20220412IPC to Staff 17-29.pdf

sEm.
,i;i,- *l: LIJ
i.::3.Pt i': Pli 3:52
An lOAoOnP Company
LISA D. NORDSTROM
Lead Counse!
I nordstrom@ida hooower.com
April 12, 2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-21-17
ln the Matter of ldaho Power Company's Application for Authority to
lncrease lts Rates for Electric Service to Recover Costs Associated with the
Jim Bridger Power Plant
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho
Power Company's Response to the Third Production Request of the Commission Staff to
ldaho Power Company.
Due to the voluminous nature of 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. Because certain attachments contain confidential
information, the FTP site is divided between confidentialand non-confidential information.
The login information for the non-confidential portion of the FTP site was provided to all
parties on July 21, 2021, and the login information for the confidential portion was
provided to those parties that executed the Protective Agreement in this matter on July
21,2021.
lf you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
,€; p.7("*t".*,
LDN:sg
Enclosures
Lisa D. Nordstrom
CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Gase No. IPC-E-21-17
ldaho Power Company's Application for Authority to lncrease lts Rates for
Electric Service to Recover Costs Associated with the Jim Bridger Power Plant
The undersigned attorney, in accordance with RP 67, believes that the
Attachments in response to Request Nos. 18 and 25 to ldaho Power Company's
Response to the Third Production Request of the Commission Staff dated April 12,
2022, may contain information that Idaho Power Company or a third pafi claims is
confidential as described in ldaho Code S 74-101, ef seg., and $ 48-801, ef seg., and as
such is exempt from public inspection, examination, or copying.
DATED this 12th day of April2022
X*!.(^*+,,,*,
Lisa D. Nordstrom
Counselfor ldaho Power Company
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ida hopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE IDAHO POWER
COM PANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER PLANT
CASE NO. IPC-E-21-17
IDAHO POWER COMPANY'S
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF
THE COMMISSION STAFF
)
)
)
)
)
)
)
)
COMES NOW, ldaho Power Company ("ldaho Powe/'or "Company"), and in
response to the Third Production Request of the Commission Staff ("Staff') dated March
22,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISS]ON STAFF - 1
REQUEST FOR PRODUCTION NO. 17: Please provide a copy of the
decommissioning and demolition study performed by Kiewit Engineering Group lnc.
("Kiewit") in August 2019 referenced on page 23 in the direct testimony of Matthew
Larkin.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Please see the
Company's Response to the First Production Request of the lndustrial Customers of
ldaho Power No. 36.
The response to this Request is sponsored by John Garstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION 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 1.
Bridger Levelized Revenue Requirement Changes. Please provide this information in
electronic spreadsheet format with formulas intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: Please see
ConfidentialAttachment 1 to the Company's Response to lndustrial Customers of ldaho
Power Request No. 1 for the workpapers that compute the values presented in the June
2021 Request column on page 16 of the Supplemental Direct Testimony of Matthew
Larkin. Please see Confidential Attachment 1 to this response for the workpapers that
compute the values presented in the February 2022 Amended Request column on page
16 of the Supplemental Direct Testimony of Matthew Larkin.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Please see
Attachment 1.
The response to this Request is sponsored by Randy Henderson, PrincipalJoint
Projects Coordinator, ldaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO.20: ln reference to PAC's detailed
accounting noted on page 13 in the supplemental direct testimony of Matthew
Larkin, please explain ldaho Power's ('lPC') 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 natura! gas operation.
Please see the
workpaper titled Existing Plant NBV provided in Response to Request No. 18 for the
quantification of the Bridger plant coal-related net book values, by plant account, using
the allocation factors provided by PacifiGorp. The difference between these results, and
the initial Bridger plant net book values are the assets that are expected to remain in-
service for natural gas operations.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.5
REQUEST FOR PRODUCTION NO.21: Please provide al! 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:
a. Question the need for an upgrade or explore potential alternatives to
minimize costs; and
b. Scrutinized forecasted budget amounts and actual cost overruns.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: The capital budget
and review process, discussed in the direct testimony of Mr. Adelman along with the
Response to Request No. 25, demonstrate a robust engagement by the Company to
ensure only prudent capital investments are made. This engagement is carried out by
aftending review meetings where projects are vetted, through phone discussions with
plant personnel regarding projects, and observing capital work on-site at the plant.
!n addition to the materials provided in the Response to Request No. 25, ldaho
Power has retained various other reports and notes supporting formal and informal
communication between the Company and PacifiCorp regarding capital expenditures.
Due to the voluminous nature of material, it has not been provided in this response.
However, the material is available for review at the Company's headquarters. Please
contact TamiWhite at [phone] or Dave Fewkes at [phone] to schedule a
time to review the requested information.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF .6
REQUEST FOR PRODUCTION NO.22: Please provide guidelines and
procedures used by the Company and PAC to identify, plan, set budgets, and
manage capital investment projects for the Jim Bridger Power Plant.
R Section 5 of the
Amended and Restated Agreement for the Operation of the Jim Bridger Project
between ldaho Power Company and PacifiCorp ("Operation Agreement"), provided in
Response to lndustrial Customers of ldaho Power Request No. 44, identifies the
responsibilities of the partners for the operation expenses and replacements. lt
establishes when budgets will be submitted and when approvals are required for repairs
and replacements. lt also addresses that budget revisions with a total variance of 10
percent or more need approval by ldaho Power. ln addition, Section 14 of the
Operation Agreement addresses capita! additions, improvements or betterments, or
those other than the replacements required for operations.
ln addition, ldaho Power requested further controls to the capital budget,
requiring that anytime an individual capital project with a value greater than $1 million
(current budget year, 100 percent partnership share) is expected to exceed the current
year original budget by 20 percent, it will be reviewed and agreed upon by the
Company. Also, any new unbudgeted individual capital projects larger than $1 million
(100 percent partnership share) wil! be reviewed and agreed upon, and if the total
capital forecast is greater than the capital budget by more than $100,000, it will be
reviewed by both partners. This allows the plant management the flexibility to move or
shift smaller projects throughout the year while also allowing ldaho Power greater
oversight over the larger capital projects.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
The rcsponse to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAFIO POVVER COiTPAT'ffS RESPONSE TO THE THIRD PRODUGTION REQUEST OF THE
COMMISSION STAFF. S
REQUEST FOR PRODUCTION 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: Most equipment on
each Bridger unit is interchangeable except for some of the major equipment including:
(1) the high pressure/intermediate pressure turbines on Units 1 and 2, (2) the Unit 2 low
pressure turbines, (3) the Unit 4 induced draft fans/motors, and (4) the Unit 4 scrubber
equipment.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: PacifiCorp and ldaho
Power have not developed contractual terms that would be necessary to a!!ow for the
potential earlier exit of a Bridger unit by one co-owner, and not both co-owners. As
explained in the Gompany's Response to lndustrial Customers of ldaho Power's
Request Nos. 20 and 43, ldaho Power and PacifiCorp have had high level discussions
on the approach for one party to exit a unit before the other, but the parties decided to
enter formal negotiations for unit exit terms after the 2021 lntegrated Resource Plans
are filed with the Commission. As part of initial discussions, a list of terms or issues was
shared between the parties of items to be addressed during negotiations for differing
unit exit dates. The parties have not yet commenced forma! negotiations for
establishing an agreement that would address the closure of the Bridger plant.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1O
REQUEST FOR PRODUCTION NO. 25: Please provide documentation and
both formal and informal communication between the Company and PAC
regarding investments made from January 1,2012, through December 31,2020,
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, Dl 10); and
c. Demonstrating how IPC was actively involved in the quarterly Ownership
Meetings (ADELMAN, Dl 10111).
RESPONSE TO REQUEST FOR PRODUGTION NO. 25:
a. As explained in the direct testimony of Mr. Adelman, as the plant operator,
PacifiCorp analyzes and proposes the need for capital projects necessary to
ensure continued, reliable and safe operations of the plant. Annually, a
forecast of capital projects is presented to the Company, including a detailed
3-year forecast with a high level 1O-year forecast, during the mid-year budget
review meetings. During these mid-year meetings, PacifiCorp and ldaho
Power vet the proposed projects contained in the capita! plan. To facilitate
the review, the plant provides justification explanations for each proposed
project, detailing the scope of the project, the need, and business
consequences if the project is not done. For example, Confidential
Aftachment 1 and Attachments 2 and 3 include the materials and notes
presented at the 2020 mid-year meeting. Due to the voluminous nature of the
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
materialand notes presented in each mid-year meeting, notes from all
meetings have not been provided in this response. However, the material is
available for review at the Company's headquarters. Please contact Tami
White at [phone] or Dave Fewkes at [phone] to schedule a
time to review the requested information.
During each quarterly Ownership Meeting, the entire current year capital
budget spend to-date is reviewed and discussed, along with any proposed
adjustments to the remaining project work. During the September quarterly
Ownership Meetings, the final proposed capital budget is provided. Plant
personnel and subject matter experts on the various capital projects are
available during both the mid-year and September presentations to answer
any questions that may arise. The Joint Projects Leader remains in contact
with the plant Engineering/Environmental Manager via phone calls and
multiple yearly on-site plant visits, where the open dialog of the capita!
projects occurs. The Joint Projects Leader or other ldaho Power
representatives also visits the plant during overhauls to tour the plant with the
Engineering/Environmental Manager or other personnelto review and
observe the capital projects in progress.
b. See (a) above. ConfidentialAttachment 1 and Attachments 2 and 3 include
the materials and notes presented at the 2020 mid-year meeting, and the
materials and notes available for on-site review, demonstrate ldaho Power's
involvement in the capital budget review process.
c. ldaho Power's Joint Projects Leader has attended every quarterly Ownership
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
Meeting since 1994, along with other Company reprcsentatives. As detailed
in the response to (a), and evidened in the materials and notes available for
review on-site, during these Oamership Meetings the current capital budget
and forecast is reviewed. Proiect variances and other issues regarding the
capital budget are discussed.
The response to this Request is sponsorcd by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POVYER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
coMMtsstoN STAFF- 13
REQUEST FOR PRODUCTION NO.26: ln Adelman, Dl, page 20 it states,
'With input from ldaho Power, PacifiCorp developed an RFP package that
included a detailed scope of work, performance based technical specifications,
concept drawings, expected performance guarantees and commercia!
requirements." Please provide documentation showing the Company's input
provided to PAC for the development of the RFP package.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Pursuant to the
Operation Agreement, PacifiCorp is required to operate and maintain the Bridger plant
at the lowest reasonable cost and in a prudent and skillful manner in accordance with
the standards prevailing in the utility industry and with applicable laws. Among other
things, ldaho Power monitors PacifiCorp's actions through periodic owner
meetings. During such meetings, PacifiCorp updates the Company as to the operation
at the plant, expected future work, budgetary items, and other events and issues. !n the
case of the Selective Catalytic Reduction ("SCR") controls work, PacifiCorp routinely
provided ldaho Power with updates as to the RFP process, anticipated costs, expected
timelines, and other relevant topics.
As the SCR work became more likely, and prior to the execution of the
Engineering, Procurement, and Construction contract, ldaho Power increased its
diligence and review of the SCR work with PacifiCorp. The Company took part in
multiple additional discussions with PacifiCorp, which ultimately led to a half-day
gathering in Salt Lake City focused on the topics of SCR costs, compliance options, the
RFP process, scheduling concerns, and other relevant issues. Because all exchanges
between the parties were in the form of verbal communication, no written
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
documentation exists.
The response to this Request is sponsorcd by John Garctensen, Joint Projecls
Leader, ldaho Power Company.
IDAHO POVT'ER COMPANYS RESPONSE TO THE THTRD PRODUCTION REQUEST OF THE
coMMtsstoN srAFF- 15
REQUEST FOR PRODUCTION 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). lf so, please quantify the number of people and
hours which Company personnelwere on-site. !f not, please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: From late 2013
through 2015, two ldaho Power employees attended a total 57 meetings and
accumulated over 300 hours on-site, dedicated solely to the management and oversight
of the SCR proiects on Units 3 and 4, excluding trave! time to and from the plant. The
following is a list of the meetings attended including location of each meeting:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
Date
Lrl2612oL3
L2/412Ot4
L2/L8/2OL4
tl812014
LlL5/2Ot4
Ll29/2074
2lsl2Ot4
2/t2120L4
2/L9/20L4
2126120t4
3lsl2oL4
3lt3l2OL4
3/19120t4
3/26/2OL4
41212OL4
4/9l2OL4
4/2412OL4
sl8/2OL4
s/2!20L4
sl28/20t4
6lsl2OL4
6/tLl20L4
6l18/2OL4
512sl20L4
7l212ot4
7/t0l2oL4
7/L6/2OL4
7/23/2OL4
7l3O/20L4
8/6/2ot4
8/t4/20t4
8/2O120t4
9lt7/2Ot4
9124/2OL4
9l2s/20t4
LOlLl2Ot4
LO/L6/2OL4
LO/29/2OL4
Lth2l274
rLlL9l20L4
t2/t!20L4
t2/L7120t4
LlLl2oLs
!L4l2OLs
214lzlLs
2/t!2OLs
2/t&l2OLs
314/2OLs
3h2l20Ls
41lsl2oL5
s/20/20Ls
6lL8l20Ls
7lL6l2OLs
8lL3/z0ts
9lL7l2OLs
LO/L4l2OLs
7t/Lzl2OLs
L2ltO/20L5
locatlon
CHq-Boise
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
CHQ-Boise
Jim Brid8er Plant
CHQ-Boise
CHQ-Boise
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
CHQ-Boise
CHQ-Boise
CHQ-Boise
Jim Bridger Plant
St Catharines, Ontario
CHQ-Boise
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
Canceled
CHQ-Boise
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
CHQ-Boise
CHQ-Boise
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
CHQ-Boise
CHQ-Boise
Jim Brid8er Plant
CHQ-Boise
.lim Brid8er Plant
CHQ-Boise
Jim BridSer Plant
CHQ-Boise
CHQ-Boise
Jim Bridger Plant
CHQ-Boise
CHq-Boise
cHQ-Boise
CHQ-Boise
Jim Bridger Plant
Jim Bridger Plant
CHQ-Boise
Jim Bridger Plant
Jim Bridger Plant
Jim BridSer Plant
Jim Bridger Plant
CHQ-Boise
CHQ-Boise
CHQ-Boise
Meeting
Call/discussion with R Goff and M Saunders
JB 3&4 SCR BWP Weekly Meeting
Attended Monthly Meeting with B&W and Perry Group
JB 3&4 SCR BWP Weekly Meeting
Attended Monthly Meeting with B&W and Perry Group
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly MeetinS
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
.,8 3&4SCR BWP Monthly Meeting
NElS Flow Model Validation
JB 3&4 SCR BWP Weekly Meetin8
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BwP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
CWIP Call/discussion with R Goff and M Saunders
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Weekly Meeting
JB 3&4 SCR BWP Monthly Meeting
JB 3&4 SCR BWP Monthly Meeting
Phone call with Richard
SCR Monthly Meeting
SCR Monthly Meeting
SCR Monthly MeetinB
SCR Monthly Meeting
SCR Monthly Meeting
SCR Monthly Meeting
SCR Monthly Meeting
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.17
The response to this Request is sponsored by John Caretensen, Joint Proiec.ts
Leader, ldaho Power Company.
IDAHO POWER COMPA}.IY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 18
REQUEST FOR PRODUCTION NO.28: PIease provide a detailed
description of the process the Company used to validate and approve costs
incurred by its managing partner, PAC.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28: The following details
the process by which the Company validates and approves costs incurred by PacifiCorp
for Bridger:
- On the third business day of each month, the plant emails preliminary cost data
for ldaho Power's accrualentry. ldaho Power:
o Checks O&M invoice totals for correct ownership share,
o Verifies capital projects for correct ownership share,
o Compares billing totals to budget and/or budget update, and
o Reaches out to the Joint Projects Leader or the plant with questions as
needed.
- Monthly, PacifiCorp emails the invoice and uploads the prior month finalized cost
data file to ldaho Power's secure FTP site.
- The Company verifies the O&M and Capital invoice pivot in the Excel Bridger
Detailfile:
o Comparing account totals to prior month accrual, reaching out to
PacifiCorp and/or the plant with questions on notable differences.
o Creates O&M and capital pivot tables from the detail data and compares
to invoice pivots provided by PaclfiCorp, ensuring totalcosts balance to
data and correct ownership share of one-third is billed.
o Verifies that Material and Supply charges agree to Materialand Supply
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
inventory report received from PacifiCorp.
o Using the capital pivot table, ldaho Power's work orders are verified for
accurate ownership share. For new capital projects, the Appropriation
Project Request ('APRs") received from Bridger are gathered. Using
information from the APR, creates work order in Asset Suite and foruards
to Joint Projects Leader for review and approval.
o Verifies amounts on O&M and Capita! invoice pivots agree with the
invoice.
Verifies fuel handling expense on O&M invoice:
o Compares account totals to prior month accrual, reaching out to
PacifiCorp and/or the plant with questions if necessary.
o Verifies that railcar charges billed agree with railcar report received from
PacifiCorp.
o Verifies that FuelOil lnventory and Fuel Consumed charges agree to
lnventory report received from PacifiCorp.
Creates and send payment request, with invoice, to Joint Projects Leader,
requesting the following:
o To review the invoice and EFT and forward the emailwith approvalto the
Company's Accounts Payable department:
. The Joint Projects Leader receives the email, conducts the review
of the invoice(s), then forwards the email to
[e-mail]. The email will contain a statement
of verification that the work was done, and the charge is accurate,
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
and that the Joint Projects Leader has reviewed and approves the
invoice.
- lf the invoices are more than $500,000, the 500 kV and Joint Projects Senior
Manager, is required to approve the invoice, consistent with the steps above.
- Account reconciliations are performed monthly on the accounts that the invoice is
recorded to. lf any errors are made through the recording of the invoice, it is
identified during the reconciliation process.
- Actual to budget results are reviewed monthly with the Joint Projects team and
quarterly with the plant operations and finance personnel.
The response to this Request is sponsored by Anne Wadsworth, Joint Venture
Analyst, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
REQUEST FOR PRODUCTION 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 and/or subcontractors were
verified as correct and prudently incurred; and
d. The costs for equipment procured by PAC were verified as correct and
prudently incurred.
RESPONSE TO REQUEST FOR PRODUCTION NO. 29: As detailed in the
Company's Response to Request No. 28, invoices are received monthly from
PacifiCorp detailing charges to each capital project, by cost category including labor,
material, outside services, and miscellaneous. Part of the invoice review and
approval process includes the validation of costs incurred by the managing partner,
ensuring the charge category and total project costs are in Iine with the latest forecast
for that project, and that ldaho Powe/s share of the project payments due have been
calculated at the correct ownership percentage. Because ldaho Power is not the
partner paying the contractors, suppliers, employees, etc. who work and provide
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22
services on the projects, it is not feasible to perform a separate review/approval of
the payments for these items. ldaho Power relies upon budget review activities and
controls to monitor capita! spend, ensuring it is prudently incurred, valid and
reasonable. Operationalaudits are performed by ldaho Power's internalaudit
department annually to provide further assurance that Bridger capital charges are
valid and accurate, and billed to ldaho Power appropriately.
ln addition, each month, the plant provides a Monthly Financial Report that
includes, among other financial reporting items, a worksheet with all current year capital
projects and a comparison between monthly actuals and forecasted spend, a worksheet
for forecasted year-end variances for each capital project, and a monthly variance
worksheet for the projects. ldaho Power monitors and reviews the capital project
expenditures and variances through these processes along with communications with
the plant and plant site visits as needed. Due to the voluminous nature of this
documentation, it has not been provided in response to this request. lf Staff would like
to review a subset of this information, please contact Regulatory Consultant Courtney
Waites at [phone].
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23
Respectftrlly submitted this 12th day of Apil2A22,
fr;fr.ff^l-t^-*,
USA D. NORDSTROM
Attomeys for ldaho Power Company
IDAHO POV1IER COMPAIIY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF -24
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of April2022, I served a true and
correct copy ldaho Power Company's Response to the Third Production Request of the
Commission Staff upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Chris Burdin
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customer of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 N.6th Street
Boise, ldaho 83701
City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
Hand Delivered_U.S. Mail
Overnight Mai!_FAXX FTP SiteX Email: [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX FTP SiteX EMAIL dreadinq@mindsprinq.
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX FTP SiteX EMAIL [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX FTP SiteX EMAIL [e-mail]
bo iseC itvAtto rnev@citvofboise. o ro
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
Clean Energy Opportunities for ldaho, lnc.
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.,
Boise, ldaho 83703
Michael Heckler
Courtney White
Clean Energy Opportunities for ldaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
Sierra Club
Rose Monahan
Ana Boyd
2101 WebsterStreet, Suite 1300
Oakland, CA94612
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Jim Swier
Micron Technology, lnc.
8000 S. FederalWay
Boise, lD 83707
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX FTP SiteX EMAIL [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX FTP SiteX EMAIL
mike@clea nenerovopportu nities. com
cou rtnev@cleanenerovopportu nities. com
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX EMAIL [e-mail]
ana. [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX FTP SiteX EMAIL [e-mail]
[e-mail]
[e-mail]
aclee@holla nd hart.com
q loa roanoamari@holla nd hart. com
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP Site
X EMAIL [e-mail]
&^#=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 26