in prior data responses with the project completion date of October 2024 in Mr.
Colburn's testimony. Please note, the scheduled in-service date has been moved
out from October 2024 to December 2024 since submittal of Colburn's testimony.
i. Response to 20(e) — Attachment 1 WBS: 1/17/25 — Because the Company
anticipates the final payment of approximately $23k for construction support
services to be made in January 2025, following the in-service date of the
project, the WBS shows a completion of all activity on January 17, 2025.
ii. Response to 20(c) - Confidential Attachment 12- Construction Winning Bid —
Schedule: — This reflects the forecasted in-service date at the time the
winning bid was submitted, April 2024. While the Company initially anticipated
an in-service date in October 2024, it now appears the in-service date will align
more with the winning bid estimate.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 61

REQUEST FOR PRODUCTION NO. 104: The Company's response to Staff
Production Request No. 21 included several attachments in which the total Transmission
Line 902 project budget and completion date is different from the costs and dates
identified in Colburn's Direct at 9. Please answer the following:
a. Please provide actual spend to date by year and total in-service expenditures by
year for this project in excel format.
b. Please explain if any of this project was recovered in the previous rate case. If so,
please provide the amount that was included as recovered.
c. Please identify the total cost that the Company is seeking recovery of this project
in this rate case.
d. Please reconcile the project budget from the following:
i. Colburn Direct at 9: $21.2 million;
ii. Response to Request No. 20(e) -Variance Notes: $20,514,727; and
iii. Response to Request No. 17(a) Confidential Attachment 2:
e. Please identify each component of the budget to include each winning RFP bids,
materials, AFUDC, etc. Additionally, please identify the updated costs of
construction, design, steel poles, labor, etc. from the latest Change Orders.
f. Please reconcile the following two expected project completion dates with
Colburn's testimony of December 2024:
i. Response to 20(e) —Attachment 1- WBS: 12/29/26; and
ii. Response to 20(c) - Confidential Attachment 6- Winning Bid — MPE
Construction Schedule:M.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 62

RESPONSE TO REQUEST FOR PRODUCTION NO. 104:
a. Please see the Response to Request No. 17(a) — Confidential Attachment 2, the
Budget Update—Authorized to Spend file, that includes actual spend through June
30, 2024. No work orders associated with this Budget ID have been placed in
service in 2024 yet.
b. There were no costs associated with the project included in the 2023 general rate
case test year.
c. See Larkin Workpaper 3. Idaho Power is seeking recovery of project costs of
$21.17 million in this case.
d. The following is a reconciliation of the project amounts presented in various
documents:
i. Colburn Direct at 9: $21.2 million: This amount reflects the rounded version of
project costs presented in Larkin's Workpaper 3.
ii. Response to Request No. 21(e) - Variance Notes: $20,514,727: This amount
reflects the budget estimate as of April 2024.
iii. Response to Request No. 17(a) Confidential Attachment 2: This
is the sum of the original approved annual budget amounts. Recall, 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. Therefore, summing the original approved annual budget
amounts is not an accurate reflection of the approved budget in totality.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 63

e. The following chart summarizes the initial budget of $21,807,340 as presented in
the Variance Notes provided as the Response to Request 21(e) — Attachment 2,
by component. It also includes the budget by component for each subsequent
budget update as well as actual project costs by component as of August 23, 2024.
Note, AFUDC is not included in budget estimates as it is not tracked in MS Project
Server, therefore the actual costs to date presented below also do not include
AFUDC.
Category Budget Budget Budget Actual Cost
Apr 2023 Jan 2024 Apr 2024 To Date
Labor $82,340 $89,715 $51,055 _
Materials $11,400,000 $12,449,053 $12,365,340
Purchased Services $10,325,000 $6,810,020 $8,060,420
Other Expenses $14,521 $37,913 _
Total $21,807,340 $19,273,594 $20,463,672
f. The following is a reconciliation of two expected project completion dates provided
in prior data responses with the project completion date of December 2024 in Mr.
Colburn's testimony:
i. Response to 21(e) —Attachment 1- WBS: 12/29/26: Idaho Power identified an
error in the completion date presented in the WBS provided in the Response
to Request for Production No. 21(e) — Attachment 1. The project completion
date for the Rattlesnake to DRAM portion of the line is December 13, 2024.
Please see the Supplemental Response to Request No. 21(e) — Attachment 1
for the corrected WBS.
ii. Response to 21(c) - Confidential Attachment 6 - Winning Bid — MPE
Construction Schedule: 5/31/24: Upon investigation, it was determined that the
winning bid provided as the Company's Response to 21(c) — Confidential
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 64

Attachment 6 was not the winning bid for this phase of the project. Please see
the Supplemental Response to Request No. 21(c) — Confidential Attachment 1
for the correct MPE winning bid. Note, the preliminary construction schedule
identified a final completion of December 2024. It was also discovered the RFP
and the bid evaluation provided for the construction services was associated
with a different phase of the project. Please see the Supplemental Response
to Request No. 21(c) —Attachment 2 for the correct RFP for construction
services and Supplemental Response to Request No. 21(c) — Confidential
Attachment 3 for the correct construction services bid evaluation.
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 65

REQUEST FOR PRODUCTION NO. 105: Please provide copies of all invoices
and other supporting documentation, such as contracts, incentive requests, approvals,
and calculations for the expenses listed on "Capital Project Data Request June 2024 pt
2" (Confidential Attachment No. 1). Please also provide the following data in Excel format
for each individual expense for the projects:
a. Invoice date;
b. Invoice number;
c. Invoice amount; and
d. Invoice purpose (Services performed and/or materials purchased, etc.).
RESPONSE TO REQUEST FOR PRODUCTION NO. 105:
Please see Response to Request for Production No. 105 - Confidential
Attachments 1 through 11 providing supporting documentation for the expenses selected
in Staff's sample, "Capital Project Data Request June 2024 pt 2" (Confidential Attachment
No. 1).
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 66

DATED at Boise, Idaho, this 9t" 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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 67

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 9t" day of September 2024, 1 served a true and
correct copy of Idaho Power Company's Response to the Twelfth 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 [e-mail]
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 TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 68

Idaho Conservation League Hand Delivered
Brad Heusinkveld U.S. Mail
710 N. 6t" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email
bheusinkveld(aD.idahoconservation.org
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(a-)hollandhart.com
Denver, CO 80202 tnelson hollandhart.com
awiensen(a)hollandhart.com
karoach(a�hol land hart.com
aclee hol land hart.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
swierC@_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 BoiseCityAttorney_(a)cityofboise.org
eiewell(a-)-cityofboise.org
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 69

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
sh u bbleCcDcityofboise.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(o-)hg.doe.gov
emily.medlyn(a-),hg.doe.gov
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER - 70