20230821IPC to Staff 155_157-158_161-168_171-173_176_179-182_189-191_193-196.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 21, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-11
Idaho Power Company’s General Rate Case

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response
Request Numbers 155, 157, 158, 161, 162, 163, 164, 165, 166, 167, 168, 171, 172, 173,
176, 179, 180, 181, 182, 189, 190, 191, 193, 194, 195, and 196 to the Confidential
Seventh Production Request of the Commission Staff to Idaho Power Company. Because
of the volume of documentation requested in the Seventh Production Request, the
Company is providing the responses in a minimum of two tranches, as discussed with
Commission Staff, and anticipates to have the entire set submitted no later than August
25, 2023. The attached 85+ page narrative response is supported by nearly 1,000
documents. The attachments will be made available as quickly as Idaho Power can
assemble them in the format requested by the Commission Staff. The Company will
update the parties via email as soon as those attachments are made available.

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 Idaho Power Company’s Response to the Commission Staff’s Seventh
Production Request to the secure FTP site. Because certain attachments contain
confidential information, the FTP site is password protected and access will only be
provided to those parties who have executed the Protective Agreement in this matter. The
confidential version of the above-mentioned discovery responses can be found in the FTP
site.

Please note that the entire set of documents responsive to the Commission Staff’s
Seventh Protection Request is password protected so that both confidential and non-
confidential attachments could be grouped holistically for review. Documents subject to
the Protective Agreement are marked “CONFIDENTIAL.” To gain access to the secure
RECEIVED
2023 AUGUST 21, 2023 4:47PM
IDAHO PUBLIC
UTILITIES COMMISSION
Jan Noriyuki
August 21, 2023
Page 2

FTP site, please contact Stacy Gust via email at [e-mail] or Christy
Davenport via email at [e-mail].

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,

Lisa D. Nordstrom
LDN:cd
Enclosures

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-11
In the Matter of the Application of Idaho Power Company for Authority to Increase
Its Rates and Charges for Electric Service to Its Customers in the State of Idaho
and For Associated Regulatory Accounting Treatment

The undersigned attorney, in accordance with Commission Rules of Procedure
67, believes that some of the attachments in Response to Requests Nos. 155, 165, 172,
173, 179, 180, 181, 182, and 193 to Idaho Power Company’s Response to the
Confidential Seventh Production Request of the Commission Staff dated July 31, 2023,
contain information that Idaho Power Company and a third party claim are trade secrets
and/or business records of a private enterprise require by law to be submitted to or
inspected by a public agency, as described in Idaho Code § 74-101, et seq., and/or §
48-801, et seq. As such, it is protected from public disclosure and exempt from public
inspection, examination, or copying.

DATED this 21st day of August 2023.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
)
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
RESPONSE TO THE
CONFIDENTIAL SEVENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Confidential Seventh Production Request of the Commission Staff
(“Commission” or “Staff”) dated July 31, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 155: Please provide the referenced
presentation by Idaho Power's supplier in June of 2022 highlighting the "Utility Market
Commodity Impacts and Outlook" Grow Direct at 27.
RESPONSE TO REQUEST FOR PRODUCTION NO. 155: The Utility Market
Commodity Impacts presentation from Wesco that is referenced on page 27 of Ms.
Grow’s testimony is provided in the confidential attachment. For clarification, this report
was first published in May 2022.
The response to this Request is sponsored by Debra Leithauser, Vice President
of Corporate Services and Communications, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 156:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 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).

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5

RESPONSE TO REQUEST FOR PRODUCTION NO. 157: Please refer to
Confidential Attachment 1-Response to Staff Request No. 35 provided on July 5, 2023,
in response to the First Production Request of the Commission Staff.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 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).
RESPONSE TO REQUEST FOR PRODUCTION NO. 158:
Please refer to Confidential Attachment 1-Response to Staff Request No. 35
provided on July 5, 2023, which provided capital projects completed through May 2023 in
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7
response to the First Production Request of the Commission Staff. Please see
Confidential Attachment 1-Response to Staff Request No. 158 for capital projects
completed in June 2023. The information includes June accounting activity for work
orders previously placed in service.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 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 quantify the difference between the proposed current levels to actuals and/or
forecasts.
RESPONSE TO REQUEST FOR PRODUCTION NO. 159:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 160:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 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.)
RESPONSE TO REQUEST FOR PRODUCTION NO. 161:
The Jim Bridger Power Plant (“Bridger”), in which PacifiCorp owns two-thirds and
is operator of the plant and Idaho Power has one-third ownership, is owned and operated
in accordance with three agreements: the Agreement for the Ownership of the Jim Bridger
Project between Idaho Power Company and Pacific Power & Light Company, the
Agreement for the Construction of the Jim Bridger Project between Idaho Power
Company and Pacific Power & Light Company, and the Agreement for the Operation of
the Jim Bridger Project between Idaho Power Company and Pacific Power & Light
Company (“Operation Agreement”), all of which are dated September 22, 1969, as
amended by Amendments 1 through 9 (collectively, “Bridger Agreements”). The Bridger
Agreements set forth the respective obligations of the owners with respect to the
ownership, construction, and operation of Bridger.
As the plant operator, PacifiCorp manages the capital budget for Bridger. However,
the Company is and always has been actively involved in the decision-making process in
all matters associated with Bridger capital investments as a co-owner. While PacifiCorp,
as the operator, vets and analyzes the need for specific capital replacements as they
arise to continue reliable and safe operation of the plant, Idaho Power regularly

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 11
participates in discussions of the capital investment forecast prepared by PacifiCorp,
influencing the investments ultimately made. As a one-third owner and non-operating
partner, Idaho Power receives from PacifiCorp a monthly billing invoice, invoice support
documentation, and monthly invoice reconciliation. Appropriation Requests (“APR”) are
available for every project, which include a project description, investment reason, project
number, and projected expenditures for the project, by year. During the quarterly
Ownership Meetings, Idaho Power reviews the current year operations and maintenance
(“O&M”) expense and capital budgets and forecasts.
Further, under Section 5.4 of the Operation Agreement, on or before October each
year, PacifiCorp will submit a forecast of its estimate of operating expenses for the
following calendar year, including capital projects, to Idaho Power. The budget will include
items of expenditures for replacement and repair of facilities and will include a
contingency for emergency repairs and replacements. The forecast is subject to approval
by the Company. Under the agreement, if the forecast for projects changes by 10 percent
or more during the calendar year, PacifiCorp will notify Idaho Power. In addition,
beginning in 2005, forecasts for projects over $1 million that change by 10 percent or
more during the calendar year must be approved by both Bridger co-owners.
With respect to the Company’s participation in Bridger capital investment
discussions that meet the contractual rights just described, mid-year PacifiCorp and Idaho
Power hold a capital budget review where the forecasted capital projects expected to
occur over the next three calendar years over $50,000 are discussed in detail. In addition,
large capital projects expected over the next decade are reviewed, such as unit
overhauls, and the scope and need of projects are discussed. Following the meeting,

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 12
plant personnel consolidate and finalize the list of all projects, including the scope, need,
and consequence for each.
During the fall quarterly Ownership Meeting, the plant personnel presents a formal
capital and O&M expense budget for the following year as well as a high level 10-year
forecast. The intent of the meeting is for both Idaho Power and PacifiCorp to ask
questions of the plant personnel, most often the subject matter experts, about any details
surrounding the forecasted capital investments and O&M expense. Once the budget is
approved, during each quarterly Ownership Meeting, a standing agenda item is to review
the current year capital and O&M expense budget. This review routinely provides Idaho
Power the opportunity to raise any questions necessary about current or upcoming
projects. Additionally, on a monthly basis, forecasts for capital and O&M expenses are
provided for review by the Company. Idaho Power is continuously involved in capital
investment discussions, both prior to the project commencing and during the completion
phase, providing input and approval, and ensuring the projects are being completed in a
least cost manner.
Other than the procedures referenced in this response, there are no Idaho Power-
specific guidelines or procedures documenting the methods relative to management of
the capital investments at Bridger as the decision-making process is one that continuously
occurs jointly with the two co-owners. Additionally, as noted in the Exhibit No. 1 to the
direct testimony of Lindsay Barretto, Idaho Power plans to implement the Major Projects
Checklist that will detail review timing and documentation for all projects over a certain
threshold, including specific documentation if costs exceed the budget by a certain
amount as well as an Oversight Meeting Checklist to document its participation in the

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 13
quarterly meetings at Bridger, including the budget overview document provided at and
discussed during these meetings.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 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.)
RESPONSE TO REQUEST FOR PRODUCTION NO. 162:
Please see the Company’s Response to Request for Production No. 161 for a
discussion of how Idaho Power ensures projects are completed in a least cost manner at
the Jim Bridger Power Plant. Idaho Power cannot speak to any additional methods
PacifiCorp uses to ensure capital investments were completed in a least-cost manner
outside of those that are performed jointly with Idaho Power.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 163:
a. In their review of Case No. IPC-E-22-05, the Company’s request for prudence of
Valmy investments made during the January 1, 2019, through December 31, 2021, time
period, Staff indicated they could not recommend that the investments were operationally
prudent due to lack of sufficient evidence documenting that the projects were done in a
least-cost manner. With Order No. 35494, the Commission indicated it was fair, just, and
reasonable for the Company to file additional documentation to support a prudence
determination after working with Staff to expand the documentation process. As part of
that process, Idaho Power created the Oversight Meeting Checklist that is intended to
document the Company’s ongoing and continual participation in the capital budget
reviews of each plant throughout the year, encompassing the entirety of the capital
budget, all in one location, regardless of the dollar amount of individual projects.
b. As explained in Ms. Barretto’s testimony, Staff and Idaho Power are still working
to memorialize and finalize the information and documentation necessary for Staff’s

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 16
prudence review, including the Oversight Meeting Checklist, therefore it has not yet been
implemented.
c. Please see the Company’s Response to Staff’s Request for Production No. 161.
The checklist will be in addition to Idaho Power’s current procedures that include
continuous involvement in the capital investment decision-making process, documenting
the entirety of the process in one location.
d. Please see parts (a) and (b).
e. Please see part (b).
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 17
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 164:
Due to the voluminous nature of this request, the Company has included as
Attachment 1 – Response to Staff’s Request No. 164, all Appropriation Requests (“APR”)
associated with projects over $100,000 at the Idaho Power level. The projects for which
the APR are provided are the same projects where the Company provided a project
description and investment purpose classification in Exhibit No. 3 of the direct testimony
of Lindsay Barretto, totaling 61 projects. Included as Attachment 2 – Response to Staff’s
Request No. 164 is a copy of Exhibit No. 3 with an additional column identifying the APR
number associated with each of the 61 projects. If Staff is interested in reviewing APR
associated with any additional projects, the Company will supplement this response with
those identified. Please note, Idaho Power does not sign the APR but does provide written
approval, as provided in the Response to Request for Production No. 165(f).
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 18
REQUEST FOR PRODUCTION NO. 165: Please provide the following
documentation for Jim Bridger Power Plant Power 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 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 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;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 19
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
h. Indicate whether the Company has completed a checklist referenced in Barretto
Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 165:
Due to the voluminous nature of this request associated with all projects greater
than $250,000 on a plant level, or $83,333 on an Idaho Power level, the Company is
instead providing the information requested for all projects over $250,000 on an Idaho
Power level. If, however, Staff is interested in the information requested associated with

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 20
any additional projects, the Company will supplement this response with the additional
documentation of those projects identified. Attachment 2 – Response to Staff’s Request
No. 164 includes a copy of Exhibit No. 3 with additional information to support the
documentation provided in response to this request. The Company has added a column,
Project Number, identifying those projects greater than $250,000 for which the Company
is providing additional documentation in response to this request.
a. The Company has added to Attachment 2 – Response to Staff’s Request No. 164
a column, Part (a) Analysis of Need, to identify the attachment(s) provided in response to
this request that detail the analysis of the need for the corresponding project.
b. The Company has added to Attachment 2 – Response to Staff’s Request No. 164
a column, Part (b) Project Plan, to identify the attachment(s) provided in response to this
request that detail the project plan for the corresponding project.
c. The Company has added to Attachment 2 – Response to Staff’s Request No. 164
a column, Part (c) RFP, to identify the attachment(s) provided in response to this request
that describes the issuance of an RFP and the associated responses, if applicable, for
the corresponding project.
d. The Company has added to Attachment 2 – Response to Staff’s Request No. 164
a column, Part (d) Project Construction Documentation, to identify the attachment(s)
provided in response to this request that support the construction/addition of the
corresponding project.
e. The Company has added to Attachment 2 – Response to Staff’s Request No. 164
a column, Part (e) Project Completion Analysis, to identify the original work order approval

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 21
amount and the variance between actuals of the corresponding project. In addition, for
variances greater than 5 percent, an explanation has been included.
f. Idaho Power’s approval of the Bridger capital projects occurs as part of the yearly
budget approval process. Following the Jim Bridger Ownership Meeting with the budget
presentation, the Company provides the plant written authorization of the capital budget
as well as a list of the capital projects that make up that budget amount. Please see
Attachments 1 and 2 – Response to Staff Request No. 165(f) for the Company’s approval
of those capital projects over $250,000 as identified in Attachment 1 – Response to Staff
Request No. 165 and for which Idaho Power is seeking prudence in this case.
g. As explained in the Company’s Response to Request for Production No. 161, once
the budget is approved for Bridger, during each quarterly Ownership Meeting, a standing
agenda item is to review the current year capital and O&M expense budget, routinely
providing Idaho Power the opportunity to raise any questions necessary about projects.
Additionally, on a monthly basis, forecasts for capital and O&M expense are provided for
review by the Company. Idaho Power is continuously involved in capital investment
discussions, both prior to the project commencing and during the completion phase,
providing input and approval, and ensuring the projects are being completed in a least
cost manner.
h. The Major Projects Checklist and the Oversight Meeting Checklist were developed
in response to Order No. 35494 in which the Commission directed the Company to work
with Staff to expand the documentation process necessary to support a prudence
determination of the joint project investments. As explained in Ms. Barretto’s testimony,
Staff and Idaho Power are still working to memorialize and finalize the information and

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 22
documentation necessary for Staff’s prudence review. Because the checklists have not
been finalized, they are not available for use in determining prudence of investments
requested as part of this case.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 23
REQUEST FOR PRODUCTION NO. 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.)
RESPONSE TO REQUEST FOR PRODUCTION NO. 166:
The North Valmy Power Plant (“Valmy”) is jointly owned by NV Energy and Idaho
Power with each co-owner having 50 percent ownership. NV Energy operates the Valmy
facility, however it works jointly with the Company to make decisions regarding Valmy.
The ownership and operation of Valmy is governed by three agreements: the Agreement
for the Ownership of the North Valmy Power Plant Project, the Agreement for the
Operation of the North Valmy Power Plant Project, both of which are dated December 12,
1978, and the North Valmy Station Operating Procedures Criteria, dated as of February
11, 1993, between Idaho Power Company and Sierra Pacific Power Company,1 as
amended by Amendment No. 1 to the Operating Procedure Criteria for Valmy Coal
Diversion Procedures and Usage, dated as of January 1, 2012. Additionally, the Parties
entered into the North Valmy Project Framework Agreement between NV Energy and
Idaho Power dated as of February 22, 2019 (“Framework Agreement”), memorializing the
terms and conditions under which either partner may elect exit of participation of Valmy.
As a 50 percent owner of the plant, Idaho Power is involved in the decision-making
process related to capital investments at Valmy. NV Energy manages the capital budget

1 Sierra Pacific Power Company has conducted business as NV Energy since 2008.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 24
for Valmy as the plant operator, however, Idaho Power has established guidelines at
Valmy to allow NV Energy to manage the capital budget as needed and directed by the
plant manager, without exceeding the yearly budget, or adding large projects without
authorization by both the Company and NV Energy. These guidelines provide the
appropriate level of oversight while allowing the plant operator to practically manage the
plant and any variances that may occur throughout the budget year.
In accordance with the guidelines, if Idaho Power’s share of the capital forecast is
greater than the capital budget by more than $100,000, the Company will review and may
authorize the budget change. In addition, all new or unbudgeted Unit 2 or common facility
capital projects larger than $1 million, at the plant level, require a review and authorization
in writing by both Idaho Power and NV Energy prior to starting the project. Finally, any
time an individual Unit 2 or common facility capital project with a value greater than $1
million, at the plant level, is forecast to exceed the current year original budget by 20
percent, each Valmy co-owner must review and authorize it in writing prior to starting or
continuing the project.
Individual capital project variances are discussed during Ownership Meetings and
other meetings as directed by the Valmy co-owners. In addition, NV Energy produces an
Authorization for Expenditures (“AFE”) request for all capital projects. AFE include the
project title, date, project manager, description and purpose of the expenditure, cost and
budget information, along with various other information to provide support for the project.
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.
Upon execution of the Framework Agreement and Idaho Power’s planned exit of

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 25
coal-fired operations at the plant, beginning in 2020, Idaho Power began providing
authorization to NV Energy of all AFEs and supplemental AFE for each project. The
Company has requested that no projects begin, and the total annual budget may not be
exceeded, unless the AFE is approved by both NV Energy and Idaho Power. Lastly, in
addition to the plant-specific guidelines detailed above, Idaho Power performs holistic
budget reviews on a monthly basis. This includes all capital expenditures at Valmy, and
therefore provides an additional review process through which the Company monitors its
capital spend.
Other than the procedures referenced in this response, there are no Idaho Power-
specific guidelines or procedures documenting the methods relative to management of
the capital investments at Valmy as the decision-making process is one that continuously
occurs jointly with the two co-owners. However, as noted in Exhibit No. 1 to the direct
testimony of Lindsay Barretto, Idaho Power plans to implement the Major Projects
Checklist that will detail review timing and documentation for all projects over a certain
threshold, including specific documentation if costs exceed the budget by a certain
amount as well as an Oversight Meeting Checklist to document its participation in
meetings regarding Valmy with NV Energy, including the budget overview document
provided at and discussed during these meetings.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 26
REQUEST FOR PRODUCTION NO. 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.)
RESPONSE TO REQUEST FOR PRODUCTION NO. 167:
Please see the Company’s Response to Request for Production No. 166 for a
discussion of how Idaho Power ensures projects are completed in a least cost manner at
the North Valmy Power Plant. Idaho Power cannot speak to any additional methods NV
Energy uses to ensure capital investments were completed in a least-cost manner outside
of those that are performed jointly with Idaho Power.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 27
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 168:
Please see the Company’s Response to Request for Production No. 163. The
Oversight Meeting Checklist is envisioned to be used for both Bridger and Valmy
documentation.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 28
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 169:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 29
REQUEST FOR PRODUCTION NO. 170: Please provide the following
documentation 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;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 30
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
h. Indicate whether the Company has completed a checklist referenced in Barretto
Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 170:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 31
REQUEST FOR PRODUCTION NO. 171: Please provide documentation of all
communication between the Company and Powin Energy Corporation ("Powin") as part
of the June 30, 2021, RFP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 171: Powin was not a
participant in the RFP issued June 30, 2021, therefore there was no communication
between Idaho Power and Powin regarding the 2021 RFP. However, see Idaho Power’s
Response to Request for Production Nos. 172-176 related to the process and
documentation that led to the selection of Powin as the manufacturer to provide the Black
Mesa 40 MW and Hemingway 80 MW battery energy storage systems.
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 32
REQUEST FOR PRODUCTION NO. 172: Please provide documentation of all
communication between the Company and Powin Energy Corporation following the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 172: See the Company’s
Response to Staff’s Request for Production No. 173 as the Black Mesa 40-MW BESS
was negotiated at the same time as the Hemingway 80-MW BESS.
Confidential Attachment 1 – Response to Staff Request No. 172 – Black Mesa
Change Orders provides additional contract related change orders since the execution of
the original Battery Energy Storage Agreement (“BESA”).
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 33
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 173: Idaho Power began a
competitive solicitation for battery energy storage systems in July 2021 requesting up to
80 MW of capacity with a commercial operation date of June 1, 2023, as identified in
Attachment 1 – Response to Staff Request No. 173 – RFQ Documents in which Powin
was identified as a potential supplier and provided a response in August 2021. Idaho
Power sent a request for quotes (“RFQ”) to eight different battery manufacturers. The
indicative pricing received from these 16 suppliers, including Powin, was comparative to
the lowest-cost proposals for 17 similar battery storage projects submitted through the
RFP process.
At that time, Idaho Power was already negotiating a contract with Powin related to
numerous small distribution battery implementations that resulted in four Battery Energy
Supply Agreements (“Distribution BESA”). Although negotiating the Distribution BESA’s
leading up to their execution in December 2021, Idaho Power’s communication with
Powin as it related to the Hemingway 80 MW and Black Mesa 40 MW BESS projects was
limited. The Company assumed that should Powin ultimately be the successful bidder for
supplying the Hemingway 80-MW and Black Mesa 40-MW BESS projects, that the
contract developed for the Distribution BESA could be leveraged.
Negotiation of the Hemingway 80-MW and Black Mesa 40-MW BESA began in
earnest in November 2021 after the Hemingway 80-MW and Black Mesa 40-MW BESS

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 34
projects were identified as the least-cost capacity resources to meet the 2023 need as
articulated in Case No. IPC-E-22-13. Confidential Attachment 2 – Response to Staff
Request No. 173 – BESA Negotiation includes e-mail correspondence between Idaho
Power and Powin during the contract negotiations leading up to an executed contract.
The communication included is chronologically ordered and primarily related to updated
quotes, contract negotiations, and the details associated with redline contract exchanges
and decisions on contractual terms between Idaho Power and Powin.
Confidential Attachment 3 – Response to Staff Request No. 173 – Hemingway
Change Orders provides additional contract related change orders since the execution of
the original BESA.
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 35
REQUEST FOR PRODUCTION NO. 174: Please provide the following
documentation for the Hemingway 80-MW four-hour duration BESS 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 winning bid.
d. Project construction documentation including
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 36
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 174:
In consultation with Staff, Idaho Power has requested an extension for this response
and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 37
REQUEST FOR PRODUCTION NO. 175: Please provide the following
documentation for the Black Mesa 40-MW four-hour duration BESS 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 winning bid.
d. Project construction documentation including
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 38
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.
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 175:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 39
REQUEST FOR PRODUCTION NO. 176: Please provide the results and all
supporting documentation for 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 176: See the Company’s
Response to Staff’s Request for Production No. 173 that provides information related to
Idaho Power’s parallel investigation into different configurations of Company-owned and
constructed BESS, ultimately leading to the competitive solicitation and contract
negotiations to acquire the Hemingway 80-MW and Black Mesa 40-MW BESS.
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 40
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 177:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 41
REQUEST FOR PRODUCTION NO. 178: Please explain and quantify the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 178:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 42
REQUEST FOR PRODUCTION NO. 179: Please provide the following
documentation 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;
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;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 43
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 179:
a. The Lower Salmon Falls hydro generating facility is made up of a number of
individual projects and work orders based on the work assigned to each generating unit.
The following project need is stated as follows and is included in Confidential Attachment
1 - Response to Staff Request No. 35:
i) BUDGET_ID LSPR140001 (Unit 1 and 3): The new turbines will gain an
expected 3-5 percent in efficiency and should reduce long-term maintenance
costs. The turbines will be specified for anticipated operating cycle and
increased unit operation flexibility. The Units 1 and 3 generators are listed as

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 44
Medium Concern according to the Company’s annual generator condition
assessment and testing program. Condition-based testing of the coils show
them to be deteriorated and in need of replacement. Component ages: coils –
40 years, core – 74 years, and turbine – 74 years. BUDGET_ID B00900276
(Unit 4): This project will increase turbine output and increase project efficiency.
First unit is planned to be Unit 4. Additionally, Unit 4 consistently requires
frequent repairs to the turbine and throat. This will minimize maintenance in this
unit for many years to come.
ii) BUDGET_ID LSPR160002 (Unit 2): This project will increase unit efficiency by
an expected 3-5 percent and should reduce long-term maintenance costs.
Increased generation is expected to qualify for tax credits and/or renewable
energy credits. Turbine will be specified for anticipated duty cycle and
increased unit operation flexibility. This generator is listed as Highest Concern.
Condition-based testing of the coils show them to be deteriorated and in need
of replacement. Component ages: coils – 32 years, core – 70 years, turbine –
70 years.
Additional information related to the need for the project can be found in Attachment 1 –
Response to Staff Request No. 179 – Project Need.
b. Project Plan: Attachment 2 – Response to Staff Request No. 179 – Scope
Documents includes information related to the planned scope. More information related
to each is addressed in additional responses to this request.
i. Scope:
1. LSPR140001 (Units 1 and 3): Replace both remaining fixed pitch turbines

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 45
and refurbish the mechanical components to gain a life extension of 30-50
years for these major assets. The generators will be refurbished with new
stator iron and coils and refurbished of rotor poles. Unit 3 will be completed
in December of 2023 and remaining work in 2024 is to close out the project.
2. BO0900276 (Unit 4): This project will replace the turbine in Unit 4 at Lower
Salmon Power Plant. This project will be complete in 2015, but the 2016
budget request is for project management documentation and final reporting
of the project.
3. LSPR160002 (Unit 2): This project will refurbish the Kaplan turbine and
mechanical components to gain a life extension of 50 years. The generator
will be refurbished with new stator iron and coils, and refurbishment of rotor
poles. Idaho Power is currently in contract with Voith for turbine and generator
materials and services.
ii. Proposed budget: The budget and actual costs can be found in Confidential
Attachment 1 - Response to Staff Request No. 35 as BUDGET_ID LSPR140001,
B00900276, and LSPR160002.
iii. Proposed schedule: The project was first identified in 2012, was constructed in
phases over 11 years and will be completed in 2023. Various phases have been
placed in-service as evidenced in Confidential Attachment 1 - Response to Staff
Request No. 35 as Work Order No. 27393657, 27414003, 27512733, 27512925.
c. RFP: Numerous competitive solicitations exist for this project for various material,
design and consulting services, and construction. Attachment 3 – Response to Staff
Request No. 179 – RFP Documents contains the RFP solicitations broken out by the

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 46
different components.
In addition to competitive bid events, Idaho Power purchases many minor and
ancillary materials and services in accordance with the Idaho Power Procurement Policy
and Procurement Standard, provided as Attachment 2 – Response to Staff’s Request No.
34. Many goods are stock items in Idaho Power warehouses and are not bid through an
RFP on a project basis, but rather as wholesale purchases.
d. Project Construction Documentation: Construction documentation including
contracts, scope, work breakdown, design documents and drawings, special conditions,
schedules, and other pertinent construction documentation can be found in Attachment 4
– Response to Staff Request No. 179 – Contracts.
e. Project Completion Analysis: Project completion includes closing contracts,
reconciling individual work orders to place property and plant in-service, and completing
and archiving project schedules. Generally, although no formal lessons learned are
documented, employees and leaders collaborate to discuss projects at completion and
determine potential process improvements and best practices based on the results of
each project. See Attachment 5 – Response to Staff Request No. 179 – LSPR Unit 4
Post Mortem for detailed information about lessons learned. Budget to actual
comparisons can be found in Confidential Attachment 1 - Response to Staff Request No.
35, as noted above. Baseline schedule comparisons to actual schedule delivery is not
compared due to the ever-changing landscape of the entire portfolio. Rather, projects
are managed in real-time, and schedules are constantly monitored in comparison to the
entire portfolio of projects to manage timeline and execution strategy, in conjunction with
all other capital project needs. Project schedules are updated at least monthly for

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 47
resource leaders to evaluate planned work across the matrixed organization. Variances
in budget forecasts are also constantly evaluated and monitored within the overall
portfolio of projects.
f. Project Approval: Idaho Power utilizes several approval processes throughout the
life cycle of a project. First, employees and leaders evaluate project requests and
establish a general conceptual level scope, estimate, and schedule incorporating
feedback from project sponsors, subject matter experts, and leadership. The project
requests are then evaluated amongst the many requests each year and ultimately
prioritized. Next, senior leaders evaluate the projects annually to approve or deny the
requests. Finally, the upcoming year’s annual budget is submitted to the Board of
Directors for approval in November. This process happens during the annual budgeting
cycle and, through iteration, the project is ultimately approved in the capital budget. Once
a project is approved, it is continuously managed and scrutinized for changes in scope,
budget, or schedule monthly. These approvals happen in real-time based on the overall
portfolio limits and are approved or denied. The changes, as appropriate, are documented
by revising the scope, design drawings, construction specifications, and other pertinent
documents and the budget and schedule are updated in the scheduling software related
to forward action items that overwrite previous plans. Refer to Attachment 2 – Response
to Staff Request No. 179 – Scope Documents for more information as it relates to the
LSF hydro project regarding project approvals.
g. Completion at Least-Cost: The information provided in the subsections of this
response along with adherence to the Idaho Power Procurement Policy and Procurement
Standard, provided as Attachment 2 – Response to Staff’s Request No. 34 support the

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 48
Company’s efforts to ensure the project was completed in a least-cost manner.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 49
REQUEST FOR PRODUCTION NO. 180: Please provide the following
documentation 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.
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;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 50
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 180:
a. The project need is stated as follows and is included in Confidential Attachment 1
- Response to Staff Request No. 35 as BUDGET_ID B00809249 and is applicable to the
Company’s Response to Request for Production Nos. 180, 181, 182, and 183, as this
response discusses all four Brownlee units. These units had significant erosion
associated with the turbines and wicket gates. Replacing the turbines increased
performance and addressed serious reliability concerns. Additionally, these new runners
provide the added ability to aerate the water to meet dissolved oxygen improvements
proposed in the new Hells Canyon Complex license. The Unit 3 generator failure in 2015

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 51
accelerated the rewind schedule of this unit.
Additional information related to the need for the project can be found in Attachment 1 –
Response to Staff Request No. 180 – Project Need and is applicable to the Company’s
Response to Request for Production Nos. 180, 181, 182, and 183.
b. Project Plan: Attachment 2 – Response to Staff Request No. 180 – Scope
Documents includes information related to the planned scope and is applicable to the
Company’s Response to Request for Production Nos. 180, 181, 182, and 183. More
information related to each is addressed in additional responses to this request.
i. Scope: This project consists of refurbishing the mechanical turbine parts,
including replacing the turbine runners for all of Units 1 through 4. The Company
has a contract for Voith Hydro to supply four new aerating turbine runners,
replace or refurbish many mechanical control components, and perform field
machining to repair cavitation damaged embedded parts to like-new. The first
unit went into service in 2016, the second in 2017, the third in 2018, and the
fourth scheduled for 2019. Unit 3 received new generator stator coils and core
laminations in 2017. Unit 1 will receive a blade trailing edge modification in 2019
to improve aeration with Voith's new design. This response is applicable to the
Company’s Response to Request for Production Nos. 180, 181, 182, and 183.
Additional scope documents for Brownlee Unit 1 are included in Attachment 3 –
Response to Staff Request No. 180 – Brownlee Unit 1 Scope.
ii. Proposed budget: The budget and actual costs can be found in Confidential
Attachment 1 - Response to Staff Request No. 35 as BUDGET_ID B00809249.
iii. Proposed schedule: The project was first identified in 2012, was constructed in

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 52
phases over eight years and was completed in 2020 as evidenced in Confidential
Attachment 1 - Response to Staff Request No. 35 as BUDGET_ID B00809249.
Brownlee Unit 1 was completed and placed in-service on 2016-08-19.
c. RFP: Numerous competitive solicitations exist for this project for various
material, design and consulting services, and construction. Attachment 4 – Response to
Staff Request No. 180 – RFP Documents contains the RFP solicitations broken out by
the different components and are applicable to the Company’s Response to Request for
Production Nos. 180, 181, 182, and 183. Attachment 5 – Response to Staff Request No.
180 – Brownlee Unit 1 RFP has additional RFP solicitation documents applicable to
Brownlee Unit 1.
In addition to competitive bid events, Idaho Power purchases many minor and
ancillary materials and services in accordance with the Idaho Power Procurement Policy
and Procurement Standard, provided as Attachment 2 – Response to Staff’s Request No.
34. Many goods are stock items in Idaho Power warehouses and are not bid through an
RFP on a project basis, but rather as wholesale purchases.
d. Project Construction Documentation: Construction documentation including
contracts, scope, work breakdown, design documents and drawings, special conditions,
schedules, and other pertinent construction documentation can be found in the following
Attachment 6 – Response to Staff Request No. 180 – Contract Documents and are
applicable to the Company’s Response to Request for Production Nos. 180, 181, 182,
and 183. Attachment 7 – Response to Staff Request No. 180 – Contract Documents has
additional RFP solicitation documents applicable to Brownlee Unit 1.
e. Project Completion Analysis: Project completion includes closing contracts,

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 53
reconciling individual work orders to place property and plant in-service, and completing
and archiving project schedules. Generally, although no formal lessons learned are
documented, employees and leaders collaborate to discuss projects at completion and
determine potential process improvements and best practices based on the results of
each project. Budget to actual comparisons can be found in Confidential Attachment 1 -
Response to Staff Request No. 35 as noted above. Baseline schedule comparisons to
actual schedule delivery is not compared due to the ever-changing landscape of the entire
portfolio. Rather, projects are managed in real-time, and schedules are constantly
monitored in comparison to the entire portfolio of projects to manage timeline and
execution strategy in conjunction with all other capital project needs. Project schedules
are updated at least monthly for resource leaders to evaluate planned work across the
matrixed organization. Variances in budget forecasts are also constantly evaluated and
monitored within the overall portfolio of projects.
f. Project Approval: Idaho Power utilizes several approval processes throughout the
life cycle of a project. First, employees and leaders evaluate project requests and
establish a general conceptual level scope, estimate, and schedule incorporating
feedback from project sponsors, subject matter experts, and leadership. The project
requests are then evaluated amongst the many requests each year and ultimately
prioritized. Next, senior leaders evaluate the projects annually to approve or deny the
requests. Finally, the upcoming year’s annual budget is submitted to the Board of
Directors for approval in November. This process happens during the annual budgeting
cycle and, through iteration, the project is ultimately approved in the capital budget. Once
a project is approved, it is continuously managed and scrutinized for changes in scope,

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 54
budget, or schedule monthly. These approvals happen in real-time based on the overall
portfolio limits and are approved or denied. The changes, as appropriate, are documented
by revising the scope, design drawings, construction specifications, and other pertinent
documents and the budget and schedule are updated in the scheduling software related
to forward action items that overwrite previous plans. Refer to attachments identified in
this Response to Staff Request No. 180 for more information as it relates to Brownlee
Unit 1 regarding project approvals.
g. Completion at Least-Cost: The information provided in the subsections of this
response along with adherence to the Idaho Power Procurement Policy and Procurement
Standard, provided as Attachment 2 – Response to Staff’s Request No. 34, support the
Company’s efforts to ensure the project was completed in a least-cost manner.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 55
REQUEST FOR PRODUCTION NO. 181 Please provide the following
documentation 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 winning bid.
d. Project construction documentation including
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 56
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 181:
a. See part (a) to the Company’s Response to Request for Production No. 180.
Additionally, see Attachment 1 – Response to Staff Request No. 181 – Project Need.
b. Project Plan: See part (b) to the Company’s Response to Request for Production
No. 180.
i. Proposed schedule: Brownlee Unit 2 was completed and placed in-service on
2020-02-12.
c. RFP: See part (c) to the Company’s Response to Request for Production No. 180.
Attachment 2 – Response to Staff Request No. 181 – RFP Documents has additional

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 57
RFP solicitation documents applicable to Brownlee Unit 2.
In addition to competitive bid events, Idaho Power purchases many minor and ancillary
materials and services in accordance with the Idaho Power Procurement Policy and
Procurement Standard, provided as Attachment 2 – Response to Staff’s Request No. 34.
Many goods are stock items in Idaho Power warehouses and are not bid through an RFP
on a project basis, but rather as wholesale purchases.
d. Project Construction Documentation: See part (d) to the Company’s Response to
Request for Production No. 180. Attachment 3 – Response to Staff Request No. 181 –
Contract Documents has additional RFP solicitation documents applicable to Brownlee
Unit 2.
e. Project Completion Analysis: See part (e) to the Company’s Response to Request
for Production No. 180.
f. Project Approval: See part (f) to the Company’s Response to Request for
Production No. 180. Refer to attachments identified in this Response to Staff Request
No. 181 for more information as it relates to Brownlee Unit 2 regarding project approvals.
g. Completion at Least-Cost: The information provided in the subsections of this
response along with adherence to the Idaho Power Procurement Policy and Procurement
Standard, provided as Attachment 2 – Response to Staff’s Request No. 34, support the
Company’s efforts to ensure the project was completed in a least-cost manner.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 58
REQUEST FOR PRODUCTION NO. 182: Please provide the following
documentation 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 winning bid.
d. Project construction documentation including
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 59
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 182:
a. See part (a) to the Company’s Response to Request for Production No. 180.
b. Project Plan: See part (b) to the Company’s Response to Request for Production
No. 180.
i. Proposed schedule: Brownlee Unit 3 was completed and placed in-service on
2017-10-24.
c. RFP: See part (c) to the Company’s Response to Request for Production No. 180.
Attachment 1 – Response to Staff Request No. 182 – RFP Documents has additional
RFP solicitation documents applicable to Brownlee Unit 3.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 60
In addition to competitive bid events, Idaho Power purchases many minor and ancillary
materials and services in accordance with the Idaho Power Procurement Policy and
Procurement Standard, provided as Attachment 2 – Response to Staff’s Request No. 34.
Many goods are stock items in Idaho Power warehouses and are not bid through an RFP
on a project basis, but rather as wholesale purchases.
d. Project Construction Documentation: See part (d) to the Company’s Response to
Request for Production No. 180. Attachment 2 – Response to Staff Request No. 182 –
Contract Documents has additional RFP solicitation documents applicable to Brownlee
Unit 3.
e. Project Completion Analysis: See part (e) to the Company’s Response to Request
for Production No. 180.
f. Project Approval: See part (f) to the Company’s Response to Request for
Production No. 180. Refer to attachments identified in this Response to Staff Request
No. 182 for more information as it relates to Brownlee Unit 3 regarding project approvals.
g. Completion at Least-Cost: The information provided in the subsections of this
response along with adherence to the Idaho Power Procurement Policy and Procurement
Standard, provided as Attachment 2 – Response to Staff’s Request No. 34, support the
Company’s efforts to ensure the project was completed in a least-cost manner.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 61
REQUEST FOR PRODUCTION NO. 183: Please provide the following
documentation 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 winning bid.
d. Project construction documentation including
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 62
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 183:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 63
REQUEST FOR PRODUCTION NO. 184: Please provide the following
documentation 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 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;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 64
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 184:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 65
REQUEST FOR PRODUCTION NO. 185: Please provide the following
documentation 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 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;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 66
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 185:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 67
REQUEST FOR PRODUCTION NO. 186: Please provide the following
documentation 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 winning bid.
d. Project construction documentation including
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 68
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 186:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 69
REQUEST FOR PRODUCTION NO. 187: Please provide the following
documentation for the work on the Midpoint-to-Borah345-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 winning bid.
d. Project construction documentation including
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 70
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 187:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 71
REQUEST FOR PRODUCTION NO. 188: Please provide the following
documentation for the multi-year underground cable 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 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);

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 72
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 188:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 73
REQUEST FOR PRODUCTION NO. 189: Please provide explanations for
Company "2022 Actual Adjustments (column E)," "Forecast Adjustments (column H)," or
"Annualizing Adjustment" (column K) in Exhibit 34 for the following accounts. Please
include calculations of adjustments in Excel Format with formulas intact.
a. Other (Line 444)- Please justify the 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";
c. Overhead Lines (Line 522)- Please justify the increase of 35% for the "2022
Actual Adjustment";
d. Overhead Lines (Line 553)- Please justify the increase of 58% for the "2022
Actual Adjustment";
e. Uncollectible Accounts (Line 566)- Please justify the increase of 77% for the
"Forecast Adjustment";
f. Injuries and Damages (Line 590)- Please justify the increase of 81% for the "2022
Actual Adjustments"; and
g. Employee Pensions & Benefits- Idaho (Line 593)- Please justify the increase of
105% for the "Forecast Adjustment".
RESPONSE TO REQUEST FOR PRODUCTION NO. 189:
a) On Line 444, the “Forecast Adjustment” of $180,701 is comprised of $17,513
related to the Fleet Adjustment described on Page 7 of Exhibit No. 26 to Matt
Larkin’s testimony. The additional $163,188 of “Forecast Adjustment” should have
been presented on Line 443 and is related to the Labor O&M adjustment
described on Page 5 of Exhibit No. 26 to Matt Larkin’s Testimony.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 74
b) To clarify, the “Forecast Adjustment” on Line 484 is a decrease of $3,372,657
primarily associated with the Langley and Bennett Mountain Plant Maintenance
described on Page 7 of Exhibit No. 26 to Matt Larkin’s Testimony. The $29,364
“Annualizing Adjustment” increase is an annualizing labor adjustment.
c) The “2022 Actual Adjustment” of $805,534 presented on Line 522 is related to the
2022 O&M adjustment for the Wildfire Mitigation Program (“WMP”), presented in
Table 3, Account 571.000, Page 15, of Paula Jeppsen’s Testimony.
d) Of the $12,695,311 “2022 Actual Adjustment” presented on Line 553,
$12,702,312 is related to the 2022 O&M adjustment for the WMP, presented in
Table 3, Account 593.000, Page 15 of Paula Jeppsen’s Testimony. Included in
the $12,695,311 “2022 Actual Adjustment”, is a decrease of $7,000 for
contributions as presented on Page 2, Line 12 of Exhibit No. 23 to Paula
Jeppsen’s Testimony.
e) The “Forecast Adjustment” of $2,514,638 presented on Line 566 is related to the
Uncollectible/Bad-Debt Expense adjustment to O&M described on Page 8 of
Exhibit No. 26 to Matt Larkin’s Testimony.
f) The “2022 Actual Adjustment” of $5,309,456 presented on Line 590 is related to
the 2022 O&M adjustment for the WMP, presented in Table 3, Account 925.000,
Page 15 of Paula Jeppsen’s Testimony.
g) The “Forecast Adjustment” of $18,028,665 presented on Line 593 is related to
Accounts 926.204 – Pension Expense described on Page 9 of Exhibit No. 26 to
Matt Larkin’s Testimony.
The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 75
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 76
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 190: There are no barista
services included in the current rate case request, as the part-time barista position was
added in April 2023. The current coffee service is structured to be employee funded, not
employer funded, with coffee revenues intended to cover the cost of the barista and
supplies. Please see “Attachment – Response to Staff Request No. 190” for cafeteria and
barista services spend from 2018 through June 2023. All Company subsidized cafeteria
services were discontinued in 2020.
The response to this Request is sponsored by Debra Leithauser, Vice President,
Corporate Services and Communications, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 77
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 191:
Please see the table below, which outlines the location, date and associated cost
of each safety summit hosted or attended by Company personnel. Additionally, the
attachment provided in response to this request contains examples of the materials
presented during or included as part of these safety summits. The Company’s safety
summits are designed to promote safety best practices, incorporate changed standards,
share knowledge, and enhance safety measures within organizations or business units.
Safety Summits Hosted or Attended, 2018–2023:

Summit Name Location Event Date Cost
Idaho Utility Safety Summit Twin Falls May 15, 2019 $7,928.04
Frontline Leader Safety
Summit (field employees)
Boise Nov. 7, 2019 $5,605.70
Frontline Leader Safety
Summit (office employees)
Boise Nov. 15, 2019 $4,399.71
Contractor Safety Summit Boise May 24, 2022 $2,392.67
Contractor Safety Summit Boise June 7, 2022 $244.90
(coffee service only)
Internal Leader Safety
Summits (6 summits)
Varied June–Sept. 2022 $4,083.12

Safety is a crucial aspect of the Company’s operations and, as such, the
Company believes its involvement in safety summits, which may resemble workforce
training for specific positions, contributes to the Company’s fulfillment of the
Commission’s expectation of providing safe and reliable service to customers.
Furthermore, the Company’s involvement in safety summits also benefits customers by

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 78
aiming to decrease the occurrence and cost of potential lost time injuries; such injuries
can affect the availability of labor necessary to complete construction and maintenance
work, thereby possibly delaying customers’ receipt or restoration of service, all of which
may impact customers’ overall satisfaction with the Company.
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 79
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 192:
In consultation with Staff, Idaho Power has requested an extension for this
response and will deliver it on, or before, August 25, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 80
REQUEST FOR PRODUCTION NO. 193: Please provide Company's Idaho and
Oregon Income Tax Returns for 2021 and 2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 193:
The 2021 Idaho Income Tax Return is provided as Confidential Attachment 1 –
Response to Staff Request No. 193. The 2021 Oregon Income Tax Return is provided
as Confidential Attachment 2 – Response to Staff Request No. 193. The returns are
combined filings of the IDACORP consolidated group. The 2022 Idaho and Oregon
Income Tax Returns are in the process of being prepared and will not be finalized until
the filing deadline of October 15, 2023.
The response to this Request is sponsored by Gene Marchioro, Corporate Tax
Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 81
REQUEST FOR PRODUCTION NO. 194: Please provide the monthly
uncollectible write-off expenses in years 2018-2023. Please separate this information into
Oregon and Idaho customers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 194:
Please see Excel file “Attachment 1 – Response to Staff Request No. 194”. The
amounts in the file are monthly write-off expenses, including current month write-offs
reduced by amounts recovered on previously written-off amounts.
Idaho Power is also providing the monthly change in the reserve for uncollectible
accounts and the monthly reserve for uncollectible accounts balance.
The response to this Request is sponsored by Paula Jeppsen, Forecast and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 82
REQUEST FOR PRODUCTION NO. 195: Please explain
according to Company Confidential
Attachment No. 5 in Response to Production Request No. 1.
RESPONSE TO REQUEST FOR PRODUCTION NO. 195:
Please see Excel file “Attachment – Response to Staff Request No. 195”, which
explains the change from November 2022 to December 2022 in Account 904001 -
Reserve for Uncollectible Accounts.
The response to this Request is sponsored by Paula Jeppsen, Forecast and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 83
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 196:
Please see Excel file “Attachment – Response to Staff Request No. 196” for the
requested information.
The response to this Request is sponsored by Sarah Griffin, Vice President Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 84
DATED at Boise, Idaho, this 21st day of August 2023.

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 85
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 21st day of August 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Confidential Seventh
Production Request of the Commission Staff to Idaho Power Company upon the following
named parties by the method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703

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Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

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IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 86
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 87
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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IDAHO POWER COMPANY’S RESPONSE TO THE CONFIDENTIAL SEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 88
Federal Executive Agencies
Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Walmart, Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702

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Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716

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Christy Davenport
Legal Administrative Assistant