HomeMy WebLinkAbout20240925IPC 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