20230928IPC to Staff 283-290.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
September 28, 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 Eighteenth 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 to 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:sg
Enclosures
RECEIVED
2023 SEPTEMBER 28, 2023 4:53PM
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 Nos. 283, 284, 285, 286,
287, 288, 289, and 290, to Idaho Power Company’s Supplemental Response to the
Eighteenth Production Request of the Commission Staff dated September 28, 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 28th day of September, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH 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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CASE NO. IPC-E-23-11
IDAHO POWER COMPANY’S
SUPPLEMENTAL RESPONSE TO
THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Eighteenth Production Request of the Commission Staff (“Commission”
or “Staff”) dated September 7, 2023, herewith supplements the following information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 283: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
RELC220001 - Line Relocations for ITD Extension of SH-16 from Chinden (SH-20/26) to
I-84, is significantly over the total budget amount. Please provide the following
information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 283:
a-b. Please see Attachment 1 – Supplemental Response to Staff Request No. 283.
The first tab, titled DRs 283 – 290 Budget vs Actuals, presents a year-by-year
budget to actuals comparison for each of the projects identified in Staff’s Request
for Production Nos. 283 through 290. The second tab, titled DRs 283 – 290 Budget
Update, presents the budget updates that revised each of the original budget
amounts presented in the first tab for the projects identified in Staff’s Request for
Production Nos. 283 through 290. Each subsequent tab presents the individual
projects identified in Staff’s Request for Production Nos. 283 through 290 for which
the budget-to-actuals comparison was requested and includes a detailed
explanation of the reason for the variances.
c. See the tab titled RELC220001 of the Attachment 1 – Supplemental Response to
Staff Request No. 283 for the detailed explanation of the variances between

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
budget and actuals. In addition, Attachment 2 – Supplemental Response to Staff
Request No. 283 includes additional project notes from Idaho Power’s capital
projects budgeting and tracking tools including the project pre-authorization notes,
the project description, need, and consequence notes, and Microsoft Project
Schedule notes that support changes to the budget as reflected in the Budget
Updates. Confidential Attachment 3 – Supplemental Response to Staff Request
No. 283 provides a screenshot from the Company’s Customer Load & Research
Information System (“CLRIS”) reflecting the initial pre-authorization request.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 284: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
ELDRl90001 - ELDR Construct two new 12.5-kV feeder ELDR-012 and ELDR-013, is
significantly over the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 284:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled ELDRl90001 of Attachment 1 – Supplemental Response to Staff
Request No. 283 for the detailed explanation of the variances between budget and
actuals. In addition, Attachment 1 – Supplemental Response to Staff Request No.
284 includes additional project notes from Idaho Power’s capital projects budgeting
and tracking tools including the project pre-authorization notes, the project
description, need, and consequence notes, and Microsoft Project Schedule notes
that support changes to the budget as reflected in the Budget Updates.
Confidential Attachment 2 – Supplemental Response to Staff Request No. 284
provides a screenshot from CLRIS reflecting the initial pre-authorization request.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 285: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T423120001 - T423 Ontario-Quartz 138kV Line - FAC008 Compliance, is significantly
over the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 285:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled T423120001 of Attachment 1 – Supplemental Response to Staff
Request No. 283 for the detailed explanation of the variances between budget and
actuals. In addition, Attachment 1 – Supplemental Response to Staff Request No.
285 includes additional project notes from Idaho Power’s capital projects budgeting
and tracking tools including the project pre-authorization notes, the project
description, need, and consequence notes, and Microsoft Project Schedule notes
that support changes to the budget as reflected in the Budget Updates.
Confidential Attachment 2 – Supplemental Response to Staff Request No. 285
provides a screenshot from CLRIS reflecting the initial pre-authorization request.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 286: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T216150001 - T216 Rebuild 69-kV Line T216 from Brownlee to Halfway- approx. ten
miles, is significantly over the total budget amount. Please provide the following
information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 286:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled T216150001 of Attachment 1 – Supplemental Response to Staff
Request No. 283 for the detailed explanation of the variances between budget and
actuals. In addition, Attachment 1 – Supplemental Response to Staff Request No.
286 includes additional project notes from Idaho Power’s capital projects budgeting
and tracking tools including the project pre-authorization notes, the project
description, need, and consequence notes, and Microsoft Project Schedule notes
that support changes to the budget as reflected in the Budget Updates.
Confidential Attachment 2 – Supplemental Response to Staff Request No. 286
provides a screenshot from CLRIS reflecting the initial pre-authorization request.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 287: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T4040401 - T404 ZLOG-CADA Build/rebuild to 138-kV from ZLOG to new CADA
substation, is significantly over the total budget amount. Please provide the following
information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 287:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 283.
d. See the tab titled T4040401 of Attachment 1 – Supplemental Response to Staff
Request No. 283 for the detailed explanation of the variances between budget and
actuals. In addition, Attachment 1 – Supplemental Response to Staff Request No.
287 includes additional project notes from Idaho Power’s capital projects budgeting
and tracking tools including the project pre-authorization notes, the project
description, need, and consequence notes, and Microsoft Project Schedule notes
that support changes to the budget as reflected in the Budget Updates.
Confidential Attachments 2 and 3 – Supplemental Response to Staff Request No.
287 provide screenshots from CLRIS reflecting the initial pre-authorization request
and the updated solution request.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 8
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 288: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T4791101 - T479 BOMT-HPVY Build 138 kV line, is significantly over the total budget
amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 288:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled T4791101 of Attachment 1 – Supplemental Response to Staff
Request No. 283 for the detailed explanation of the variances between budget and
actuals. In addition, Attachment 1 – Supplemental Response to Staff Request No.
288 includes additional project notes from Idaho Power’s capital projects budgeting
and tracking tools including the project pre-authorization notes, the project
description, need, and consequence notes, and Microsoft Project Schedule notes
that support changes to the budget as reflected in the Budget Updates.
Confidential Attachments 2 and 3 – Supplemental Response to Staff Request No.
288 provide screenshots from CLRIS reflecting the initial pre-authorization request
and the updated solution request.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 289: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
NEWX170001 - NEWX - Reconstruct 138-kV CDAL-HBRD T438 line to add a 230-kV
circuit and double circuit distribution underbuild, is significantly over the total budget
amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 289:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled NEWX170001 of Attachment 1 – Supplemental Response to
Staff Request No. 283 for the detailed explanation of the variances between
budget and actuals. In addition, Attachment 1 – Supplemental Response to Staff
Request No. 289 includes additional project notes from Idaho Power’s capital
projects budgeting and tracking tools including the project pre-authorization notes,
the project description, need, and consequence notes, and Microsoft Project
Schedule notes that support changes to the budget as reflected in the Budget
Updates. Confidential Attachments 2 and 3 – Supplemental Response to Staff
Request No. 289 provide screenshots from CLRIS reflecting the initial pre-
authorization request and the updated solution request.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 11
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 290: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
ELDRl80002 - ELDR New distribution station in central Pocatello, is significantly over the
total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 290:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled ELDRl80002 of Attachment 1 – Supplemental Response to Staff
Request No. 283 for the detailed explanation of the variances between budget and
actuals. In addition, Attachment 1 – Supplemental Response to Staff Request No.
290 includes additional project notes from Idaho Power’s capital projects budgeting
and tracking tools including the project pre-authorization notes, the project
description, need, and consequence notes, and Microsoft Project Schedule notes
that support changes to the budget as reflected in the Budget Updates.
Confidential Attachments 2 through 4 – Supplemental Response to Staff Request
No. 290 provide screenshots from CLRIS reflecting the initial pre-authorization
request and the updated solution requests.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 13
DATED at Boise, Idaho, this 28th 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 EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Supplemental Response to the Eighteenth
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 [e-mail]
[e-mail]
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 [e-mail]
Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
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[e-mail]
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
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X Email [e-mail]

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 15
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 EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 16
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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[e-mail]

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.
Washin ton, DC 20585
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IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 17
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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Stacy Gust Regulatory Administrative
Assistant