20240705IPC to ICIP Nos. 1-8.pdf

-UIQAW POWER,
RECEIVED
LISA D. NORDSTROM
Lead Counsel Frday, July 5, 2024
Inordstrom m(Wjdahopower.co IDAHO PUBLIC
UTILITIES COMMISSION
July 5, 2024
VIA ELECTRONIC FILING
Commission 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-24-07
Application of Idaho Power Company for Authority to Increase Rates for
Electric Service to Recover Costs Associated with Incremental Capital
Investments and Certain Ongoing Operations and Maintenance Expenses
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company's Response to the
First Production Request of the Industrial Customers of Idaho Power 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 will be provided to the parties that execute 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

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-24-07
Idaho Power Company's Application for Authority to Increase Rates for Electric
Service to Recover Costs Associated with Incremental Capital Investments and
Certain Ongoing Operations and Maintenance Expenses
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that some of the attachments in response to Request Nos. 4 and 8 to Idaho
Power Company's Response to the First Production Request of the Industrial Customers
of Idaho Power dated July 5, 2024, contain information that Idaho Power Company and/or
a third party claim are trade secrets, business records of a private enterprise require by
law to be submitted to or inspected by a public agency, and/or public records exempt from
disclosure by state or federal law (material nonpublic information under U.S. Securities
and Exchange Commission Regulation FD) 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 5t" day of July 2024.
LISA D. NORDSTROM
Attorney for Idaho Power Company

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]
Inordstrom(aMdahopower.com
dwalker idahopower.com
mgoicoecheaallenCabidahopower.com
Attorneys for Idaho Power Company
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 ) IDAHO POWER COMPANY'S
ASSOCIATED WITH INCREMENTAL ) RESPONSE TO THE FIRST
CAPITAL INVESTMENTS AND ) PRODUCTION REQUEST OF THE
CERTAIN ONGOING OPERATIONS ) INDUSTRIAL CUSTOMERS OF
AND MAINTENANCE EXPENSES. ) IDAHO POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Industrial Customers of Idaho Power
("ICIP") dated June 13, 2023, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 1

REQUEST FOR PRODUCTION NO. 1: Please provide, in electronic format, with
all formulae intact where possible, along with workpapers and other documents used in
the development Matthew Larkin's Workpaper 6.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: The workpapers used to
develop Matthew Larkin's Workpaper 6 are included as Attachments 1 — 21 to the
Company's Response to ICIP Request No. 1.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 2

REQUEST FOR PRODUCTION NO. 2: Please provide, in electronic format, all
formulae intact where possible, along with workpapers and other documents used in the
development Timothy Tatum's Exhibit 4.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Idaho Power's Class
Cost-of-Service ("CCOS") Study used in the development of Mr. Tatum's Exhibit 4 is
included in the file labeled "Attachment — Response to ICIP Request No. 2." The first tab
on the left labeled "Exhibit No. 4" is a copy of the exhibit in electronic format.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 3

REQUEST FOR PRODUCTION NO. 3: At pages 21 and 22 of his direct testimony
Mr. Tatum states that "In Idaho Power's 2008 general rate case, IPC-E-08-10, the
Commission approved the use of projected year-end plant balances for projects having a
cost more than $2 million. " In a footnote on page 22, Mr. Tatum quotes the Commission's
order approving said year-end plant balance rate making treatment. According to that
quoted order, the Commission required the company to "annualize" the year-end plant
balances. [See footnote 4.] Please explain the ramifications both to ratepayers and the
Company of annualizing the year-end plant balances for ratemaking purposes. Is the
Company proposing to annualize its year-end plant balances in this current application?
Please explain why, or why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The use of the word
"annualize" within the context of this question is a distinction that does not impact the
calculation used to develop the rate request in this case. The use of year-end 2024 plant
inherently is an "annualized" approach, as it reflects plant balances as of the end of 2024,
therefore there is no difference between year-end plant balances and "annualized" year-
end plant balances.
Mr. Tatum discusses the ramifications of regulatory lag—which the use of year-
end 2024 plant balances is intended to address—on pages 17 through 24 of his
testimony. At a high level, the use of year-end 2024 plant balances results in more timely
cost recovery that better aligns the rate effective date with the in-service date of the
corresponding capital investments, which has the potential to positively impact credit
ratings and Idaho Power's overall cost of doing business.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER-4

The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 5

REQUEST FOR PRODUCTION NO. 4: At page 19 of Mr. Tatum's direct
testimony, he references a "note from Standard and Poor's[that]indicated a downgrading
of its liquidity assessment of the Company." The referenced note is dated February 2023.
Please provide copies of all Standard and Poor's communications/discussions regarding
Idaho Power dated after February 2023.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Idaho Power is
interpreting this request as asking for communications issued by Standard & Poor's
regarding Idaho Power over the requested timeframe. Communications related to the
June 16, 2023, and June 13, 2024, annual published reports for Idaho Power Company
by Standard & Poor's that were not conducted telephonically consisted of the publication
of credit opinions by Standard & Poor's Global Ratings. These credit opinions are
attached to this response as "CONFIDENTIAL Attachment 1 — Response to ICIP Request
No. 4 - Credit Opinion - Idaho-Power-Company — 16Jun2Y and "CONFIDENTIAL
Attachment 2 — Response to ICIP Request No. 4 — Credit Opinion — Idaho Power
Company — 13Jun24."
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 6

REQUEST FOR PRODUCTION NO. 5: At page 29 of his Direct Testimony, Mr.
Tatum addresses the Company's proposed rate spread with a ceiling of 130 percent and
a floor of 50 percent of the average 7.31 percent increase. Please provide workpapers
in electronic format with all formulae intact where possible, that were used in calculating
and applying the cap and floor for each customer class.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the file
labeled "Attachment— Response to ICIP Request No. 2" and the tab labeled "Exhibit No.
4" for the calculations for applying the proposed revenue spread to each customer class.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 7

REQUEST FOR PRODUCTION NO. 6: Please reference Mr. Tatum's Exhibit 4 at
column "Q" (titled "COS Index"). Please explain how the values in the column were
calculated. Please explain how these values are used in determining rate spread for
customer class.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The file labeled
"Attachment — Response to ICIP Request No. 2" and the tab labeled "Exhibit No. 4"
includes the calculations for Mr. Tatum's Exhibit 4. The column "P" (titled "COS Index")
was not directly used to determine the rate spread for each customer class. Rather, the
cap and spread parameters agreed to in the 2023 Stipulation were applied to each
customer class (Tatum, DI at 29). The COS Index referenced is only a relative comparison
provided for informational purposes, which is calculated by dividing column "O" (final
revenue spread average mills/kWh) by column "G" (class cost-of-service revenue
allocation mills/kWh).
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 8

REQUEST FOR PRODUCTION NO. 7: Please reference Mr. Tatum's Exhibit 4 at
columns "L" and "M" (titled "Shortfall Allocation"). Please explain how the shortfall
Allocations among the various customer classes were arrived at and justified.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The file labeled
"Attachment — Response to ICIP Request No. 2" and the tab labeled "Exhibit No. 4"
includes the calculations for Mr. Tatum's Exhibit 4. Columns "K" through "M" (titled
"Second Pass Revenue Allocation") allocate the First Pass Shortfall of$1.073 million that
remains after applying the cap and floor percentage increases to each customer class in
the First Pass Revenue Allocation (see columns "H" through "I"). Column "K" determines
which customer classes First Pass Revenue Allocation was not at the cap or floor (shown
with a "Y" to indicate the Second Pass Revenue Allocation applies to a given customer
class). For all customer classes that the Second Pass Revenue Allocation applies,
Column "L" allocates a percentage of the total Second Pass Revenue Allocation based
on their percentage of 2024 Retail Sales in column "C" to then allocate the First Pass
Shortfall of $1.073 million in column "M" of Exhibit 4.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 9

REQUEST FOR PRODUCTION NO. 8: Please provide copies of all
communications (inclusive of discovery requests and response) the Company has had
with the Idaho PUC Staff (both formal and informal) regarding the substance of this
docket.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Please see the file
labeled "Attachment 1 — Response to ICIP Request No. 8" and "Confidential Attachment
2 — Response to ICIP Request No. 8" provided in response to this request.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
DATED at Boise, Idaho, this 5th day of July 2024.
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 FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 10

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of July 2024, 1 served a true and correct
copy of Idaho Power Company's Response to the First Production Request of the
Industrial Customers of Idaho Power upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff Hand Delivered
Chris Burdin U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email Chris.Burdin(c�puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Industrial Customers of Idaho Power Hand Delivered
Peter J. Richardson U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 27' Street FAX
Boise, Idaho 83702 FTP Site
X Email [e-mail]
Dr. Don Reading Hand Delivered
280 Silverwood Way U.S. Mail
Eagle, Idaho 83616 Overnight Mail
FAX
FTP Site
X Email dreading(@mindspring.com
Idaho Irrigation Pumpers Association, Hand Delivered
Inc. U.S. Mail
Eric L. Olsen Overnight Mail
ECHO HAWK & OLSEN, PLLC FAX
505 Pershing Avenue, Suite 100 FTP Site
P.O. Box 6119 X Email elo _echohawk.com
Pocatello, Idaho 83205
Lance Kaufman, Ph.D. Hand Delivered
2623 NW Bluebell Place U.S. Mail
Corvallis, OR 97330 Overnight Mail
FAX
FTP Site
X Email lance aegisinsight.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 11

Idaho Conservation League Hand Delivered
Matthew Nykiel U.S. Mail
710 N. 61" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email
Matthew.nykiel gmail.com
Brad Heusinkveld Hand Delivered
Idaho Conservation League U.S. Mail
710 N. 61" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email
bheusinkveld(a-),idahoconservation.org
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 12