20230922IPC to Staff Supplemental 244.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 22, 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 Supplemental
Response to the Eleventh 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
attachments 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,
Lisa D. Nordstrom
LDN:cd
Enclosures
RECEIVED
Friday, September 22, 2023 3:34:38 PM
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 some of the attachments in Response to Request No. 244 to Idaho Power
Company’s Supplemental Response to the Eleventh Production Request of the
Commission Staff dated September 22, 2023, contain information that Idaho Power
Company and a third party claims is a confidential trade secret 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 22nd day of September, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH 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.
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)
)
)
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)
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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
SUPPLEMENTAL RESPONSE TO
THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER
COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Eleventh Production Request of the Commission Staff (“Commission” or
“Staff”) dated August 16, 2023, herewith supplements the following information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2

STAFF REQUEST FOR PRODUCTION NO. 244: Please provide the following
information regarding the Field Area Network ("FAN") and replacement of an Automated
Capacitor Control ("ACC") system with the development of a new integrated volt-var
control ("IVVC") system, mentioned in Colburn Direct at 17. If any of the information
requested below cannot be provided or is not available, please explain why. Please also
explain how the Company can ensure the construction of the project was completed at
least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
b. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
c. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3

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 manner to its customers.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 244: Following discussions with Commission Staff on September 13, 2023, Idaho
Power identified additional documentation that supports the expenditures associated with
the substation and distribution system upgrades and additions portion of this project
(Budget ID: VARI170005). There are two components of the hardware portion of the
project: (1) the 700 MHz FAN radio and (2) the capacitor controls. The following
summarizes the documentation for both:
 Included as Supplemental Attachment 1 –Response to Staff Request No.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4

244 includes the RFP associated with the 700 MHz FAN radio and the bid
evaluation results supporting the selection of 4RF based on better
performance, experience with the licensed spectrum, and the availability of
the radios. Supplemental Attachment 2 –Response to Staff Request No.
244 includes the Purchase Agreement with 4RF and supporting exhibits for
the 700 MHz FAN radios.
 Supplemental Attachment 3 –Response to Staff Request No. 244 includes
the Request for Quotes (“RFQ”) associated with the capacitor controls as
well as the RFQ technical evaluation results and pricing evaluation. There
is no specific contract with Eaton for the capacitor controls rather the quote
provided through the RFQ was a firm fixed price for a period of 3 years and
the subsequent purchase of capacitor controls was done through the
purchase order process. Eaton was, however, subject to Idaho Power’s
General Terms and Conditions for Goods and Services throughout the life
of the project, which are included as Supplemental Attachment 4 –
Response to Staff Request No. 244. Confidential Supplemental Attachment
5 – Response to Staff Request No. 244 presents the purchase order
information beginning in 2017 through completion of the project in 2022,
including the firm price through June 2021. Note, following the first purchase
of capacitor controls, Idaho Power made changes to the control package to
aid with field installation and security including an inhibit switch, N-type hole
for a Laird Antenna in the bottom of the enclosure, dimples for a security
sleeve hole location and a security sleeve which increased the price of the

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5

capacitor controls during the three-year period.
Further, in the Company’s Response to Request for Production No. 244, Idaho
Power provided the RFP results for the software purchase and installation portion of the
project but did not provide the RFP evaluation results and has included them as
Confidential Supplemental Attachment 6 – Response to Staff Request No. 244. Open
Systems International, Inc. (“OSI”) was selected following a thorough evaluation of the
RFP scoring results, the strengths and limitations of each vendor, and the vendor’s overall
ability to meet the Company’s needs from both a software and services perspective. Idaho
Power determined the purchase of an off-the-shelf product that provided a full Distribution
Management System (“DMS”) was required to maintain customer expectations of a safe,
reliable and affordable distribution system. A DMS provides a foundation for the current
and future operation of the distribution system, operational awareness and control given
load growth and expanded distributed generation. The IVVC system was the first module
of the software suite implemented.
Two respondents to the RFP did not provide a full DMS suite of products and
therefore did not meet the minimum requirements of the project. The two final vendors
both provided the full suite of DMS products. Ultimately, OSI was selected for a variety of
reasons including the following:
1) Consistently scoring higher in the evaluation.
2) Providing a full suite of software developed and supported exclusively in the United
States which is critical from a support and cyber security perspective for an
operational system such as IVVC.
3) The software is developed entirely by OSI and the primary focus of the company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 6

4) They provided multiple modes of operation for the IVVC which allowed a
streamlined, phased implementation. Idaho Power was able to implement a full
IVVC system that met the Company’s system requirements without building a full
DMS model with OSI, significantly reducing the total project implementation time
and cost of the overall project. No other vendor provided this option.
5) Lower on-going software maintenance cost.
6) A modern, configurable user interface that is much more user friendly and easier
to implement.
7) While the best and final offer for the software and implementation costs were
slightly higher, OSI provided a product that better aligned with the Company’s
current and future operational needs. The bulk of OSI’s cost was for software
licenses while the alternative would have required more professional services to
implement and likely customize the software to meet Idaho Power’s requirements.
As described to Staff during discussions on September 8, 2023, the costs
associated with the selection of OSI to implement the IVVC software were not the only
costs associated with the software portion of the project. OSI provided the software and
contracted services to configure, install and aid in testing of the software but nearly half
of the project costs were associated with internal Idaho Power labor necessary to install
and configure IT hardware (e.g. servers, firewalls) to run the software. In addition,
extensive testing and commissioning activities were performed by both OSI and Company
personnel. The following chart breaks out the software component of the project costs by
category, identifying the internal labor costs associated with the project:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7

CHQB180013
IVVC Project Costs
Labor $2,281,218
Materials 1,951,439
Purchased Services 711,758
Other Expenses 750,375
AFUDC 126,315
Total $5,821,105

The response to this Request is sponsored by Mitch Colburn, Vice President
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 8

DATED at Boise, Idaho, this 22nd 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 SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 22nd day of September 2023, I served a true and
correct copy of Idaho Power Company’s Supplemental Response to the Eleventh
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 SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 10
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 SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 11
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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Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE ELEVENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 12
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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Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
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Christy Davenport
Legal Administrative Assistant