The URL can be used to link to this page

Home My WebLink About20240925IPC to Staff 122-126.pdf MqN -�IQAFIO R® LISA D. NORDSTROM Lead Counsel InordstrornCaNdahopower.com RECEIVED Wednesday, September 25, 2024 IDAHO PUBLIC September 25, 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 Sixteenth 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. If you have any questions about the attached filing, please do not hesitate to contact me. Sincerely, Lisa D. Nordstrom LDN:cd Attachments 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 Attachment No. 2 to Production Request No.122 of Idaho Power Company's Response to the Sixteenth Production Request of the Commission Staff to Idaho Power Company dated September 25, 2024, contains information that Idaho Power Company and/or a third party claim is a confidential trade secret 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 25th 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: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(a)_idahopower.com dwalker idahopower.com mgoicoecheaallen(o)_idahopower.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 SIXTEENTH 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 Sixteenth Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated September 18, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 1 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 122: This information technology equipment purchase was sole sourced. Idaho Power's existing network equipment are comprised of Cisco products, and it is necessary to replace technology with a compatible product that works within the Company's existing infrastructure. Please see the Response to Staff Request No. 122 — Attachment 1 for a copy of the material procurement justification form. The Response to Staff Request No. 122 — Confidential Attachment 2 includes the quotes received for the products. Note, Cisco requires the Company to work with a designated reseller to purchase their equipment, therefore only one quote was received from Idaho Power's designated reseller, Compunet. 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 SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 2 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 123: As explained in the Response to Request for Production No. 76, the invoices include both capital and operations and maintenance ("O&M") expenses; therefore, the total of the invoices will not equal the total of the capital expenditures provided in the Response to Request for Production No. 5 — Confidential Attachment. In addition, the amounts reflected on the invoices do not include Allowance for Funds Used During Construction ("AFUDC") or overheads which are included in the amounts shown in the Response to Request for Production No. 5 — Confidential Attachment. Note, line items on the invoice that include 8X5XNBD in the title or that indicate they are for a license and support are recorded as O&M expenses. 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 SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 3 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 124: None of the items shown on the four invoices are inventory items. 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 SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-4 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 125: Idaho Power distributes email notifications, Short Messaging Services (SMS) text notifications, and push notifications through the My Account mobile application through the system created by the Outage Alert Auto Enrollment project. These notifications inform customers of outages and associated status, cause, estimated time of restoration, and restoration. 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 SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 5 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 126: As explained in the Company's Response to Request for Production No. 77, the invoices are associated with the contract payments to the vendor. Because the work was primarily performed by Idaho Power personnel, project costs also included internal labor charges and therefore the total of the invoices will not equal the total of the expenditures provided in the Response to Request for Production No. 5 — Confidential Attachment. In addition, the amounts reflected on the invoices do not include AFUDC or overheads which are included in the amounts shown in the Response to Request for Production No. 5 — Confidential Attachment. 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 SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 6 DATED at Boise, Idaho, this 25th 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 SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25th day of September 2024, 1 served a true and correct copy of Idaho Power Company's Response to the Sixteenth 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(a-),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. 27t" Street FAX Boise, Idaho 83702 FTP Site X Email peter _richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dread ing(@ mindsprinq.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(o)_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 SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 8 Idaho Conservation League Hand Delivered Brad Heusinkveld U.S. Mail 710 N. 6th 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 17th Street, Suite 3200 darueschhoff(�Oollandhart.com Denver, CO 80202 tnelson(o)_hollandhart.com awjensen ,hollandhart.com karoach(o�hol land hart.com aclee hollandhart.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 jswier(c)_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(o)_cityofboise.org ejewell cityofboise.org IDAHO POWER COMPANY'S RESPONSE TO THE SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 9 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 shubble(aD.cityofboise.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 peter.meier(o-)_hg.doe.gov emily.medlyn(q-),hg.doe.gov (I Christy Davenport Legal Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE SIXTEENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 10