20180622IPC to Staff Supplemental 2.pdf

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An loAcoRP company
June 22,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-18-08
ldaho Department of Administration's Petition for Exemption from the ldaho
Public Utilities Commission Master-Metering Standards - ldaho Power
Company's SUPPLEMENTAL Response to Staff's First Production Request
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's SUPPLEMENTAL Response to the First Production Request of the
Commission Staff ("Staffl') to ldaho Power Company.
Also enclosed are four (4) copies of confidential disks containing information
responsive to Staff's production requests. Please handle the confidential information in
accordance with the Protective Agreement executed in this matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
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Lisa D. Nordstrom
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221\Nest ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom @ ida h opowe r. com
F.ECEIVED
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
THE IDAHO DEPARTMENT OF
ADMINISTRATION FOR AN EXEMPTION
FROM THE IDAHO PUBLIC UTILITIES
COMM!SSION'S MASTER-METERI NG
RULES FOR ELECTRIC UTILITIES AND
THE IDAHO POWER MASTER
METERING STANDARDS
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CASE NO. tPC-E-18-08
IDAHO POWER COMPANY'S
SUPPLEMENTAL RESPONSE TO
THE F!RST PRODUCTION
REQUEST OF THE COMMISSION
STAFF
COMES NOW, ldaho Power Company ("ldaho Power"), and in response to the
First Production Request of the Commission Staff to ldaho Power Company dated May
18, 2018, herewith supplements the following information:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 2: Please explain what work IDOA has asked ldaho Power to do
to modify the Campus to meet ldaho Power's requirements to maintain the power
distribution system to each building or identified electrical meters on the Campus. To
the extent available, your explanation should include details like:
a. Scope of Supply;
i. A description of the work;
ii. Schematic drawings representing the requested/necessary
modifications;
iii. Physical plan and elevation drawings identifying the requested
modifications;
b. A detailed material estimate with itemized component pricing;
c. A detailed labor estimate by worker classification, hours, and rate;
d. A detailed support equipment estimate by type, hours, and rate;
e. Detailed accounting of indirect costs;
f. Summary table of the subtotaled itemized costs; and
g. Anticipated duration and schedule.
SUPPLEMENTAL RESPONSE TO REQUEST NO. 2: This response
supplements ldaho Power's original response dated June 1,2018.
ldaho Power performed two construction studies to determine what would be
necessary for ldaho Power to own, operate, and maintain electrical facilities beyond the
point of delivery ("POD") at the ldaho Department of Administration's ("lDOA") Chinden
Campus.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
Version 1 locates the POD at the Hewlett Packard Substation, and provides the
necessary configuration if the ldaho Public Utilities Commission ("Commission") grants
IDOA's request for an exemption to the Commission's master metering rules. Version 2
locates the POD at each building and/or each chiller at the Chinden Campus under a
traditional metering arrangement where no master metering occurs.
As further explained in the studies, while Idaho Power has made considerable
efforts to estimate the costs and schedule associated with the necessary upgrades in
each study, the cost estimates are conceptual in nature and do not represent a refined
engineering design.
a,g) Please see the construction studies provided on the Confidential CD for
responses to items a, and g above.
b-0 Please see the summaries provided on the confidential CD for the
responses to items b-f above.
The confidential CD will only be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
DATED at Boise, ldaho, this 22nd day of June 2018.
X"P il-,,t t "r.-6/
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of June 2018 I served a true and
correct copy of IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:
ldaho Department of Administration
Julie K. Weaver
Deputy Attorney General
Contracts and Administrative Law Division
954 W. Jefferson, 2nd Floor
Boise, ldaho 83720-001 0
Commission Staff
Karl Klein
Deputy Attorney General
!daho Public Utilities Commission
47 2 W est Wash i ngton (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
X Hand Delivered
_ U.S. Mail
_ Overnight Mail
_ FAXX Email [e-mail]
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KTf,er[ Towdl, Executive Assistant
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 4