20230816Staff 232-252 to IPC.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
Attorneyfor 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 )ELEVENTH PRODUCTION
IN THE STATE OF IDAHO AND FOR )REQUESTOF THE
ASSOCIATED REGULATORY )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 AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than WEDNESDAY AUGUST 30,2023.1
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 telephonenumber of
'Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER l AUGUST 16,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
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.232:According to the Direct Testimony of Company Witness Hackett
at 12,the Company identified a near-term deficit in summer 2023.
a.Please provide the load and resource balance analysis prepared in May 2021,in
which the 2023 capacity deficit was anticipated;and
b.Please provide all load and resource balance analyses produced after May 2021.
REQUESTNO.233:Please provide a copy of:IHSMarkit:"Multiplefactors halt
downward trajectory of Li-ion battery costs,with higher prices for energy storage systems set to
continue throughout 2022 and 2023"January 6th,2022,as referenced in Company Witness
Hackett's Direct Testimony at 21.
REQUESTNO.234:Company Witness Barretto's Direct Testimony at 10 stated,"In
addition,all new or unbudgetedUnit 2 or common facility capital projects larger than $1 million,
at the plant level,require a review and authorization in writingby each Valmy Co-Owner prior
to starting the project."Please answer the following:
a.What are the new capital projects less than $1 million and what are their costs?
b.What are the unbudgetedUnit 2 projects less than $1 million and what are their
costs?
c.What are the common capital projects less than $1 million and what are their
costs?
d.Please explain the budget review and authorization process for the above-
mentioned capital projects.
REQUESTNO.235:As referenced in Company Witness Barretto's Direct Testimony
at 11,please provide the followinginformation:
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 16,2023
a.Authorization of Expenditures ("AFE")requests produced by NV Energy for all
capital projects from 2012 to 2023;and
b.Considering the statement:"If the project is expected to exceed the AFE amount
by either 10 percent,for variances greater than $10,000,or $100,000,a
supplemental AFE is required."Please provide all supplemental AFEs that satisfy
these criteria.
REQUESTNO.236:Please provide the followingdocumentation for the Valmy Pin
Mixer/Unloader Rebuild (Project No.27528897)referenced in Company Witness Barretto's
Direct Testimony at 15.If any of the information requested below cannot be provided or is not
available,please explain why,and explain how the Company can ensure the construction of the
project was completed in a least-cost manner.
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;
iii.Proposed schedule;and
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.Monthlyproject status report(s);
vii.Action items list(s);and
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 3 AUGUST 16,2023
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.
h.Documentation and a detailed explanation of the incident where the ash hauling
dump truck damaged Unit 2 wet fly ash unloader and the total damage caused by
the incident.
REQUESTNO.237:Please provide the followingdocumentation for the Valmy
Ground Water MonitoringWell Installation (Project No.27555279)referenced in Barretto Direct
Testimony at 31.If any of the information requested below cannot be provided or is not
available,please explain why,and also explain how the Company can ensure the construction of
the project was completed in a least-cost manner.
a.A copy of the Nevada Division of Environmental Protection ("NDEP")'s well
monitoring guidelines.
b.Copies of reports or documentation demonstrating 9 wells that were reading
critical ground water levels (five wells that were reading above top screen level
and four wells that were close to be invalid).
c.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
d.Project Plan
i.Initial project scope;
ii.Proposed budget;and
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 4 AUGUST 16,2023
iii.Proposed schedule.
e.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winning bid.
f.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).
g.Company project completion analysis
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actualschedule 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.
h.Documentation specific to Idaho Power approving the project prior to start of
construction.
i.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
REQUESTNO.238:According to Company Witness Barretto's Direct Testimony at
20,the Company found it is more cost-effective to purchase Freeze Protection Heaters than
renting Portable Electric Space Heaters for the Valmy Plant with an approximate cost of
$541,000.Please provide the followinginformation as requested.If any of the information
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 5 AUGUST 16,2023
requested below cannot be provided or is not available,please explain why,and also explain how
the Company can ensure the construction of the project was completed at least cost.
a.A justification of need for the project and a cost-benefit analysis.
b.Details on previous rental contract or orders of Portable Electric Space Heaters
since 2012 until the purchase and installation of the Freeze Protection Heaters.
c.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
d.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winning bid.
e.Documentation specific to Idaho Power approving the project prior to start of
construction.
f.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
REQUESTNO.239:Please provide the followinginformation as requested on the
Project No.27493693 (Bridger 2017Cl10 U4 Boiler Optimization System 17).If any of the
information requested below cannot be provided or is not available,please explain why,and also
explain how the Company can ensure the construction of the project was completed at least cost.
a.The followingdetails on the neural network combustion controls and soot
blowing optimizer (includingbut not limited to):
i.Make,model,capacity,specifications,etc.;and
ii.Brochure,datasheets,etc.
b.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
c.Project Plan
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 6 AUGUST 16,2023
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
d.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
e.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).
f.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.
g.Documentation specific to Idaho Power approving the project prior to start of
construction.
h.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 7 AUGUST 16,2023
REQUESTNO.240:Please provide the followinginformation as requested on the
Project No.27475574 (Bridger CITC2017C207 Backup Bandwidth Upgrades 2017).If any of
the information requested below cannot be provided or is not available,please explain why,and
also explain how the Company can ensure the construction of the project was completed at least
cost.
a.The followingdetails on previous/deprecatedradio communications at the plant
(includingbut not limited to):
i.Make,model,capacity,specifications,etc.;and
ii.Brochure,datasheets,etc.
b.The followingdetails on the upgraded radio communications at the plant
(includingbut not limited to):
i.Make,model,capacity,specifications,etc.;and
ii.Brochure,datasheets,etc.
c.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
d.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
e.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winningbid.
f.Project construction documentation including:
i.Construction contract;
ii.Organizational chart;
iii.Scope document;
iv.Work breakdown structure;
v.Baseline Schedule;
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 8 AUGUST 16,2023
vi.Monthlyproject status report(s);
vii.Action items list(s);and
viii.Contractors change order request(s).
g.Company project completion analysis:
i.Lessons learned;
ii.Budget-to-actual comparisons for overall project and by year;
iii.Baseline schedule-to-actualschedule 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.
h.Documentation specific to Idaho Power approving the project prior to start of
construction.
i.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
REQUESTNO.241:Please provide the followinginformation as requested on the
Project No.27574748 (Valmy 98483985 V2 Ovation HMI and Server Update).If any of the
information requested below cannot be provided or is not available,please explain why,and also
explain how the Company can ensure the construction of the project was completed at least cost.
a.The followingdetails on previous/deprecatedEmerson Ovation Distributed
Control System ("DCS")equipment at the plant (includingbut not limited to):
i.Make,model,capacity,specifications,etc.;and
ii.Brochure,datasheets,etc.
b.All communications with Emerson confirmingthe end of previous DCS's original
equipment manufacturer ("OEM")support.
c.The followingdetails on upgraded DCS at the plant (includingbut not limited to):
i.Make,model,capacity,specifications,etc.;and
ii.Brochure,datasheets,etc.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 9 AUGUST 16,2023
d.A copy of the latest Top 20 Critical Security Controls ("CSC")SANS guidelines
for cyber defense and detection tools,as mentioned in Exhibit No.2 Barretto
Direct at 1.
e.Analysis of Need -a justification of need for the project and a cost/benefit
analysis comparing alternatives.
f.Project Plan
i.Initial project scope;
ii.Proposed budget;and
iii.Proposed schedule.
g.RFP
i.Project requirements;
ii.Specifications;
iii.Short list bidder scorecard;and
iv.RFP from winning bid.
h.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).
i.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.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 10 AUGUST 16,2023
j.Documentation specific to Idaho Power approving the project prior to start of
construction.
k.Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
REQUESTNO.242:Please provide the followinginformation regarding the Midpoint-
to-Borah 345-kV transmission modifications as mentioned in Colburn Direct at 11.
a.Clear and detailed maps identifying the locations where the enhancements were
performed since 2012 to date.Please use color highlighting (or suitable
alternatives)to distinguish between the completed portion of the project,the
ongoing portion of the project,and the future work.
NOTE:Please provide this map in an electronic format (.pdf)which can be scale
enlarged to identify all aspects of the system.
b.Justification and documentation supporting on the issues that began to arise as the
transmission line aged (according to Colburn Testimony).
i.The details should include but not be limited to power outages and
disruption reports,customer complaints,etc.
REQUESTNO.243:Please provide the followinginformation regarding the
underground cable replacement program that began in 2012 as mentioned in Colburn Direct at
16.If any of the information requested below cannot be provided or is not available,please
explain why.Please also explain how the Company can ensure the construction of the project
was completed at least cost.
a.Clear and detailed maps identifyingthe locations/zones of the 4 million feet of
direct-buried cable that was replaced with cable within the conduit.
b.Clear and detailed maps identifyingthe locations/zones of the remaining 3 million
feet of direct-buried cable that is planned to be replaced with cable within the
conduit.Please use color highlighting(or suitable alternatives)to distinguish
between the completed portion of the project,the ongoing portion of the project,
and the future work.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 11 AUGUST 16,2023
NOTE:Please provide this map in an electronic format (.pdf)which can be scale
enlarged to identify all aspects of the system.
i.Justification and documentation supporting the reliability issues the
Company was facing that compelled the Company to replace 7 million
feet of existing direct-buried distribution cables;and
ii.The details should include but not limited to power outages and disruption
reports,customer complaints,etc.
REQUESTNO.244:Please provide the followinginformation regarding the Field Area
Network ("FAN")and replacement of an Automated Capacitor Control ("ACC")system with the
development of a new integrated volt-var control ("IVVC")system,mentioned in Colburn Direct
at 17.If any of the information requested below cannot be provided or is not available,please
explain why.Please also 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;
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 12 AUGUST 16,2023
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 manner to its customers.
REQUESTNO.245:"SBAR =Energy Related Generation Function Revenue
Requirement ÷ Idaho Retail Sales"Please explain why Line 114 in the "Miscellaneous"section
of Exhibit No.38 is part of "Energy Related Generation Function Revenue Requirement".
REQUESTNO.246:Tab "Table I"of Exhibit No.49 shows "A&G Expense
Exclusion"is subtracted from "Energy Related Generation Function Revenue Requirement".
Please respond to the following:
a.Please define A&G Expense Exclusion;
b.Please explain why A&G Expense Exclusion should be subtracted from "Energy
Related GenerationFunction Revenue Requirement"when the SBAR is
calculated;
c.Please explain why Line 499 through Line 558 in Exhibit No.37 represent the
portion of the overall A&G exclusion that should be subtracted from "Energy
Related GenerationFunction Revenue Requirement";
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 13 AUGUST 16,2023
d.Please define Line 536 "energy related FERC admin assess &securities"and
explain why this should be excluded;
e.Please define Line 538 "FERC Order 472"and explain why this should be
excluded;and
f.Please define Line 558 "Merchandising Expense"and explain why this should be
excluded.
REQUESTNO.247:Tab "Table I"of Exhibit No.49 shows "Subsidiary Income"is
subtracted from "Energy Related Generation Function Revenue Requirement".Please respond
to the following:
a.Please define "Subsidiary Income";
b.Please explain how "Subsidiary Income"is calculated and provide the workpaper
with formula intact;
c.Please explain why "Subsidiary Income"should be subtracted from "Energy
Related Generation Function Revenue Requirement";and
d.Subsidiary Income is based on Line 35 of Exhibit No.42 "IERCO Operating
Income."Please explain what IERCO stands for and what IERCO Operating
Income means.
REQUESTNO.248:Please re-run the AURORA model and provide an updated Table
5 "2023 Base Level NPSE,"contained in Brady's Direct Testimony,with Bridger Units 1 and 2
not converted to natural gas units.
REQUESTNO.249:Regarding the attachment in the Company's response to
Production Request No.81,please indicate how the amount of "2023 Forecasted Billed
Revenue,"of $1,641,862,697,correlates to the revenue requirement model.
REQUESTNO.250:Please indicate the percentage and effective dates of all General
Wage Increases ("GWI")that occurred since the Company's last general rate case.
ELEVENTH PRODUCTION REQUEST
TO IDAHO POWER 14 AUGUST 16,2023
REQUEST NO. 251: Please list the number of customer service representatives
("CSRs") employed in each month from 2017-2023.
REQUEST NO. 252: In regards to the Excel file labeled "Attachment -Response to
Staff Request No. 96" provided by the Company, the analysis is performed without Battery
Energy Storage System ("BESS'') Projects. Please answer the following:
a.Please explain why the Company conducts this analysis without BESS Projects;
b.Please explain why BESS projects should not be considered when establishing
TOU rates;
c.Please explain why BESS projects should not be considered when expanding the
summer season;
d.The Company's analysis includes Demand Response as a resource, please explain
why it is appropriate to include Demand Response while BESS resources are
removed; and
e.Please provide an updated worksheet that updates all analysis and accompanying
tabs by including all existing and contracted BESS Projects.
16� DATED at Boise, Idaho, this day of August 2023.

i:umisc:prodreq/ipce23. I ldhkl prod req 11
ELEVENTH PRODUCTION REQUEST TO IDAHO POWER
Dayn Hardie Deputy Attorney General
15 AUGUST 16, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF AUGUST 2023,
SERVED THE FOREGOING ELEVENTH PRODUCTION REQUESTOF THE
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:[e-mail]
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27TH ST EAGLE ID 83616
BOISE ID 83702 E-MAIL:dreading mindspring.com
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 hollandhart.com
TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
[e-mail]
erin.cecil arkoosh.com
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.org
dearly cityofboise.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