HomeMy WebLinkAbout20230908IPC to Staff Supplemental 169_170_173.pdf
MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallen@idahopower.com
September 8, 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 Second
Supplemental Response to the Confidential Seventh Production Request of the
Commission Staff to Idaho Power Company.
Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the attachment
to these requests to the secure FTP site to allow parties to view the requested information
remotely unless otherwise noted in the response. Because certain attachments contain
confidential information, the FTP site is divided between confidential and non-confidential
information.
The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided the parties that have executed the
Protective Agreement in this matter.
If you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
Megan Goicoechea Allen
MGA:sg
Enclosure
RECEIVED
2023 SEPTEMBER 8, 2023 4:18PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 the Attachments provided in Response to Request Nos. 170 and 173, as
included in Idaho Power Company’s Second Supplemental Response to the Seventh
Production Request of the Commission Staff dated September 8, 2023, contain
information that Idaho Power Company and a third party claim are trade secrets, and/or
business records of a private enterprise required 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, they are protected from public disclosure and exempt from public
inspection, examination, or copying.
DATED this 8th day of September, 2023.
Megan Goicoechea Allen
Counsel for Idaho Power Company
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL 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: (208) 388-5825
Facsimile: (208) 388-6936
lnordstrom@idahopower.com
dwalker@idahopower.com
mgoicoecheaallen@idahopower.com
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.
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CASE NO. IPC-E-23-11
IDAHO POWER COMPANY’S
SECOND SUPPLEMENTAL
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 supplements the following
information:
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
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.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 169: Included as Attachment – Second Supplemental Response to Staff’s Request
No. 169 is an updated Exhibit No. 2 to the direct testimony of Lindsay Barretto that was
initially expanded to present the additional information requested and provided in the
Company’s Response to Staff’s Request Nos. 169 and 170.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
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 SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
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.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 170: Attachment – Second Supplemental Response to Staff Request No. 169
includes an updated copy of Exhibit No. 2 with the information to support the
documentation provided in response to this request, including Confidential Attachment 7-
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
8 – Response to Staff Request No. 170, the Engineering, Procurement, and Construction
Contract associated with Project No. 7.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
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.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 173: As described in the Company’s Response to Request for Production No. 173,
Idaho Power began a competitive solicitation for battery energy storage systems in July
2021, sending a request for quotes (“RFQ”) to eight different battery manufacturers. In
the response, the Company erroneously stated “[t]he indicative pricing received from
these 16 suppliers, including Powin, was comparative to the lowest-cost proposals for 17
similar battery projects submitted through the RFP process (emphasis added).” The
sentence should have read: “[t]he indicative pricing received from these suppliers,
including Powin, was comparative to the lowest-cost proposals for similar battery projects
submitted through the RFP process.”
Further, in the Company’s Response to Request for Production No. 173, Idaho
Power provided the RFQ bid responses but did not provide the RFQ evaluation results
and has included them as Confidential Supplemental Attachment 1 – Response to Staff’s
Request No. 173. The competitive solicitation for battery energy storage systems began
in July 2021 and subsequently Idaho Power offered respondents the opportunity to
update their bids to include the additional costs associated with the United States customs
tariff increases, which are reflected in the RFQ evaluation results. Note, two of the
respondents were not evaluated as their prices were significantly higher than the rest of
the respondents.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.
DATED at Boise, Idaho, this 8th day of September 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 SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Second Supplemental 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
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email Dayn.Hardie@puc.idaho.gov
Chris.Burdin@puc.idaho.gov
Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email Kelsey@kelseyjae.com
Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
courtney@cleanenergyopportunities.com
mike@cleanenergyopportunities.com
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
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FAX
FTP Site
X Email peter@richardsonadams.com
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616
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FAX
FTP Site
X Email dreading@mindspring.com
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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X Email elo@echohawk.com
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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X Email lance@aegisinsight.com
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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X Email darueschhoff@hollandhart.com
tnelson@hollandhart.com
awjensen@hollandhart.com
aclee@hollandhart.com
clmoser@hollandhart.com
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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X Email jswier@micron.com
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 10
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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X Email ejewell@cityofboise.org
dearly@cityofboise.org
boca@cityofboise.org
Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
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X Email wgehl@cityofboise.org
Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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X Email mkellner@idahoconservation.org
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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bheusinkveld@idahoconservation.org
IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701
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X Email tom.arkoosh@arkoosh.com
erin.cecil@arkoosh.com
Federal Executive Agencies
Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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X Email peter.meier@hq.doe.gov
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE CONFIDENTIAL
SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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X Email detheridge@exeterassociates.com
NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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X Email diego@nwenergy.org
Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
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X Email NSemanko@parsonsbehle.com
Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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X Email Stephen.Chriss@walmart.com
Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
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X Email jcaviglia@parsonsbehle.com
Stacy Gust, Regulatory Administrative
Assistant