20240703Staff 8-16 to IPC.pdf

RECEIVED
Wednesday, July 3, 2024 3:04:13 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS )
ASSOCIATED WITH INCREMENTAL ) THIRD PRODUCTION
CAPITAL INVESTMENTS AND CERTAIN ) REQUEST OF THE
ONGOING OPERATIONS AND ) COMMISSION STAFF
MAINTENANCE EXPENSES ) TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY,JULY 24, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 3, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 8: Regarding the Revenue Allocation Summary provided as Exhibit
No. 4 in Tatum Direct Testimony, please respond to the following:
a. Please provide a copy of Exhibit 4 in Excel format with all formulas intact and
enabled; and
b. Please explain how the second pass revenue allocation among customer classes is
determined.
REQUEST NO. 9: Please provide internal and external audit reports from 2018-2024
regarding any aspects of employee compensation and benefits, including: wages, salaries, 401K
matching contributions, incentive payments, etc.
REQUEST NO. 10: Please provide all relevant information, including compensation
studies and surveys, used to determine employee general wage increases for 2023-2025.
REQUEST NO. 11: Please provide a description of how the general wage increase is
awarded to employees (i.e. across the board increase or allocated based on performance). Please
also provide the most current list of criteria and other requirements employees must meet to
receive the Company approved general wage increase.
REQUEST NO. 12: Please provide a list of all job titles and descriptions. Please
include the number of employees who are currently employed for each job title.
REQUEST NO. 13: Please provide a list of all job openings in 2023 and 2024. Include
the number of qualified candidates who applied for each position and how long each position
was open.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 3, 2024

REQUEST NO. 14: Please provide a list of employment positions created or
eliminated in 2023 and 2024. Please state the job title of such positions and justification of why
each position was created or removed.
REQUEST NO. 15: Please provide a list of employees, (ID#of employee acceptable
instead of name) who received more than the Company approved general wage increase. Please
provide reasonings for each increase.
REQUEST NO. 16: Please provide a matrix identifying the major capital expenditure
approval levels that includes the dollar level of authorization by job title and division. Please
explain the dollar level at which the individual capital expenditures require approval by the
Company's Board of Directors.
DATED at Boise, Idaho, this Yd day of July 2024.
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#3.docx
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JULY 3, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS�DAY OF JULY 2024,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-07,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: lnordstromcidahopower.com E-MAIL: ttatum c idahopower.com
dwalker�Lbidahopower.com caschenbrenner,aidahopower.com
mgoieoecheaallencidahopower.com mlarkincidahopower.com
dockets c idahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lancecaegisinsight.com
E-MAIL: elocechohawk.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreading cmindspring com
E-MAIL: peter crichardsonadams.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nykielLagmail.com E-MAIL:
heusinkveld cr,idahoconservation.or
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE