HomeMy WebLinkAbout20230929IPC to Staff 283_291-293_296-297.pdf
MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallen@idahopower.com
September 29, 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 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,
Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
2023 SEPTEMBER 29, 2023 4:46PM
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. 291, 292, 293,
296 and 297, to Idaho Power Company’s Second Supplemental Response to the
Eighteenth Production Request of the Commission Staff dated September 29,
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 29th day of September, 2023.
MEGAN GOICOECHEA ALLEN
Counsel for Idaho Power Company
IDAHO POWER COMPANY’S SECOND 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: (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 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 SECOND 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. Please see Attachment 1 – Second Supplemental Response to Staff Request No.
283. The first tab, titled 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. 291, 292, 293, 296 and 297. The second tab, titled 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. Nos. 291, 292, 293, 296 and 297. Each subsequent tab presents
the individual projects identified in in Staff’s Request for Production Nos. 291, 292,
293, 296 and 297 for which the budget-to-actuals comparison was requested and
includes a detailed explanation of the reason for the variances.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 291: 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 -
HBNDl101 - HBND Create alternate 35 kV route to Garden Valley, 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. 291:
a-b. Please see Attachment 1 – Second Supplemental Response to Staff Request No.
283.
c. See the tab titled HBNDl101 of Attachment 1 – Second Supplemental Response
to Staff Request No. 283 for the detailed explanation of the variances between
budget and actuals. In addition, Attachment 1 – Second Supplemental Response
to Staff Request No. 291 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 – Second Supplemental Response to
Staff Request No. 291 provide screenshots from the Company’s Customer Load
& Research Information System (“CLRIS”) reflecting the initial pre-authorization
request and the updated solution request.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 292: 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 -
SKWYl80001 - SKWY New Skyway distribution substation northwest of Caldwell
Industrial Airport, 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. 292:
a-b. See part (a-b) to the Company’s Second Supplemental Response to Request for
Production No. 283.
c. See the tab titled SKWYl80001 of Attachment 1 – Second Supplemental Response
to Staff Request No. 283 for the detailed explanation of the variances between
budget and actuals. In addition, Attachment 1 – Second Supplemental Response
to Staff Request No. 292 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 – Second Supplemental Response to
Staff Request No. 292u provide screenshots from CLRIS reflecting the initial pre-
authorization request and the updated solution request.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 293: 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 -
VARIl30001 - VARI Replace communications multiplex equipment, 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. 293:
a-b. See part (a-b) to the Company’s Second Supplemental Response to Request for
Production No. 283.
c. See the tab titled VARIl30001 of Attachment 1 – Second Supplemental Response
to Staff Request No. 283 for the detailed explanation of the variances between
budget and actuals. In addition, Attachment 1 – Second Supplemental Response
to Staff Request No. 293 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. 293 provide screenshots from CLRIS reflecting the initial pre-
authorization request and the updated solution request.
IDAHO POWER COMPANY’S SECOND 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 SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 296: 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 -
B00900276 - Lower Salmon #4 Turbine Refurbishment, 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. 296:
a-b. See part (a-b) to the Company’s Second Supplemental Response to Request for
Production No. 283.
c. See the tab titled B00900276 of Attachment 1 – Second Supplemental Response
to Staff Request No. 283 for the detailed explanation of the variances between
budget and actuals. In addition, Attachment 1 – Second Supplemental Response
to Staff Request No. 296 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. 296 provides the screenshots from CLRIS reflecting the initial pre-
authorization request.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 10
The response to this Request is sponsored by Eric Hackett, Projects and
Design Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 297: 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 -
CHQBl60049- BSPO U3 Kaplan Turbine and Generator Refurbishment, 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. 297:
a-b. See part (a-b) to the Company’s Second Supplemental Response to Request for
Production No. 283.
c. See the tab titled CHQBl60049 of Attachment 1 – Second Supplemental Response
to Staff Request No. 283 for the detailed explanation of the variances between
budget and actuals. In addition, Attachment 1 – Second Supplemental Response
to Staff Request No. 297 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. 297 provides the screenshots from CLRIS reflecting the initial pre-
authorization request.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
DATED at Boise, Idaho, this 29th day of September 2023.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
LISA D. NORDSTROM
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Second 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 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
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email peter@richardsonadams.com
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616
Hand Delivered
U.S. Mail
Overnight Mail
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
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email elo@echohawk.com
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
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
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
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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U.S. Mail
Overnight Mail
FAX
FTP Site
X Email jswier@micron.com
IDAHO POWER COMPANY’S SECOND 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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U.S. Mail
Overnight Mail
FAX
FTP Site
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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U.S. Mail
Overnight Mail
FAX
FTP Site
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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U.S. Mail
Overnight Mail
FAX
FTP Site
X Email mkellner@idahoconservation.org
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
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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U.S. Mail
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FAX
FTP Site
X Email tom.arkoosh@arkoosh.com
erin.cecil@arkoosh.com
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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Overnight Mail
FAX
FTP Site
X Email peter.meier@hq.doe.gov
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE EIGHTEENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email detheridge@exeterassociates.com
NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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FTP Site
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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U.S. Mail
Overnight Mail
FAX
FTP Site
X Email NSemanko@parsonsbehle.com
Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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U.S. Mail
Overnight Mail
FAX
FTP Site
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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Overnight Mail
FAX
FTP Site
X Email jcaviglia@parsonsbehle.com
Stacy Gust Regulatory Administrative
Assistant