20240918Staff 122-126 to IPC.pdf

SIXTEENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 SEPTEMBER 18, 2024
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810

Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

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

SIXTEENTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY

Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company (“Company”)
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, SEPTEMBER 25, 2024.1
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of

1 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff’s
attorney at [phone].
RECEIVED
Wednesday, September 18, 2024 3:09:59 PM
IDAHO PUBLIC
UTILITIES COMMISSION

SIXTEENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 SEPTEMBER 18, 2024
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.

REQUEST NO. 122: For Budget ID B01100010 – Network Infrastructure Lifecycle,
please explain the procurement process that was followed for the items purchased under this
project. Additionally, please provide any quotes or bids received from other vendors.

REQUEST NO. 123: For Budget ID B01100010 – Network Infrastructure Lifecycle,
please reconcile the four invoices that total $1,275,304, provided in the response to Production
Request No. 76, with the expenditure shown on the third supplemental response provided for
Production Request No. 5 – Attachment 1 of $1,017,476.

REQUEST NO. 124: For Budget ID B01100010 – Network Infrastructure Lifecycle,
please identify which items shown on the four invoices provided in the response to Production
Request No. 76 are inventory items and not utilized in the replacement of the 57 switches and 18
routers that were needed.

REQUEST NO. 125: As a follow-up to Production Request No. 77 for Budget ID
PLZ1230013 – Outage Alert Auto Enrollment, please clearly identify all notification types which
are distributed to customers through the system created by this project.

REQUEST NO. 126: As a follow-up to Production Request No. 77 for Budget ID
PLZ1230013 – Outage Alert Auto Enrollment, please reconcile the amount shown on the
invoices provided in the Company’s response that total $400,771, with the expenditure shown on
the third supplemental response provided for Production Request No. 5 – Attachment 1 of
$1,173,749.