20220322Staff 17-29 to IPC.pdf

ldaho Public Utilities Commission
Office of the SecretaryRECEIVED
MAR 2 2 2022
TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11542
Boise, ldaho
Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837T4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLANT
CASE NO.IPC-E-2I-I7
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Taylor Brooks, Deputy Attomey General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, APRIL 12, 2022.
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
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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I MARCH 22,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 17: Please provide a copy of the decommissioning and demolition
study performed by Kiewit Engineering Group Inc. ("Kiewit") in August 2019 referenced on
page23 in the direct testimony of Matthew Larkin.
REQUEST NO. 18: Please provide Company workpapers detailing the methodology
and any intermediate steps used for calculating the values presented in the supplemental direct
testimony of Matthew Larkin on page 16, Table I . Bridger Levelized Revenue Requirement
Changes. Please provide this information in electronic spreadsheet format with formulas intact.
REQUEST NO. 19: Please provide the PacifiCorp ("PAC") detailed accounting records
noted on page 13 in the supplemental direct testimony of Matthew Larkin. Please provide this
information in electronic spreadsheet format with formulas intact.
REQUEST NO. 20: In reference to PAC's detailed accounting noted on page 13 in the
supplemental direct testimony of Matthew Larkin, please explain Idaho Power's ("IPC")
methodology for making the adjustments to the breakout as discussed. Please provide the
itemized adjustment amount for each account broken down by common plant and each
generating unit for the portion of investment:
a. That will be retired when coal unit operations cease; and
b. That will remain in service with continued natural gas operation.
REQUEST NO.2l: Please provide all documentation including both formal and
informal communication between the Company and PAC regarding investments made from
January 1,2012, through December 31,2020, demonstrating how the Company actively engaged
its operating partner to minimize Jim Bridger Power Plant investments. Please include emails,
meeting notes, and/or records of discussion that:
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MARCH 22,2022
a. Question the need for an upgrade or explore potential alternatives to minimize costs;
and
b. Scrutinized forecasted budget amounts and actual cost ovemrns.
REQUEST NO.22: Please provide guidelines and procedures used by the Company
and PAC to identiff, plan, set budgets, and manage capital investment projects for the Jim
Bridger Power Plant.
REQUEST NO.23: What equipment, parts, or other infrastructure can the Company or
PAC salvage from decommissioned Jim Bridger generating units to use in other units that remain
in service?
REQUEST NO.24: Please explain the Company and PAC's approach for establishing
an agreement similar to the Valmy Framework Agreement developed with NV Energy, to
address the full Jim Bridger Power Plant closure?
REQUEST NO.25: Please provide documentation and both formal and informal
communication between the Company and PAC regarding investments made from January l,
2012, through December 3 l, 2020, that:
a. Determined how those capital investment decisions were made at the Jim Bridger
Power Plant;
b. Demonstrating how IPC was actively involved in the Mid-year Co-Owner capital
budget review meetings (ADELMAN, DI l0); and
c. Demonstrating how IPC was actively involved in the quarterly Ownership Meetings
(ADELMAN, DI l0/11).
REQUEST NO.26: In Adelman, DI, page 20 it states, "With input from Idaho Power,
PacifiCorp developed an RFP package that included a detailed scope of work, performance based
technical specifications, concept drawings, expected performance guarantees and commercial
requirements." Please provide documentation showing the Company's input provided to PAC
for the development of the RFP package.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY J MARCH 22,2022
REQUEST NO. 27: Please explain whether the Company provided any continuous or
periodic on-site management at the plant during the construction of the $62.92 million Unit #3
SCR and the $66.91 million Unit #4 SCR ($ are IPC's share). If so, please quantify the number
of people and hours which Company personnel were on-site. If not, please explain.
REQUEST NO. 28: Please provide a detailed description of the process the Company
used to validate and approve costs incurred by its managing partner, PAC.
REQUEST NO. 29: For each capital project contained in EXHIBIT NO. 3 with an IPC
share amount of $1.5 million or greater, implemented from January 1,2012, through December
31,2020, please provide the Company's due diligence analysis demonstrating that the project
was managed to achieve least cost. Specific to each project, please include analysis showing
that:
a. The overhead costs for PAC to provide project management and oversight were
verified as correct and prudently incurred;
b. The costs for completing projects using PAC direct labor and materials were verified
as correct and prudently incurred;
c. The costs from PAC's project contractor andlor subcontractors were verified as
correct and prudently incurred; and
d. The costs for equipment procured by PAC were verified as correct and prudently
incurred.
,)DATED at Boise,Idaho, thisJ2 day of March2022.
i:umisc:prodreq/nsww2l. I Tdhrk prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4
General
MARCH 22,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF MARCH 2022, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IpC-E-2t-17, By E-MAILING A COpy
THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: lnordstronr@i dahooower.com
dockets@idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL : botto@.idahoconservation.org
ROSE MONAHAN
ANA BOYD
SIERRA CLUB
2IOI WBSTER ST STE I3OO
OAKLAND CA946I2
E-MAIL: [e-mail]
[e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL: [e-mail]
MATT LARKTN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : mlarki [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEYS OFF
PO BOX 500
BOISE ID 83701-0500
E- MAI L : B o i s e C i tv A tt o rne.v-- @ c i tvo tb o i s e. o r g
ejewelI @citvofboise.org
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTI.]NITIES FOR
IDAHO
3778 PLANTATION DR, SUITE I02
BOISE ID 83703
E-MAIL:
[e-mail]
courtney @c I eanenergvopportunities. com
JIM SWIER
MICRON TECHNOLOGY INC
8OO SOUTH FEDERAL WAY
BOISE ID 83707
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD ANELSON
AUSTIN W JENSEN
HOLLAND & HART LLP
555 tTrH ST STE 3200
DENVER CO 80202
E-MAIL : [e-mail]
tnelson@hollandhart. com
awj ensen@ hollandhart. com
aclee@hollandhart. com
[e-mail]
,)n,4A*,SECRET^MF/
CERTIFICATE OF SERVICE