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Home My WebLink About20240705IPC to Staff 1-4.pdf 0-10AM POWER. RECEIVED LISA D. NORDSTROM Frday, July 5, 2024 Lead Counsel IDAHO PUBLIC Inordstrorn(Widahopower.com 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 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 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 the attachment in response to Request No. 1 to Idaho Power Company's Response to the First Production Request of the Commission Staff dated July 5, 2024, contains information that Idaho Power Company and a third party claim are confidential 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 5th day of July 2024. �(�c. ,�• �hc��?'�-,-ram 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: (208) 388-5825 Facsimile: (208) 388-6936 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 ) COMMISSION STAFF TO IDAHO AND MAINTENANCE EXPENSES. ) POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated June 13, 2023, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 1 REQUEST FOR PRODUCTION NO. 1: Please provide copies of the monthly trial balances from January 2023 through the most current month available. Please supplement your response when additional months become available throughout 2024. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see "Confidential Attachment— Response to Staff 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 COMMISSION STAFF TO IDAHO POWER - 2 REQUEST FOR PRODUCTION NO. 2: Please provide a copy of the Company's Chart of Accounts. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see "Attachment — Response to Staff Request No. 2". 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 COMMISSION STAFF TO IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 3: Please provide all workpapers and exhibits in Excel format with formulas intact and enabled. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see the attached Excel files labeled: • "Attachment 1 - Response to Staff Request No. 3 — Larkin Workpaper 1", • "Attachment 2 - Response to Staff Request No. 3 — Larkin Workpaper 2", • "Attachment 3 - Response to Staff Request No. 3 — Larkin Workpaper 3", • "Attachment 4 - Response to Staff Request No. 3 — Larkin Workpaper 4", • "Attachment 5 - Response to Staff Request No. 3 — Larkin Workpaper 5", • "Attachment 6 - Response to Staff Request No. 3 — Larkin Workpaper 6", • "Attachment 7 - Response to Staff Request No. 3 — Larkin Workpaper 7", • "Attachment 8 - Response to Staff Request No. 3 — Larkin Workpaper 8", • "Attachment 9 Response to Staff Request No. 3 — Application Attachment 3" • "Attachment 10 - Response to Staff Request No. 3 — Tatum Exhibit No. 4", • "Attachment 11 - Response to Staff Request No. 3 — Larkin Exhibit No. 6", • "Attachment 12 - Response to Staff Request No. 3 — Larkin Exhibit No. 7", • "Attachment 13 - Response to Staff Request No. 3 — Larkin Exhibit No. 8", • "Attachment 14 - Response to Staff Request No. 3 — Larkin Exhibit No. 9", • "Attachment 15 - Response to Staff Request No. 3 — Larkin Exhibit No. 10". 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 COMMISSION STAFF TO IDAHO POWER -4 REQUEST FOR PRODUCTION NO. 4: Please provide the revenue requirement model in Excel format with formulas intact and enabled. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see Attachment 15 provided in the Company's Response to Staff's Request No. 3. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 5 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 COMMISSION STAFF TO IDAHO POWER - 6 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 Commission Staff to 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 peterC@richardsonadams.com 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 COMMISSION STAFF TO IDAHO POWER - 7 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.n kiel mail.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 COMMISSION STAFF TO IDAHO POWER- 8