20230928IPC to Staff 298-299.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 Response to the
Nineteenth 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
Thursday, September 28, 2023 2:41:50 PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE NINETEENTH 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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CASE NO. IPC-E-23-11
IDAHO POWER COMPANY’S
RESPONSE TO THE NINETEENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Nineteenth Production Request of the Commission Staff (“Commission”
or “Staff”) dated September 8, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 298: Please provide necessary information
related to the two-year Underground Cable Replacement Pilot Program as referenced in
" Confidential Attachment 1 - Response to Staff Request No. 188 - Project Need." The
information should include but not limited to the following:
a.All pertinent data, workpapers, analysis, and any supporting documentation that
the Company used to justify its decision to extend their two-year Pilot Program into
a 40-year replacement implementation starting from 2015; and
b.A comparison of the reliability issues faced by the Company before and after the
Pilot Program. The comparison may include any information related to reduction
of the number of faults, outages, etc. that justifies the extension of the Program.
RESPONSE TO REQUEST FOR PRODUCTION NO. 298:
a.As described in the Company’s Response to Request for Production No. 188, the
replacement of the direct-buried cables with unjacketed, concentric neutrals is to
reduce the risk of faults and outages. The intent of the two-year Underground
Cable Replacement Pilot Program was not to determine whether the replacement
of underground cable would continue after the two years but rather to analyze the
feasibility of underground cable replacement by evaluating three different methods
of construction to perform this work: utilizing contract crews, performing the work
with an internal Idaho Power crew, and utilizing a combination of both contractors
and Idaho Power crews. Due to the volume and geographical location of the
projects using both an Idaho Power crew and contract crews was determined to
be the most cost-effective method for performing this work and the long-term plan
to continue was approved through the Company’s annual budgeting and project

IDAHO POWER COMPANY’S RESPONSE TO THE NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
approval processes. Further see part (f) to the Company's Response to Request
for Production No. 184 that addresses how approved projects are continuously
managed and scrutinized for changes and, if appropriate, are approved through
these processes. Also see Confidential Attachment 2 - Response to Staff Request
No. 243 for a description of the transition into the cable replacement program.
b. The decision to extend the Underground Cable Replacement Program was based
upon the anticipated design life of the direct-buried cables with unjacketed,
concentric neutrals. The intent was, and remains, to replace this cable before it
fails based on industry data and knowledge of cable life expectancy. See
Attachment 1 – Response to Staff Request No. 188 that contains a Powerpoint
titled Underground Cable Presentation (Final) that addresses the industry trend of
corrosion and failures that occur due to the aging concentric neutral cable. Also
see Confidential Attachment 2 – Response to Staff Request No. 243 that
addresses the anticipated design life of this cable. Further See Response to Staff
Request No. 243 - Confidential Attachment 3 that contains information pertaining
to outages that occurred on primary underground line dating back to 2010.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 299: Please provide the following information
for real property purchases/building construction needed for substations (Transmission,
Distribution, or combined) that the Company is seeking cost recovery in this rate case:
a. A list of each real property purchase/construction broken down by substation that
occurred since the Company's previous general rate case;
b. For any real property purchase(s)/construction listed in (a) above, please provide
the date and cost of each, and the amount of acres of land purchased and/or
square footage of building constructed; and
c. For any real property purchase(s)/construction listed in (a) above, please provide
the percentage of the land or square footage of building constructed that is
currently not in-service or will not be in-service by December 31, 2023.
RESPONSE TO REQUEST FOR PRODUCTION 299: Please refer to Attachment
1 – Response to Staff Request No. 299 for land acquisitions since the Company’s
previous general rate case. The attachment is broken into two sections, identifying those
properties included within FERC Accounts 101 - Electric Plant In Service and 105 - Plant
Held for Future Use for which Idaho Power is seeking cost recovery of in this general rate
case.
Substation buildings that have been constructed and placed in-service since the
Company’s previous general rate case are included in Attachment 2 – Response to Staff
Request No. 299. Information for the buildings within Attachment 2 was gathered using
asset cost data associated with the Company’s “COMPLETE STATION BUILDING”
property units within the transmission and distribution Structures and Improvements plant
accounts 35200 and 36100, respectively.
IDAHO POWER COMPANY’S RESPONSE TO THE NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
The response to this Request is sponsored by Mitch Colburn, VP of Planning,
Engineering and Construction, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
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 RESPONSE TO THE NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
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 Response to the Nineteenth 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 NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
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 NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
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
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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IDAHO POWER COMPANY’S RESPONSE TO THE NINETEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
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