20230731Staff 155-196 to IPC - Redacted.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )CASE NO.IPC-E-23-11
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC SERVICE )REDACTED SEVENTH
IN THE STATE OF IDAHO AND FOR )PRODUCTION REQUESTOF
ASSOCIATED REGULATORY )THE COMMISSION STAFF
ACCOUNTING TREATMENT )TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,Deputy Attorney General,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than MONDAY AUGUST 21,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 identify the name,job title,location,and
telephone number of the record holder.
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 1 JULY 31,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.155:Please provide the referenced presentationby Idaho Power's
supplier in June of 2022 highlightingthe "Utility Market Commodity Impacts and Outlook"
Grow Direct at 27.
REQUESTNO.156:Please provide all Wood Mackenzie pricing data used by Idaho
Power from the period starting in 2012 up to the current date.Hackett Direct at 22.
REQUESTNO.157:Please provide an Excel file showing all capital investment
projects completed since the Company's last General Rate Case (Case No.IPC-E-11-08)up to
the Company's 2023 test year,which the Company seeks recovery of.For each project,please
provide the following:
a.Name or Title;
b.Project identifier(s)(include all project identifiers internal to the Company,and
those specific to the project which may be external to the Company);
c.Plant-In-Service date;
d.Classification (i.e.Generation,Transmission,Distribution,Environmental,
Enterprise,Partnered Plant,Other,...);
e.Rationale supporting the need for each capital investment;
f.Whether a cost benefit analysis was completed (Yes/No);
g.Project dates:(i.e.target start date,actual start date,target completion date,and
actual completion date);
h.Project costs:(i.e.estimated cost,budgeted cost,and actual cost).(Note:Where
adjustments were made to forecasted costs indicate the date and amount of the
adjustment;
i.Cost analysis considering whether the work should be completed by a contractor
or primarily using Company employees (Yes/No);and
j.If a contractor was used,was a request-for-proposal issued for the project
(Yes/No).
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 31,2023
REQUESTNO.158:Please provide an Excel file showing all capital investment
projects completed within the Company's 2023 test year,which the Company seeks recovery of.
For each project,please provide the following:
a.Name or Title;
b.Project identifier(s)(include all project identifiers internal to the Company,and
those specific to the project which may be external to the Company);
c.Plant-In-Service date;
d.Classification (i.e.Generation,Transmission,Distribution,Environmental,
Enterprise,Partnered Plant,Other,...);
e.Rationale supporting the need for each capital investment;
f.Whether a cost benefit analysis was completed (Yes/No);
g.Project dates:(i.e.target start date,actual start date,target completion date,and
actual completion date);
h.Project costs:(i.e.estimated cost,budgeted cost,and actual cost).(Note:Where
adjustments were made to forecasted costs indicate the date and amount of the
adjustment;
i.Cost analysis considering whether the work should be completed by a contractor
or primarily using Company employees (Yes/No);and
j.If a contractor was used,was a request-for-proposal issued for the project
(Yes/No).
REQUESTNO.159:In reference to Tatum Direct Testimony page 13,please explain
why the Company should "Maintain the North Valmy Power Plant and the Jim Bridger Power
Plant non-fuel coal-related cost recovery at current levels.Please quantifythe difference
between the proposed current levels to actuals and/or forecasts.
REQUESTNO.160:In reference to Tatum Direct Testimony page 13,please provide
the difference in the amount of recovery requested by the Company to the previously deferred
revenue requirements for the North Valmy Power Plant and for the Jim Bridger Power Plant.
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 3 JULY 31,2023
REQUESTNO.161:Specific to the Jim Bridger Power Plant,please describe the
methods directly used by Idaho Power to ensure capital investment projects were completed in a
least cost manner.Please include any Idaho Power specific guidelines and/or procedures
documenting these methods relative to the Jim Bridger Power Plant.(Note:If the guidelines
and/or procedures changed over time,please indicate what changed,why it changed,and the date
it was implemented.)
REQUESTNO.162:Specific to Jim Bridger Power Plant,please describe the methods
used by the Operating Partner to ensure capital investment projects were completed in a least-
cost manner.Please include any Operating Partner specific guidelines and procedures
documenting these methods.(Note:If the guidelines and/or procedures changed over time,
please indicate what changed,why it changed,and the date it was implemented.)
REQUESTNO.163:In reference to the "Oversight Meeting Checklist"specific to Jim
Bridger Power Plant referenced in Barretto Direct Testimony at 36,please answer the following:
a.Please explain the purpose and/or benefit of the checklist?
b.When did the Company implement the checklist?
c.What procedures were in place prior to implementing the checklist?
d.Why didn't the Company implement the checklist earlier?
e.Provide all "Oversight Meeting Checklists"completed to date.
REQUESTNO.164:Please provide all Jim Bridger Power Plant capital project
"Appropriation Requests"signed by Idaho Power for which the Company is seeking recovery in
this case.
REQUESTNO.165:Please provide the followingdocumentation for Jim Bridger
Power Plant Power Capital Investment Projects referenced in Barretto's Direct Testimony.The
response should include all individual projects (2$250,000 based on Plant Level Cost)within this
filing where Idaho Power seeks recovery.If any of the information requested below cannot be
provided or is not available,please explain why.Additionally,for any information that cannot
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 4 JULY 31,2023
be provided please explain how the Company can ensure the construction of the project was
completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.Requests for proposals ("RFP")
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winning bid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 5 JULY 31,2023
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers
h.Indicate whether the Company has completed a checklist referenced in Barretto
Direct Testimony.
REQUESTNO.166:Specific to North Valmy Power Plant,please describe the
methods used by Idaho Power to ensure capital investment projects were completed in a least
cost manner.Please include any Idaho Power specific guidelines and/or procedures
documenting these methods relative to the North Valmy Power Plant.(Note:If the guidelines
and/or procedures changed over time,please indicate what changed,why it changed,and the date
when it was implemented.)
REQUESTNO.167:Specific to North Valmy Power Plant,please describe the
methods used by the Operating Partner to ensure capital investment projects were completed in a
least-cost manner.Please include any Operating Partner specific guidelines and procedures
documenting these methods.(Note:If the guidelines and/or procedures changed over time,
please indicate what changed,why it changed,and the date when it was implemented.)
REQUESTNO.168:In reference to the "Oversight Meeting Checklist"specific to the
North Valmy Power Plant.Please answer the following:
a.Please explain the purpose and/or benefit of the checklist?
b.When did the Company implement the checklist?
c.What procedures were in place prior to implementing the checklist?
d.Why didn't the Company implement the checklist earlier?
e.Provide all "Oversight Meeting Checklists"completed to date.
REQUESTNO.169:Please provide all North Valmy Power Plant capital project
"Authorization for Expenditure"request's signed by Idaho Power for which the Company is
seeking recovery in this case.
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 6 JULY 31,2023
REQUESTNO.170:Please provide the followingdocumentation for the North Valmy
Power Plant Capital Investment Projects referenced in Barretto's Direct Testimony.The
response should include all individual projects (>$250,000 based on Plant Level Cost)within this
filing where Idaho Power is seeking recovery.If any of the information requested below cannot
be provided or is not available,please explain why.Additionally,for any information that
cannot be provided please explain how the Company can ensure the construction of the project
was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winning bid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthlyproject status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 7 JULY 31,2023
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers
h.Indicate whether the Company has completed a checklist referenced in Barretto
Direct Testimony.
REQUESTNO.171:Please provide documentation of all communication between the
Company and Powin Energy Corporation ("Powin")as part of the June 30,2021,RFP.
REQUESTNO.172:Please provide documentation of all communication between the
Company and Powin Energy Corporation followingthe June 30,2021,RFP related to the
Company's direct negotiations with Powin for the Black Mesa 40-MW four-hour duration
battery energy storage system ("BESS")referenced in Hackett Direct Testimony.
REQUESTNO.173:Please provide documentation of all communication between the
Company and Powin Energy Corporation related to the Company's direct negotiations with
Powin for the Hemingway 80-MW four-hour duration BESS referenced in Hackett Direct
Testimony.
REQUESTNO.174:Please provide the followingdocumentation for the Hemingway
80-MW four-hourduration BESS referenced in Hackett's Direct Testimony.If any of the
informationrequested below cannot be provided or is not available,please explain why.
Additionally,for any information that cannot be provided please explain how the Company can
ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 8 JULY 31,2023
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.175:Please provide the followingdocumentation for the Black Mesa
40-MW four-hour duration BESS referenced in Hackett's Direct Testimony.If any of the
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 9 JULY 31,2023
information requested below cannot be provided or is not available,please explain why.
Additionally,for any information that cannot be provided please explain how the Company can
ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard and
iv.RFP from winning bid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
Budget-to-actual comparisons for overall project and by year;
ii.Baseline schedule-to-actual schedule comparison;and
iii.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 10 JULY 31,2023
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.176:Please provide the results and all supporting documentationfor
the analysis used within the Company's "parallel investigation into different configurations of
Company-owned and constructed BESS,and the indicative pricing"referenced in Hackett's
Direct Testimony at 17.
REQUESTNO.177:Please provide all analysis and documentation used to support the
$28 million investment for performance degradation over time for maintaining 120 MW of
BESS capacity referenced in Hackett's Direct Testimony at 24.
REQUESTNO.178:Please explain and quantifythe revenue impact of delaying
recovery of the revenue requirement associated with the 120 MW of battery storage resources to
be online in 2023 with interim earnings support from the associated investment tax credits
generated from the battery storage resources.Tatum Direct at 13.
REQUESTNO.179:Please provide the followingdocumentation for the upgrades and
improvements at the Lower Salmon Falls hydro generation facility ("LSF")referenced in
Hackett's Direct Testimony.If any of the information requested below cannot be provided or is
not available,please explain why.Additionally,for any information that cannot be provided
please explain how the Company can ensure the construction of the project was completed at
least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule;
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 11 JULY 31,2023
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winning bid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.180:Please provide the followingdocumentation for the upgrades and
improvements included in the Brownlee Unit 1 refurbishment referenced in Hackett's Direct
Testimony.If any of the information requested below cannot be provided or is not available,
please explain why.Additionally,for any information that cannot be provided please explain
how the Company can ensure the construction of the project was completed at least cost.
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 12 JULY 31,2023
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 13 JULY 31,2023
REQUESTNO.181:Please provide the followingdocumentation for the upgrades and
improvements included in the Brownlee Unit 2 refurbishment referenced in Hackett's Direct
Testimony.If any of the information requested below cannot be provided or is not available,
please explain why.Additionally,for any information that cannot be provided please explain
how the Company can ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthlyproject status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 14 JULY 31,2023
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.182:Please provide the followingdocumentation for the upgrades and
improvements included in the Brownlee Unit 3 refurbishment referenced in Hackett's Direct
Testimony.If any of the information requested below cannot be provided or is not available,
please explain why.Additionally,for any information that cannot be provided please explain
how the Company can ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthlyproject status report(s);
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 15 JULY 31,2023
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.183:Please provide the followingdocumentation for the upgrades and
improvements included in the Brownlee Unit 4 refurbishment referenced in Hackett's Direct
Testimony.If any of the information requested below cannot be provided or is not available,
please explain why.Additionally,for any information that cannot be provided please explain
how the Company can ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 16 JULY 31,2023
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.184:Please provide the followingdocumentation for the upgrades and
improvements in the Shoshone Falls Units 1 &2 replacement referenced in Hackett's Direct
Testimony.If any of the information requested below cannot be provided or is not available,
please explain why.Additionally,for any information that cannot be provided please explain
how the Company can ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justificationof need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule;
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 17 JULY 31,2023
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winning bid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.185:Please provide the followingdocumentation for the rebuild of the
59-mile transmission line between the King Substation and the Wood River Substation
referenced in Colburn's Direct Testimony.If any of the information requested below cannot be
provided or is not available,please explain why.Additionally,for any information that cannot
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 18 JULY 31,2023
be provided please explain how the Company can ensure the construction of the project was
completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthly project status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 19 JULY 31,2023
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.186:Please provide the followingdocumentation for the upgrade of the
6.8-mile transmission line between the Cloverdale Substation and the Hubbard Substation
referenced in Colburn's Direct Testimony.If any of the information requested below cannot be
provided or is not available,please explain why.Additionally,for any information that cannot
be provided please explain how the Company can ensure the construction of the project was
completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthlyproject status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 20 JULY 31,2023
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.187:Please provide the followingdocumentation for the work on the
Midpoint-to-Borah 345-kV transmission line referenced in Colburn's Direct Testimony.If any
of the information requested below cannot be provided or is not available,please explain why.
Additionally,for any information that cannot be provided please explain how the Company can
ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 21 JULY 31,2023
v.Baseline Schedule;
vi.Monthlyproject status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s);
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.188:Please provide the followingdocumentation for the multi-year
undergroundcable replacement program referenced in Colburn's Direct Testimony.If any of the
information requested below cannot be provided or is not available,please explain why.
Additionally,for any information that cannot be provided please explain how the Company can
ensure the construction of the project was completed at least cost.
a.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives
b.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
c.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 22 JULY 31,2023
iv.RFP from winning bid.
d.Project construction documentation including
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
vi.Monthlyproject status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
e.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actual schedule comparison;and
iv.For any actual costs differing from the budget amount by plus or minus
five percent during a particular year,please list and explain the reason(s)
for the budget amount difference.
f.Documentation specific to Idaho Power approving the project prior to start of
construction
g.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost to its customers.
REQUESTNO.189:Please provide explanations for Company "2022 Actual
Adjustments (column E),""Forecast Adjustments (column H),"or "AnnualizingAdjustment"
(column K)in Exhibit 34 for the followingaccounts.Please include calculations of adjustments
in Excel Format with formulas intact.
a.Other (Line 444)-Please justifythe 40%increase for the "Forecast Adjustment";
b.Miscellaneous Expenses (Line 484)-Please justify the increase of 481%for the
"Forecast Adjustment"and the increase of 43%for the "Annualizing
Adjustment";
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 23 JULY 31,2023
c.Overhead Lines (Line 522)-Please justify the increase of 35%for the "2022
Actual Adjustment";
d.Overhead Lines (Line 553)-Please justifythe increase of 58%for the "2022
Actual Adjustment";
e.Uncollectible Accounts (Line 566)-Please justifythe increase of 77%for the
"Forecast Adjustment";
f.Injuriesand Damages (Line 590)-Please justifythe increase of 81%for the "2022
Actual Adjustments";and
g.Employee Pensions &Benefits-Idaho (Line 593)-Please justifythe increase of
105%for the "Forecast Adjustment".
REQUESTNO.190:Please describe the benefits to customers of having Company
barista(s)and Company funded coffee service onsite.Please provide a cost/benefit analysis for
these expenses.Please also provide the annual budget for the barista service.Please provide
revenue and expense details in years 2018-2023.Please provide an overview of how the barista
service affects this case.
REQUESTNO.191:Please provide details of all hosted or attended safety summits in
years 2018-2023.Please provide the cost of each safety summit,location of the summit(s),copy
of materials provided.Please provide an overview of how safety summits affect this case.
REQUESTNO.192:Please provide a list of workshops and expos,and the respected
costs,the Company held in years 2018-2023.In your response,please provide whether each
workshop and expo are annual events,locations,and the cost.Please provide an overview of
how workshops and expos affect this case.
REQUESTNO.193:Please provide Company's Idaho and Oregon Income Tax Returns
for 2021 and 2022.
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 24 JULY 31,2023
REQUESTNO.194:Please provide the monthly uncollectible write-off expenses in
years 2018-2023.Please separate this information into Oregon and Idaho customers.
REQUESTNO.195:Please explain
according to Company Confidential Attachment No.5 in Response to
Production Request No.1.
REQUESTNO.196:Please provide an overview of open employment opportunities for
each month from 2018-2023.Please indicate the average time to fill open positions for each
year.
DATED at Boise,Idaho,this day of July 2023.
ardie
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.1ldhkl prod req 7 redacted
CONFIDENTIAL SEVENTH PRODUCTION REQUEST
TO IDAHO POWER 25 JULY 31,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 316'DAY OF JULY 2023,SERVEDTHEFOREGOINGREDACTEDSEVENTHPRODUCTIONREQUESTOFTHE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-11,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail] [e-mail]
[e-mail]
[e-mail]
KELSEY JAE MICHAEL HECKLER
LAW FOR CONSCIOUS LEADERSHIP COURTNEY WHITE
920 N CLOVER DR CLEAN ENERGY OPPORTUNITIES
BOISE ID 83703 3778 PLANTATION RIVER DR
E-MAIL:[e-mail] STE 102
BOISE ID 83703
E-MAIL:
[e-mail]
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aegisinsight.com
E-MAIL:elo echohawk.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27THST EAGLE ID 83616
BOISE ID 83702 E-MAIL:[e-mail]
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 HOLLAND &HART LLP
E-MAIL:[e-mail] 555 17TH ST STE 3200
DENVER CO 80202
E-MAIL:[e-mail]
[e-mail]
[e-mail]
[e-mail]
clmoser hollandhait.com
TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-MAIL [e-mail]
[e-mail]
ED JEWELL WIL GEHL
DARRELL EARLY ENERGY PROGRAM MANAGER
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S OFFICE PO BOX 500
PO BOX 500 BOISE ID 82701-0500
BOISE ID 83701-0500 E-MAIL:weehl citvofboise.org
E-MAIL:[e-mail]
ejewell citvofboise.ore
dearly citvofboise.ore
MARIE CALLAWAY KELLNER BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:mkellner idahoconservation.org E-MAIL:
bheusinkveld idahoconservation.org
PETER MEIER DWIGHT ETHERIDGE
US DEPT OF ENERGY EXETER ASSOCIATES
1000 INDEPENDENCE AVE SW 5565 STERRETT PLACE
WASHINGTON DC 20585 STE 310
E-MAIL:[e-mail] COLUMBIA MD 21044
E-MAIL:detheridge exeterassociates.com
CERTIFICATE OF SERVICE
F.DIEGO RIVAS
NW ENERGY COALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:diego nwenergy.org
SECRETARY
CERTIFICATE OF SERVICE