20130522IPC to Glanbia 1-13.pdf

LISA D. NORDSTROM
Lead Counsel
SIHm*
An IDACORP Company
May 22,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-13-09
Glanbia Petition f6r Rule H Allowance - ldaho Power Company's Response
to the First Production Request and Request for Admissions of Glanbia
Foods, lnc., to ldaho Power Company
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's Response to the First Production Request and Request forAdmissions
of Glanbia Foods, lnc., ("Glanbia") to ldaho Power Company. Also, enclosed are four (4)
copies of a confidentialdisk containing data responsive to Glanbia's Production Request
Nos. 1 , 3, 4,7 , and 12 to ldaho Power Company.
Very truly yours,
/<r,r..n Z(*Utr,,*
Lisa D. Nordstrom
LDN:evp
Enclosures
1221 W. ldaho St. (83702)
PO. 8ox 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@ idahopower. com
ih i lto n@idahopower. com
Attorneys for ldaho Power Company
IN THE MATTER OF THE PETITION OF
GLANBIA FOODS, INC. FOR
APPROVAL OF A LINE EXTENSION
ALLOWANCE PURSUANT TO IDAHO
POWER COMPANY'S RULE H.
CASE NO. IPC-E-13-09
IDAHO POWER COMPANY'S
RESPONSE TO GLANBIA FOODS,
INC.'S, FIRST PRODUCTION
REQUEST AND REQUEST FOR
ADMISSIONS TO IDAHO POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to Glanbia Foods, lnc.'s, ("Glanbia") First Production Request and Request for
Admissions to ldaho Power dated May 1, 2013, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 1
REQUEST FOR ADMISSION NO. 1: Please admit that the North American
Electric Reliability Corporation defines the distinction between transmission and
distribution by function and not size. Reference:
http://www.qooqle.com/url?sa=t&rct=i&o=olossarv%20of%2Oterms%20used%20in%20n
erc%20reliabilitv%2ostandards&source=web&cd=1&ved=0CDAeFiAA&url=http%3A%2
F%2Fwww.nerc.com%2Ffiles%2FGlossarv of Terms.pdf&ei=lwWAUevll42E|wLR6YD
o BQ&uso =AFQjCN EYg u93FXo il r-7 E9 N Ca MJTWc6 hfw&bvm=bv. 4592 1 1 28,d. cG E
ANSWER TO ADMISSION NO. 1: The North American Electric Reliability
Corporation ("NERC") definitions speak for themselves. However, based on the
Company's review of the referenced document, the North American Electric Reliability
Corporation recognizes some distinctions between transmission and distribution based
on either function or size.
The document states the definition of a Transmission Line is "A system of
structures, wires, insulators and associated hardware that carry electric energy from
one point to another in an electric power system. Lines are operated at relatively high
voltages varying from 69 kV up to 765 kV, and are capable of transmitting large
quantities of electricity over long distances." By this definition, Glanbia's request for
construction of a ten mile 138 kilovolt ("kV') line would be a Transmission Line, which is
in alignment with the Company's characterization of the request for service.
The Company respectfully points out that while the North American Electric
Reliability Corporation may maintain a glossary of terms used in NERC Reliability
Standards, the Company adheres to its Rule B in the ldaho Public Utilities Commission-
approved ("Commission") tariff when defining a distinction between its Secondary,
Primary, and Transmission Service levels.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 2
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 3
REQUEST FOR ADMISSION NO. 2: Glanbia's Petition at page 4 provides:
ldaho Power has refused to entertain the concept of an allowance
for the Glanbia project despite Dr. Reading's assurances that he
calculated the Glanbia allowance using the identical methodology
used by the Staff in calculating the generic allowances for other
classes.
And at page 5:
As can be seen by Dr. Reading's work in Exhibit B [to the Petition],
he used precisely the facilities referenced by Mr. Anderson [Exhibit
C to the Petitionl in arriving at his calculations.
Please admit or deny that Dr. Reading's work as shown in Exhibit B calculates the
allowance due to Glanbia using the identical methodology used by the Staff in
calculating generic allowances for other classes of customers. lf you deny, please
specifically identify each and every variance from said methodology used by Dr.
Reading.
Please also admit or deny that Dr. Reading's work as shown in Exhibit B uses precisely
the facilities referenced by Mr. Anderson in his letter reproduced at Exhibit C of the
Petition. lf you deny, please specifically identify each and every variance from the
facilities referenced by Mr. Anderson that you believe Dr. Reading inappropriately used
or inappropriately did not use.
ANSWER TO ADMISSION NO. 2: The Company cannot admit or deny that Dr.
Reading's work as shown in Exhibit B calculates the allowance due to Glanbia using the
identical methodology used by the ldaho Public Utility Commission Staff ("Staff') in
calculating generic allowances. While it appears that Dr. Reading has used the same
calculation/methodology that Staff used in its filed Comments in Case No. IPC-E-08-22,
the Company did not support this methodology, and the Commission did not approve
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 4
this methodology in its Final Orders. Further, while the Company is not familiar with the
underlying calculations nor does it have access to the details underlying the analysis
that Staff performed during the aforementioned Case, the Company believes Staff could
better determine if Dr. Reading used "the identica! methodology used by Staff."
The Company denies that Dr. Reading's work as shown in Exhibit B uses
precisely the facilities referenced by Mr. Anderson in his letter reproduced at Exhibit C
of the Petition. Mr. Anderson's letter provides that "Allowances under Rule H are based
on the cost of providing and installing Standard Terminal Facilities, which are the
overhead Terminal Facilities (transformer, meter, overhead service conductor) most
commonly installed for overhead single phase and three phase service." Standard
Terminal Facilities are defined in Rule H to mean:
The overhead Terminal Facilities the Company considers to be
most commonly installed for overhead single phase and three
phase services. Single phase Standard Terminal Facilities include
the cost of providing and installing one overhead service conductor
and one 25 kVA transformer to serve a 2OO amperage meter base.
Three phase Standard Terminal Facilities include the cost of
providing and installing one overhead service conductor and three
15 kVA transformers to serve a 2OO amperage meter base.
While the Company cannot provide all of the specific underlying components that
Dr. Reading used in his calculation, below are the material components the Company
used to calculate its single phase and three phase allowances which were approved by
the Commission in its most recent Rule H annual update, filed December 26,2012:
Single Phase - wedge stirrup hot tap, switch arm, switch, 25 kilovoltampere
("kVA") transformer, transformer bussing, 125 feet of service wire and a ground rod.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 5
Three Phase - three wedge stirrup hot taps, switch arm, switch, transformer
mount, three 15 kVA transformers, transformer bussing, 125 feet of service wire and a
ground rod.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 6
REQUEST NO. 1: At page 11, ldaho Power's Petition provides:
The Commission and its Staff are familiar with the validity of the
Company's construction and bidding practices, which are reviewed
during the Company's applications for Certificates of Public
Convenience and Necessity and during the annual Rule H tariff
update.
Please provide copies of the bidding practices referred to.
RESPONSE TO REQUEST NO. 1: The reviews of the Company's Rule H-
related construction practices occur annually during the Rule H update, which per
Commission Order No. 30853, must be filed no later than January 1 of each year.
Please see the confidential PDF file, provided on the confidential CD. The confidential
PDF file was included with Advice No. 12-14, filed with the Commission on December
26,2012. The calculations for the charges and allowances defined within Rule H are
contained in this document, however, it should be noted once again that Rule H does
not apply to transmission or substation facilities. The confidential CD will be provided to
those parties that have executed the Protective Agreement in this proceeding.
The statement above regarding the Staffs familiarity with the Company's bidding
practices as they relate to Certificates of Public Convenience and Necessity ("CPCN')
can be evidenced in the Company's Application filed in Case No. IPC-E-09-03. ln that
application, at page 4, Section lV RFP Process, the Company explains the Request for
Proposal ("RFP') process followed for the Langley Gulch Power Plant. Additionally, Mr.
Kar! Bokenkamp's filed testimony and exhibits from the same case provides a detailed
explanation of the Company's RFP process for that project. These documents are
publicly available on the ldaho Commission's website.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 7
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counse!, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 8
REQUEST NO. 2: Please explain in detail, with supporting documents, how the
Company's bidding practices are "reviewed" by the Commission and its Staff.
RESPONSE TO REQUEST NO. 2: Please see the Company's Response to
Glanbia's Production Request No. 1.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 9
REQUEST NO. 3: PIease provide copies of all of the Company's bidding
practices as they relate to the construction and extension of and expansion of electrical
service to industrial scale customers.
RESPONSE TO REQUEST NO. 3: The Company does not have a specific
policy for the extension of and expansion of electrical service to industrial scale
customers, but does have a policy for bid solicitations for those jobs that are not
covered under Rule H. Please see the confidential PDF file, provided on the
confidential CD, which shows the Company's policy relating to the solicitation of bids.
The confidential CD wi!! be provided to those parties that have executed the Protective
Agreement in this proceeding.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, !NC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER . 1O
REQUEST NO.4: At page 10, ldaho Powe/s Petition provides:
The Company considered whether granting Glanbia some
Company Betterment amount would be appropriate in this instance,
but after reviewing its load forecast for the area, the Company
concluded that there is no indication for additional capacity needs in
that substation in the near term.
Please provide a copy of the "!oad forecast for the area" relied on to support the
conclusion reached in that sentence along with all workpapers and supporting
documents used to prepare the same.
RESPONSE TO REQUEST NO. 4: The "load forecast for the atea" that was
relied on to support the conclusion is provided in the confidential Excel file, provided on
the confidential CD, with the tab labeled "Toponis T131 Forecast." This forecast
identified that a system improvement would not be required until 2022, at the earliest,
which is beyond the five-year near-term planning horizon. The confidentia! CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding.
Upon further consideration of the request for Company Betterment, a second
forecast, provided in the "Toponis T131 less Glanbia Fcast" tab, was developed based
on the assumption that the Glanbia facility would be served from a new substation. !n
this forecast, the Glanbia load was removed from the forecast starting year and from the
growth rate calculation. This forecast results in a maximum loading of 72 percent in
year 2026 and demonstrates the anticipated low utilization of the existing Toponis
facilities following the transfer of Glanbia from this station.
Background - The confidential Excelfile is a load forecasting tool that is used by
Idaho Power regional planners. Row 4 of the spreadsheet "Toponis T131 Forecast" tab
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 11
lists the substation transformer peak demand measurements, in kilowatts ("kW"), over
the last ten years. The annual number of customers served from the transformer is
provided in Row 5 of the spreadsheet "Toponis T131 Forecast" tab. Grovyth rates
based on the past five and ten year periods are calculated using embedded formulas in
cell 88 through C9 of the spreadsheet "Toponis T131 Forecast" tab. Load may vary
greatly from year to year as it is dependent on many factors including but not limited to:
weather, load diversity, crop rotations, irrigation patterns, and economic development.
Al! of these factors can impact the peak loading and are taken into consideration when
forecasting future demand. Therefore, the planner uses the historical load and
customer growth as well as local knowledge of the area and its growth possibilities to
determine a growth rate that best fits the area and is entered into B10 of the
spreadsheet "Toponis Tl31 Forecast" tab.
Generation located on the distribution feeders served by the substation
transformer must also be accounted for when forecasting the loading. This particular
area has seven generators connected to the distribution feeders. The power output of
these generators at the time of the transformer peak demand may also vary. The
planner includes the outage of the largest generator in the forecast to reduce the
possibility of under-forecasting the peak demand. The peak output of the largest
generator is added to the demand as shown in the spreadsheet cell H30 of the
spreadsheet "Toponis T131 Forecast" tab.
Based on the existing transformer loading, ldaho Power has identified a project
to transfer 1200kW of peak load from one of the Toponis feeders to a Gooding Rural
Substation feeder. This forecasted transformer loading reduction is included in ce!! H33
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 12
of the spreadsheet "Toponis T131 Forecast" tab. The project will be implemented when
the Toponis transformer is forecasted to exceed the substation transformer replacement
criteria. ldaho Power replaces substation transformers before they reach 98 percent of
their nameplate capacity rating. The forecasted implementation year for this project is
2020 based on the present Glanbia peak loading.
The response to this Request was prepared by Dave Angell, Delivery Planning
Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 13
REQUEST NO. 5: Please explain the rationale for the Company's policy of
restricting vested interests to distribution facilities. lf your answer is to simply reference
Rule H, please provide all documents supporting the provision in Rule H restricting
vested interest from being applicable to facilities other than distribution facilities.
RESPONSE TO REQUEST NO. 5: Please note that "the Company's policy" is to
align with Commission-approved policy embodied in approved tariffs. However, the
Company agrees with the approach to restrict the applicability of Rule H to requests for
electrical service under Schedules 1,3,4,5,7,9, 19,24,45, and 46 that require the
installation, alteration, relocation, removal, or attachment of Company-owned
distribution facilities. The Company also supports the provision within Rule H which
states, "This rule does not apply to transmission or substation facilities." To the extent
that a required substation or transmission upgrade is requested by an industrial
customer, and where those facilities otherwise would not have been needed, the
Company requires the customer to fund the investment through a contribution in aid of
construction.
The "documents supporting the provision" are the publicly available Commission-
issued Orders which have approved Rule H as it exists today.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER . 14
REQUEST NO. 6: Please provide all documentation related to Idaho Power's
granting of a vested interest in the substation facilities constructed by ldaho Power to
serve Micron Technologies' Nampa facility.
RESPONSE TO REQUEST NO.6: No vested interests existed in the substation
facilities constructed by ldaho Power to serve Micron Technologies' Nampa Facility.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 15
REQUEST NO. 7: Please identify all other instances, and document the same,
in which ldaho Power has granted a vested interest in facilities other than distribution
facilities.
RESPONSE TO REQUEST NO. 7: The Company does not feel it has "granted a
vested interest" in facilities other than distribution facilities. However, the Company is
aware of three instances in which it entered into non-standard agreements to provide
electrical substation and/or transmission facilities.
The three cases the Company identified were the Hidden Springs development,
the Tamarack development, and the Avimor development. !n all three of these cases,
the Customer requested specific deviation from the tariff that was agreed to by the
Company.
Please see the confidential PDF file, provided on the confidential CD, which is
the Hidden Springs Agreement. The confidential CD wi!! be provided to those parties
that have executed the Protective Agreement in this proceeding.
The Application, Agreement, and Commission Order approving the Tamarack
Agreement can be found on the Commission website under Case No. IPC-E-04-12.
The Application, Agreement, and Commission Order approving the Avimor
Agreement can be found on the Commission website under Case No. IPC-E-06-23.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 16
REQUEST NO. 8: Please explain the rationale for allowing subdivision
developers to have a vested interest in transformers while not allowing industrial
customers to have a vested interest in transformers and substation facilities.
RESPONSE TO REQUEST NO. 8: Subdivision developers are not "allowed" a
vested interest in transformers.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 17
REQUEST NO. 9: ldaho Power's Answer at page 9 provides:
Glanbia's proposed allowance as calculated in Exhibit B to the
Petition represents a re-packaging of a computation Staff presented
in initial comments in Case No. IPC-E-08-22, which was not
adopted by the Commission in either its initial Order No. 30853 or
its Reconsideration Order No. 300955.
Please explain what is meant by the phrase "represents a re-packaging".
RESPONSE TO REQUEST NO. 9: The Company was paraphrasing what
Glanbia stated in Exhibit B to its Petition:
The following table replicates the rate of retum and gross up used
by Staff in their calculation of allowance for Schedule 19. The
return on common equity is imputed from the other known cost of
capital values... Glanbia has verified Staff calculations with in
rounding error and accepts the allowable investment per kW of
$122... Once the line extension and plant upgrades to the plant are
completed Glanbia expects a load of 16 MW. Therefore at $122per kW the line extension allowance will be $1,952,000
(16000.122).
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 18
REQUEST NO. 10: Please document every instance in the last ten years in
which ldaho Power has granted a Rule H allowance to an industrial customer.
RESPONSE TO REQUEST NO. 10: While the Company does not maintain a list
of all existing Rule H allowances, it cannot find any circumstance where a Rule H
allowance exists for an industrial customer during the last ten years.
The response to this Request was prepared by Connie Aschenbrenner,
Regulatory Analyst, ldaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 19
REQUEST NO. 11: ldaho Power's Answer at page 11 provides:
ln fact, on February 1, 2013, ldaho Power solicited non-binding
Engineering, Procurement, and Construction (.EPC") proposals
from four contractors through the Company's Request for
lnformation ("RFl") Process.
Please describe the RFI process and provide all documentation related to how it works
and how it was developed.
RESPONSE TO REQUEST NO. 11: The Company decided to pursue
solicitations for proposals through an RFI after several meetings with Glanbia, where
Glanbia indicated dissatisfaction with the Company's construction estimates. The
Company's decision to pursue an RFI process was simply to check its own construction
estimates against the market. The Company does not have a formal process for doing
these types of RFl, rather, it pursued this option in an effort to determine up front if there
was a lower cost option for Glanbia to pursue.
Please see confidential Attachment No. 1, provided on the confidential CD, in the
Company's Response to Glanbia's Production Request No. 12 for a copy of what the
Company provided to the selected contractors. The confidential CD will be provided to
those parties that have executed the Protective Agreement in this proceeding.
The response to this Request was prepared by Ed Helms, Delivery Projects
Manager, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 20
REQUEST NO. 12: Reference the quote in Request for Production No. 10.
Please provide the solicitations, all documents used to prepare the solicitations and the
responses to the solicitations. Please describe how the four contractors were selected
to receive the solicitations.
RESPONSE TO REQUEST NO. 12: The Company notes the question
references a "quote in Request for Production No. 10," but the Company believes the
question is in reference to the RFI process discussed in Production Request No. 11.
Please see confidential Attachment 1, provided on the confidential CD, for the
RFI sent to the contractors. Confidentia! Attachment 2, provided on the confidential CD,
is a copy of all clarifying questions received from the contractors, listed by contractor,
and the Company's responses which were provided simultaneously to a!! four
contractors. Confidential Attachments 3, 4, 5, and 6, provided on the confidential CD,
are the responses received from each of the contractors. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding.
The Company selected the contractors based on the contractors' known
experience in constructing the types of facilities that would be required for the Glanbia
request. The Company has worked with three of the four contractors for other similar
type work. ldaho Power recently leamed about the fourth firm included in the RFI from
an informational presentation it held with Company representatives.
The response to this Request was prepared by Ed Helms, Delivery Projects
Manager, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REOUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 21
REQUEST NO. 13: Reference Attachment 5 to ldaho Power's Answer. Please
provide all workpapers and documents used or referred to in the preparation of the
IPCO EPC (Engineer Procure Construct) Summary. Specifically explain why there are
zero dollars bid for some of the project work. Please detail and itemize the components
of and source of the "General Overheads" and the "Tax Gross Up." Please also itemize
and document the components and source of "ldaho Power Support and Oversight of
EPC."
RESPONSE TO REQUEST NO. 13: Please see ldaho Powe/s response to
Production Request No. 12, confidential Attachments 14 for all workpapers and
documents used to prepare the EPC Summary.
Regarding an explanation for why the summary showed "zero dollars bid for
some of the project work," the EPC document provided with the Company's Answer to
the Petition was a Summary of the information provided by the contractor firms.
Confidential Attachment Nos. 3-6 from the Company's response to Production Request
No. 12 are the responses received from the contractors in their entirety. The Summary
was intended to be just that, a summary. Some of the bidders provided lump sum bids,
while others provided more detailed information. Because this process was not a full
Request for Proposal, ldaho Power did not mandate that the contractors provide an
itemized cost proposa!.
The Company assigns overheads to all construction jobs, and 20 percent
represents the rate used for estimates. The Company will collect a tax gross up on the
tota! contribution, which is also represented in the summary.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCT]ON REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 22
Regarding the Company's oversight, ldaho Power will have to provide internal
project management, review the contracto/s design drawings, incorporate all the design
drawings as well as the materials into the appropriate ldaho Power databases, and
provide construction management and inspection of the EPC contractor. A line item
was put in the estimate for these costs. The $350,000 is an estimate based on the
range of the proposals received. The RFI process was not intended to be a formal bid
process and the Company has not treated it as such.
The response to this Request was prepared by Ed Helms, Delivery Projects
Manager, ldaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, ldaho Power Company.
DATED at Boise, tdaho, this 22nd day of May 2013.
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S, FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER - 23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of May 2013 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC.'S,
FIRST PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO
POWER upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Weldon Stutzman
Deputy Attomey General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
X Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand DeliveredX U.S. Mail
_Overnight Mail
FAXX Email pete r@ richard sona nd o learv. co m
o reo @richa rd sona nd o lea rv. co m
IDAHO POWER COMPANY'S RESPONSE TO GLANBIA FOODS, INC,'S, FIRST
PRODUCTION REQUEST AND REQUEST FORADMISSIONS TO IDAHO POWER - 24