20240912IPC to Staff 113-119.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 12, 2024

VIA ELECTRONIC FILING

Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-24-07
Application of Idaho Power Company for Authority to Increase Rates for
Electric Service to Recover Costs Associated with Incremental Capital
Investments and Certain Ongoing Operations and Maintenance Expenses

Dear Commission Secretary:

Attached for electronic filing, please find Idaho Power Company’s Response to the
Fourteenth Production Request of the Commission Staff to Idaho Power Company.

Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.

The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site will be provided to the parties that execute the
Protective Agreement in this matter.

Given the significant time and resources required to individually label each
confidential document contained in the confidential attachments, Idaho Power has instead
marked the entirety of the contents contained within Production Response Nos. 116
Confidential Attachment 2, and 117 Confidential Attachment 2, confidential by designating
the Attachment folder and individual file name as “CONFIDENTIAL”. When downloading
the zip folder, please save the zip file to your desktop to avoid any errors with the lengthy
file names.

RECEIVED
Thursday, September 12, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
' a1DA11> POWER .
Commission Secretary
Idaho Public Utilities Commission
September 12, 2024
Page 2

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-24-07
Idaho Power Company’s Application for Authority to Increase Rates for Electric
Service to Recover Costs Associated with Incremental Capital Investments and
Certain Ongoing Operations and Maintenance Expenses
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that portions of text in response to Requests No. 115 and some of the
attachments to Request Nos. 116,117, 118, and 119 to Idaho Power Company’s
Response to the Fourteenth Production Request of the Commission Staff dated
September 12, 2024, contain 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 12th day of September 2024.
Lisa D. Nordstrom
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

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

CASE NO. IPC-E-24-07

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fourteenth Production Request of the Commission Staff (“Commission”
or “Staff”) to Idaho Power Company dated August 29, 2024, herewith submits the
following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 113: In the Company’s Confidential
Attachment “” provided in
response to Production Request No. 21(a), details there was a fire damage to existing
poles. Please explain if the Company received any funds from insurance for the damaged
poles. If so, please provide the amount that was received by insurance and explain how
it was applied to the total project cost.
RESPONSE TO REQUEST FOR PRODUCTION NO. 113: The Company did not
receive any funds from insurance proceeds as Idaho Power self-insures its transmission
and distribution lines and poles.
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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 114: If any proceeds from insurance claims
were received for any damages or repairs that involved capitalized plant or initiated
additional capital expenditures, please provide the associated capital project and
accounting treatment.
RESPONSE TO REQUEST FOR PRODUCTION NO. 114: Idaho Power has a
policy with FM Global that provides coverage for damage/loss to the Company’s property
and equipment, other than to transmission and distribution lines and poles, caused by
incident though the policy has occurrence retention levels that vary by facility and/or plant.
1st Party Property Claims (filed by Idaho Power): There were two separate claims
filed by Idaho Power for which the Company received insurance proceeds during the
January 1, 2023, through August 31, 2024, time period:
 The first claim occurred at Midpoint substation due to electrical breakdown of a
transformer. Idaho Power received $3,457,524 in insurance proceeds which were
applied as a credit to Federal Energy Regulatory Commission (“FERC”) Account
108 – Accumulated Provision for Depreciation (“FERC Account 108”). Please see
the Response to Request for Production No. 114 – Attachment 1 for supporting
documentation of the proceeds.
 The second claim occurred at the Hells Canyon power plant due to damage to
generator unit #1. Idaho Power received $5,300,000 in insurance proceeds which
were applied as a credit to FERC Account 108. Please see the Response to
Request for Production No. 114 – Attachment 2 for supporting documentation of
the proceeds.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 4
Note, these amounts were credited to FERC Account 108 in accordance with the
Uniform System of Accounts in the Code of Federal Regulations, Title 18:
108 Accumulated Provision for Depreciation of Electric Utility Plant (Major only)
B. At the time of retirement of depreciable electric utility plant, this account shall be
charged with the book cost of the property retired and the cost of removal and shall be
credited with the salvage value and any other amounts recovered, such as insurance.
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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 115: Please provide the following information
associated with the components (e.g., Capacitor Bank, Control System Building, and
Construction) of Budget ID :
a. The actual in-service date for each individual component of the project.
b. A breakdown of the total actual cost of the project, first by Idaho Power and joint
owner, PacifiCorp, then for each component and finally by cost category
(materials, purchased services, AFUDC, overheads, etc.) in workpapers with
formulas intact.
c. Please reconcile the project budget against the following:
i. Response to Request No. 22(e) -Variance Notes: ; and
ii. Response to Request No. 17(a) – Confidential Attachment 2: .
d. Please reconcile the following actual costs against the following:
i. Second Supplemental Response to Staff’s Request No. 5 - Confidential
Attachment - Capital Projects Completed Thru June 2024: $ ; and
ii. Response to Request No. 17(a) – Confidential Attachment 2: $.
RESPONSE TO REQUEST FOR PRODUCTION NO. 115:
a. See the Company’s Third Supplemental Response to the Request for Production
No. 5 – Confidential Attachment 1 for a list of the plant closings for the January
through July 2024, time period. As can be seen, two work orders associated with
Budget ID MPSN210001 were placed in service in January 2024.
b. The following provides a breakdown of the actual project costs by cost component
as of July 31, 2024. Note, the payments received from PacifiCorp are reflected on
the Contribution in Aid of Construction (“CIAC”) line.
-

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 6
MPN210001 Charges  

Labor  
Materials  
Purchased Services   
Other Expenses  
AFUDC  
CIACS 
Overheads   
Total  

c. The following is a reconciliation of the project budget against:
i. Response to Request No. 22(e) - Variance Notes: – This amount
represents the estimated total project cost as of April 2024. Note, this amount
does not include Allowance for Funds Used During Construction or overheads.
ii. Response to Request No. 17(a) – Confidential Attachment 2: $ –
This amount is the sum of the approved 2021, 2022, and 2023 Budget Update
4 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 approved
budget amounts for that year stay as originally approved. Therefore, summing
the approved budget amounts is not an accurate reflection of the approved
budget in totality.
d. The following is a reconciliation of the actual project costs against:
i. Second Supplemental Response to Staff’s Request No. 5 – Confidential
Attachment - Capital Projects Completed Thru June 2024: $ – This
is the sum of the project costs through June 30, 2024. As can be seen in part
--
-

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 7
(a), some additional amounts were recorded to the project in July 2024
therefore this is not reflective of the total project costs.
ii. Response to Request No. 17(a) – Confidential Attachment 2: $
– This is the sum of the actual project costs recorded through June 30, 2024.
Note, this amount does not include Allowance for Funds Used During
Construction or overheads.
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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 8
REQUEST FOR PRODUCTION NO. 116: Please provide the following information
for Budget ID project referenced in the
Second Supplemental Response to Staff’s Request No. 5 - Confidential Attachment.
Please include any available workpapers with formulas intact. If any of the information
requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including
the following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the Work-Breakdown Structure
(“WBS”); and
iii. Contractor change orders.
c. If a Request for Proposal (“RFP”) or Request for Quote (“RFQ”) was submitted,
please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
d. Please provide the following related to completion of the project:
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 9
iii. Budget update information throughout the timeline of the project including the
original approved budget.
RESPONSE TO REQUEST FOR PRODUCTION NO. 116:
a. The Wilson Butte substation was built in 1953 with wooden poles and crossarms
which were in poor condition and rotting due to the passage of time. The T051
transformer was manufactured in 1959 and was approximately 15 years beyond
its expected reliable operating life in 2024. Repair parts were no longer available,
and the foundation was crumbling, requiring replacement. The existing distribution
automation remote terminals (“DART RTU”) were no longer manufactured or
manufacturer-supported so they cannot be repaired or replaced-in-kind when they
fail. These devices operated on outdated MS-DOS software which was causing
unreliable Supervisory Control and Data Acquisition (“SCADA”) data and false
alarm indications due to incompatibility with analog inputs from station equipment.
b. A specific project plan could not be located. However, the following provides more
information related to the project:
i. Remove wood structures and add low-side operated bus with supports and
replace with steel. Upgrade the T051 transformer with new 14 MVA transformer
and new concrete foundation pad. Install new 1200 amp all duty 051L switch.
A new two-pole steel structure to mount new 051F fused disconnect switches
is required. Upgrade the local service fused disconnect switches. Two new
steel light duty class direct buried poles with new 052T and 051T air-break
switches outside of station are required to replace the existing inoperable air-
break switches inside the substation. Replace the existing DART RTU brand

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 10
station SCADA with GE iBox-based assembly, including Bitronics M651, SEL
2032. A detailed scope of work is also included in the Statement of Work
provided as the Response to Request for Production No. 116 – Confidential
Attachment 2.
ii. The schedule prepared at the beginning of construction after the project was
designed, can be found in the Work Breakdown Structure included as the
Response to Request for Production No. 116 – Attachment 1.
iii. The Statement of Work, the contract between Idaho Power and Wasatch
Electric, is included as Response to Request for Production No. 116 –
Confidential Attachment 2. No change orders have been executed.
c. A Request for Proposal (“RFP”) bid event was completed in 2023:
i. The RFP event is included as Response to Request for Production No. 116 –
Attachment 3.
ii. The scorecard is included as Response to Request for Production No. 116 –
Confidential Attachment 4 and 5.
iii. The Statement of Work contract and bid submittal with the winning bidder is
included as Response to Request for Production No. 116 – Confidential
Attachment 2.
d. The following provides the information related to completion of the project:
i. As seen in the Third Supplemental Response to Request for Production No. 5
– Confidential Attachment 1, the three work orders associated with this project
were placed in service in April 2024.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 11
ii. See the Third Supplemental Response to Request for Production No. 5 –
Confidential Attachment 1 for project costs as of July 31, 2024.
iii. See Response to Request for Production No. 116 – Confidential Attachment 6
for budget update authorized to spend and original budget by year. Response
to Request for Production No. 116 – Confidential Attachment 7 includes the
total project forecast and variances. Note, the project costs presented in both
attachments do not include AFUDC and overheads and are as of September
5, 2024, therefore they do not tie to the amounts presented in the Third
Supplemental Response to Request for Production No. 5 – Confidential
Attachment 1 which included project costs as of July 31, 2024.
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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 12
REQUEST FOR PRODUCTION NO. 117: Please provide the following information
for Budget ID project referenced in the
Second Supplemental Response to Staff’s Request No. 5 - Confidential Attachment.
Please include any available workpapers with formulas intact. If any of the information
requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including
the following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the WBS; and
iii. Contractor change orders.
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. The short-list bidder scorecard; and
iii. A copy of the winning bid.
d. Please provide the following related to completion of the project:
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and
iii. Budget update information throughout the timeline of the project including the
original approved budget.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 13
RESPONSE TO REQUEST FOR PRODUCTION NO. 117:
a. Huntington Substation is currently served by the 69-kV transmission line from the
Weiser substation. The existing 69-kV transmission line had poles dating from the
original construction in 1927 and needed significant repair and replacement. In
addition to the general poor condition of the transmission line, the section of line
from Steck Park to Huntington is in inaccessible sections on old railroad piers in
Brownlee Reservoir and at the toes of steep slopes at the edge of Brownlee
Reservoir. Thorough analysis of alternatives concluded that the most economic
approach to restoration of this asset was to remove most of this line and serve the
existing loads via other sources. Therefore, the 69-kV transmission line was
removed, and customer load is served by adjacent 138-kV substations Huntington
and Durkee. As a result, the Huntington Substation was upgraded to 138-kV and
served from the adjacent 138-kV transmission line between Ontario and Quartz
Stations.
b. A specific project plan could not be located. However, the following provides more
information related to the project:
i. Modifications at the Huntington substation to change the transmission source
from the 69-kV T209 Weiser-Quartz transmission line to the adjacent 138-kV
T423 Ontario-Quartz transmission line. The existing substation will be
expanded to accommodate the 138-kV equipment. Replace transformer T061
with a 138:13/7.56-kV transformer relocated from Payette substation. Add a
new wave trap, new regulator bank, air-break switches, and other ancillary work
such as foundations, steel supports, and bus work. Replace the existing

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 14
distribution structures with standard aluminum low-profile structures. Install
34.5-kV disconnect switches. Replace lead cable and existing conduit with
1100 MCM Aluminum cable and new six-inch conduit. A detailed scope of work
is also included in the Project Construction Agreement provided as the
Response to Request for Production No. 117 – Confidential Attachment 2.
ii. The schedule prepared at the beginning of construction after the project was
designed can be found in Response to Request for Production No. 117 –
Attachment 1.
iii. The Project Construction Agreement, the contract between Idaho Power and
Cardinal, is included as Response to Request for Production No. 117 –
Confidential Attachment 2. No change orders have been executed.
c. An RFP bid event was completed in 2023:
i. The RFP event is included as Response to Request for Production No. 117 –
Attachment 3.
ii. The scorecard is included as Response to Request for Production No. 117 –
Confidential Attachment 4 and 5.
iii. The Project Construction Agreement and bid submittal from the winning bidder
is included as Response to Request for Production No. 117 – Confidential
Attachment 2.
d. The following provides the information related to completion of the project:
i. As seen in the Third Supplemental Response to Request for Production No. 5
– Confidential Attachment 1, the work order associated with this project was
placed in service in February 2024.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 15
ii. See the Third Supplemental Response to Request for Production No. 5 –
Confidential Attachment 1 for project costs as of July 31, 2024.
iii. See Response to Request for Production No. 116 – Confidential Attachment
6 for budget update authorized to spend and original budget by year.
Response to Request for Production No. 117 – Confidential Attachment 6
includes the total project forecast and variances. Note, the project costs
presented in both attachments do not include AFUDC and overheads and are
as of September 5, 2024, therefore they do not tie to the amounts presented
in the Third Supplemental Response to Request for Production No. 5 –
Confidential Attachment 1 which included project costs as of July 31, 2024.
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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 16
REQUEST FOR PRODUCTION NO. 118: Please provide the following information
for Budget ID project referenced in the
Second Supplemental Response to Staff’s Request No. 5 - Confidential Attachment.
Please include any available workpapers with formulas intact. If any of the information
requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including
the following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the WBS; and
iii. Contractor change orders.
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. The short-list bidder scorecard; and
iii. A copy of the winning bid.
d. Please provide the following related to completion of the project:
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and
iii. Budget update information throughout the timeline of the project including the
original approved budget.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 17
RESPONSE TO REQUEST FOR PRODUCTION NO. 118:
a. The silencing baffles at the Bennett Mountain power plant (“Bennett Mountain”),
which are required to stay in compliance with the City of Mountain Home noise
permit, had experienced damage due to ordinary wear and tear and the Company
had been performing major repairs for several years. An emergency repair requires
the plant to be shut down and the baffles are not easily accessible, requiring down
time at the plant. The integrity of the baffles was questionable for long-term use,
and with a long lead time for new baffles, in 2022 it was recommended they were
replaced. However, in September 2023, Bennett Mountain was forced into an
outage due to metal shrapnel being ejected from the exhaust stack. Idaho Power
maintenance crews inspected the exhaust and found one baffle section that had
failed and others that were concerning. Due to the emergency nature of the
situation, the Company contacted three third-party vendors for repair proposals
while a plan to replace the exhaust baffles was developed.
The plan was that the vendor would inspect the baffles and remove the
compromised ones in order to get the unit back online as quickly as possible. Only
one vendor was able to meet Idaho Power’s proposed repair timeline. An
agreement was executed, and the repairs performed on October 3, 2023.
However, upon inspection, it was clear the baffles would need to be removed,
repaired, and replaced except for the one baffle section that had failed.
Reinstallation was required to stay compliant with the noise permit.
b. A specific project plan could not be located. However, the following provides more
information related to the project:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 18
i. Following inspection of the damaged baffles, it was determined the baffles at
Bennett would need to be removed, repaired, and replaced with the exception of
the one baffle section that had failed and required replacement.
ii. The only WBS the Company can provide for the project is reflective of the most
recent budget and schedule which shows the project is complete, as shown in
the Company’s Response to Request for Production No. 118 – Attachment 1.
However, as seen on the final page of the WBS, the work was initially scheduled
to be performed during the October 2023 through June 2024 time period.
iii. Please see the Response to Request for Production No. 118 – Confidential
Attachment 2 for the change order that was a result of the change in scope
following the initial inspection, leading to the repair and replacement of the
baffles.
c. Due to the urgency of the work needed and the associated impacts to reliability, a
formal competitive solicitation event was not performed.
i. Not applicable. However, the Company has included as the Response to
Request for Production No. 118 – Attachment 3 the Procurement Justification
document for sole sourcing SVI Dynamics.
ii. A short-list bidder scorecard is not available; however the bids received are
included as the Response to Request for Production No. 118 – Confidential
Attachment 4 (SVI Dynamics), Response to Request for Production No. 118 –
Confidential Attachment 5 (Schock Manufacturing), and Response to Request
for Production No. 118 – Confidential Attachment 6 (Durr Universal). As

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 19
evidenced on the Procurement Justification documentation, SVI Dynamics was
the most cost-effective solution.
iii. Please see the SVI Dynamics proposal provided as the Response to Request
for Production No. 118 – Confidential Attachment 4.
d. The following provides the information related to completion of the project:
i. As seen in the Third Supplemental Response to Request for Production No. 5
– Confidential Attachment 1, this project was placed in service in April 2024.
ii. See the Third Supplemental Response to Request for Production No. 5 –
Confidential Attachment 1 for project costs as of July 31, 2024.
iii. See Response to Request for Production No. 116 – Confidential Attachment 6
for budget update authorized to spend and original budget by year. Response
to Request for Production No. 118 – Attachment 7 includes the total project
variance explanations. Note, the project costs presented in both attachments
do not include AFUDC and overheads, therefore they do not tie to the amounts
presented in the Third Supplemental Response to Request for Production No.
5 – Confidential Attachment 1 which included project costs as of July 31, 2024.
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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 20
REQUEST FOR PRODUCTION NO. 119: Please provide the following information
for Budget ID project referenced in
the Second Supplemental Response to Staff’s Request No. 5 - Confidential Attachment.
Please include any available workpapers with formulas intact. If any of the information
requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the
analysis justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including
the following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the WBS; and
iii. Contractor change orders.
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. The short-list bidder scorecard; and
iii. A copy of the winning bid. See attachments
d. Please provide the following related to completion of the project
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and
iii. Budget update information throughout the timeline of the project including the
original approved budget.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 21
RESPONSE TO REQUEST FOR PRODUCTION NO. 119:
a. The silencing baffles at the Danskin power plant (“Danskin”), which are required to
stay in compliance with the Elmore County noise permit, were inspected during the
fall 2023 major outage and found to have extensive damage at the weld seams,
were missing insulation in some sections, and had multiple retention bars that had
come off. The baffles were showing signs of failure. An emergency repair requires
the plant to be shut down and the baffles are not easily accessible, requiring down
time at the plant. Continued repairs were not recommended due to the damage,
and in October 2023 it was recommended they were replaced. This was the same
time the Bennett Mountain baffles were undergoing inspection and repair;
therefore the Company included in the repair proposal request to the third-party
vendors a solicitation for baffle repairs at Bennett Mountain and baffle
replacements at Danskin. Two vendors provided proposals, however only one
vendor was able to meet Idaho Power’s proposed replacement timeline.
b. A specific project plan could not be located. However, the following provides more
information related to the project:
i. The scope of work included the replacement of the exhaust silencer, including
new silencing baffles.
ii. The only WBS the Company can provide for the project is reflective of the most
recent budget and schedule which shows the project is complete, as shown in
the Company’s Response to Request for Production No. 119 – Attachment 1.
However, as seen on the final page of the WBS, the work was initially

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 22
scheduled to be performed during the October 2023 through June 2024 time
period.
iii. There were no change orders associated with this project.
c. Due to the urgency of the work needed and the associated impacts to reliability, a
formal competitive solicitation event was not performed.
i. Not applicable. However, the Company has included as the Response to
Request for Production No. 119 – Attachment 2 the Procurement Justification
document for sole sourcing SVI Dynamics. Note, the Procurement Justification
form erroneously states in the Request Description and description of services
section that the work is associated with Bennett Mountain. However, the
description is incorrect, as evidenced by the Procurement Justification provided
as the Response to Request for Production No. 118 – Attachment 3 which
details the requested Bennett Mountain work.
ii. A short-list bidder scorecard is not available however the bids received are
included as the Response to Request for Production No. 119 – Confidential
Attachment 3 (SVI Dynamics) and Response to Request for Production No.
119 – Confidential Attachment 4 (Durr Universal). As evidenced on the
Procurement Justification documentation, SVI Dynamics was the most cost-
effective solution.
iii. Please see the SVI Dynamics proposal provided as the Response to Request
for Production No. 119 – Confidential Attachment 3.
d. The following provides the information related to completion of the project:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 23
i. As seen in the Third Supplemental Response to Request for Production No. 5
– Confidential Attachment 1, this project was placed in service in May 2024.
ii. See the Third Supplemental Response to Request for Production No. 5 –
Confidential Attachment 1 for project costs as of July 31, 2024.
iii. See Response to Request for Production No. 116 – Confidential Attachment 6
for budget update authorized to spend and original budget by year. Response
to Request for Production No. 119 – Attachment 5 includes the total project
variance explanations. Note, the project costs presented in both attachments
do not include AFUDC and overheads, therefore they do not tie to the amounts
presented in the Third Supplemental Response to Request for Production No.
5 – Confidential Attachment 1 which included project costs as of July 31, 2024.
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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 24
DATED at Boise, Idaho, this 12th 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 FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 25
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 12th day of September 2024, I served a true and
correct copy of Idaho Power Company’s Response to the Fourteenth Production Request
of the Commission Staff to Idaho Power upon the following named parties by the method
indicated below, and addressed to the following:

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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

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Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 26
Idaho Conservation League
Brad Heusinkveld
710 N. 6th Street
Boise, Idaho 83702
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

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

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IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 27
Steven Hubble
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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

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Stacy Gust
Regulatory Administrative Assistant

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