20230929IPC to Staff 306-309.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

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 Response to the
Twenty-Second 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 4:52PM
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. 306, 308, and 309,
to Idaho Power Company’s Response to Staff’s Twenty-Second 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 RESPONSE TO THE TWENTY-SECOND 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.
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
RESPONSE TO THE TWENTY-
SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF TO
IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Twenty-Second 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 TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 306: 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 -
B00809249 - BLPR Ul234 Turbine Refurbishments, 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 306:
a-b. Please see Attachment 1 – Response to Staff Request No. 306. The first tab,
titled DRs 306-309 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. 306 through 309. The second tab, titled DRs 306-309 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. 306 through 309. Each subsequent tab presents the individual projects for
which the budget-to-actuals comparison was requested and includes a detailed
explanation of the reason for the variances.
Baseline schedule comparisons to actual schedule delivery is not compared
due to the ever-changing landscape of the entire portfolio of capital projects.
Rather, projects are managed in real-time, and schedules are constantly monitored
in comparison to the entire portfolio of projects to manage timeline and execution

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 3
strategy, in conjunction with all other capital project needs. Project schedules are
updated at least monthly for resource leaders to evaluate planned work across the
matrixed organization. Variances in budget forecasts are also constantly evaluated
and monitored within the overall portfolio of projects.
c. See the tab titled B00809249 of Attachment 1 –Response to Staff Request No.
306 for the detailed explanation of the variances between budget and actuals. In
addition, Attachment 2 – Response to Staff Request No. 306 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 –
Response to Staff Request No. 306 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 RESPONSE TO THE TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 307: 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 -
CHQBl00145 - Hatcheries - NSFS – Hatchery Expansion/Renovation, 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 307:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 306.
c. The Company is still gathering the documentation to support the response to part
(c) of this request and will supplement the response by October 4, 2023.
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 TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 308: 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 -
HCPR200001 - HCPR Ul3 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 308:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 306.
c. See the tab titled HCPR200001 of Attachment 1 – Response to Staff Request
No. 306 for the detailed explanation of the variances between budget and
actuals. In addition, Attachment 1 – Response to Staff Request No. 308 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 – Response to Staff Request No. 308 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 RESPONSE TO THE TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 309: 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 -
LSPRl60002 - LSPR U2 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 309:
a-b. See part (a-b) to the Company’s Response to Request for Production No. 306.
c. See the tab titled LSPRl60002 of Attachment 1 – Response to Staff Request No.
306 for the detailed explanation of the variances between budget and actuals. In
addition, Attachment 1 – Response to Staff Request No. 309 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 –
Response to Staff Request No. 309 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 RESPONSE TO THE TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 7
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 RESPONSE TO THE TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 8
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 Response to the Twenty-Second
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 TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 9
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 TWENTY-SECOND 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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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 TWENTY-SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF - 11
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