20240806IPC to Staff 31-33.pdf

-UIQAW POWER,
LISA D. NORDSTROM
Lead Counsel
Inordstrorn(Widahopower.com
RECEIVED
August 6, 2024 Tuesday, August 6, 2024
g IDAHO PUBLIC UTILITIES
COMMISSION
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
Fifth 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.
Given the significant time and resources required to individually label each
confidential document contained in the 390 MB of confidential attachments, Idaho Power
has instead marked the entirety of the contents contained within Production Response
Nos. 31(b) Confidential Attachment 7, 31(c) Confidential Attachment 2, 31(c) Confidential
Attachment 4, 31(d) Confidential Attachment 4, 31(d) Confidential Attachment 5, 31(d)
Confidential Attachment 6, 31(d) Confidential Attachment 7, 32(b) Confidential
Attachment 2, and 32(b) Confidential Attachment 3, confidential by designating the
Attachment folder and individual file name as "CONFIDENTIAL".

Commission Secretary
Idaho Public Utilities Commission
August 6, 2024
Page 2
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 to Request Nos. 31, 32, and 33 to Idaho Power
Company's Response to the Fifth Production Request of the Commission Staff dated
August 6, 2024, contain information that Idaho Power Company and/or a third party claim
are trade secrets, business records of a private enterprise required 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 6th day of August 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 FIFTH
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 Fifth Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated July 16, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 1

REQUEST FOR PRODUCTION NO. 31: Please provide the following information
for the Oxbow Hatchery project referenced by Direct Testimony of Eric Hackett. Please
include any available workpapers with formulas intact. If any of the information requested
below cannot be provided or is not available, please explain why it is not available or
cannot be provided.
a. Please provide any confidential documents not available to the public related to
the rebuild of the Oxbow fish hatchery, and "1980 Settlement Agreement" that
dictates the Company's obligation to operate the current fish hatchery.
b. If a Request for Proposal(s) ("RIFF) or Request for Quote(s) ("RFQ") was
submitted, please provide the following information:
i. A copy of the RFP(s) or RFQ(s) that were submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the proposal(s);
iii. The short-list bidder scorecard(s); and
iv. A copy of the winning bid(s).
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
d. Please provide the following for the Baseline Construction Project Plan:
i. Baseline project scope;
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 2

ii. Baseline project budget broken down by Work-Breakdown Structure
("WBS").
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope, budget, and/or schedule deviated
from the Initial Project Plan, please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.
e. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any deviations in schedule from the baseline construction
schedule.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31:
a. Please see the Response to Request for Production No. 31(a) — Attachment for a
copy of the 1980 Settlement Agreement. There are no other documents that dictate
the Company's obligation to operate the current fish hatchery.
b. Numerous competitive solicitations exist for this project. Two key bid events were
conducted for services to be provided to Idaho Power including engineering design
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 3

services, construction, construction support services and construction inspection
services. The construction support services were sole sourced. The following bid
events and detailed information regarding specifications, requirements, and other
pertinent RFP information can be found in the following attachments:
i. See the Company's Response to Request for Production No. 31(b) —
Attachment 1 for a copy of the Request for Bids ("RFB") for engineering design
services, Company's Response to Request for Production No. 31(b) —
Attachment 2 for a copy of the RFB for construction and see Company's
Response to Request for Production No. 31(b)—Attachment 3 for a copy of the
Sole Source Procurement Justification for construction support services. A
formal RFB was not issued for construction inspection services because of the
specialized services required. Rather, Idaho Power contacted three known
vendors directly, requesting a bid for the work necessary.
ii. See the Company's Response to Request for Production No. 31(b) —
Confidential Attachment 4 for a copy of the bid summaries for engineering
design, the Response to Request for Production No. 31(b) — Confidential
Attachment 5 for a copy of the bid summaries for construction, and the
Response to Request for Production No. 31(b) — Confidential Attachment 6 for
a copy of the bid proposal for construction support services. Because there was
no RFB or RFQ issued for construction inspection services, there is no
scorecard associated with this vendor selection.
iii. See part (b)(ii).
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER-4

iv. See the Company's Response to Request for Production No. 31(b) —
Confidential Attachment 4 for a copy of the bid for engineering design, the
Response to Request for Production No. 31(b) — Confidential Attachment 7 for
a copy of the winning bid for construction, and the Response to Request for
Production No. 31(b) — Confidential Attachment 8 for a copy of the winning bid
for construction support services. Because there was no RFB or RFQ issued
for construction inspection services, there is no winning bid associated with this
vendor selections.
c. See the Response to Request for Production No. 31(c) — Confidential Attachment
1 for the initial project plan. Please note, due to the continued deferment of the
hatchery renovations while awaiting approval from the Federal Energy Regulatory
Commission ("FERC"), the scope detailed in the initial project plan, which was
prepared in 2017, changed considerably once approval was received in 2023. It
was initially envisioned that the renovation project would include the construction
of a new river pump platform, the extension of current pumps and T-screen,
changing the power service from ground to overhead and the demolition and
construction of the hatchery and incubation building. Between 2017 and 2023, the
hatchery began showing significant signs of aging and potential safety issues and
therefore the renovation project scope was broadened. The following provides
information specific to the scope identified in 2023:
i. Idaho Power's Oxbow hatchery, located downstream from the Oxbow dam
powerhouse at the mouth of Pine Creek, is the holding and spawning facility
for adult steelhead migrating up the Snake River above its confluence with the
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 5

Salmon River. Built in 1961, the Oxbow hatchery was the first hatchery facility
constructed by the Company as part of its hatchery mitigation program and is
required by FERC as part of Idaho Power's operating license for the Brownlee,
Oxbow, and Hells Canyon dams ("Hells Canyon Complex"). Due to the aging
infrastructure and need for modernization, and the license requirement that the
Company provide the facility, it was essential the hatchery undergo an
extensive renovation.
The renovation and modernization of the Oxbow hatchery included the
removal of the hatchery building, the adjacent cooling unit, abandoned
raceways in the northeast corner of the site, the abandoned raceway west of
the existing hatchery building, intake structure, holding ponds, sorting and
spawning equipment, and a garage/storage building. The Company will add a
larger set of holding ponds with an open-air structure covering them, a masonry
sorting and spawning building, a wood-framed hatchery building, a wood-
framed shop and storage building, a surface water intake structure and aeration
tower, and a new visitor kiosk with interpretive and educational information. The
new intake structure addresses structural and flood elevation issues that were
experienced with the existing intake structure. The rebuilt hatchery also
incorporated improved stormwater drainage infrastructure with fill brought in so
that the hatchery meets floodplain requirements and paved throughways and
parking areas.
For the scope specific to the engineering design, see the Statement of Work
and the Project Approach provided as Response to Request for Production No.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 6

31(c) — Confidential Attachment 2. The scope of work specific to construction
is detailed in the RFB document and the accompanying Exhibits B and C
provided in the Company's Response to Request for Production No. 31(b) —
Attachment 2. The scope of work specific to construction support is detailed in
the Statement of Work provided as the Company's Response to Request for
Production No. 31(c) — Confidential Attachment 3 and for construction
inspection services is provided as the Company's Response to Request for
Production No. 31(c) — Confidential Attachment 4.
ii. Please see Response to Request for Production No. 31(c) — Confidential
Attachment 5 for the Budget Update — Authorized to Spend spreadsheet that
identifies the original approved budget amount of $5.4 million. As discussed in
part (c), the scope of the hatchery renovation broadened considerably following
establishment of the initial project plan and initial budget.
iii. The Oxbow hatchery renovation was originally scheduled to be scoped and
designed in 2019-2020 with construction completed in 2021. However, due to
unforeseen delays resulting from FERC's determination that an amendment to
the existing Hells Canyon Complex license would be required, construction was
pushed to the summer of 2022 with in-service in the fall 2024. For the schedule
specific to the engineering design, see the Response to Request for Production
No. 31(c) — Attachment 6 and for the schedule specific to construction see the
Response to Request for Production No. 31(c) — Attachment 7. Construction
support services were intended to occur alongside the construction schedule
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 7

while construction inspection services occur alongside and following
construction.
iv. See the Company's Response to Request for Production No. 17(a)(iv) for an
explanation of the capital project budget approval processes. The creation of
the BID BLPR130013 for the Oxbow hatchery renovation and corresponding
approved budgets reflected in the Response to Request for Production No.
31(c) — Confidential Attachment 5, the Budget Update — Authorized to Spend
spreadsheet, is evidence of approval of the initial budget.
d. There is no construction project plan document as construction plans did not
change since the scope and design documents were created.
i. The project scope did not change following completion of the scope documents
provided in the Company's Response to Request for Production No. 31(b) —
Attachment 2, and the Response to Request for Production No. 31(c) —
Confidential Attachments 1, 2 and 3.
ii. As explained in the Company's Response to Request for Production No.
17(a)(iv), the Oxbow hatchery renovation is continuously managed and
scrutinized on a monthly basis through MS Project Server scheduling software.
Any changes in scope, budget, or schedule, are approved in real-time based
on the overall portfolio limits. The changes, as appropriate, are documented by
revising the scope, design drawings, and construction. Specifications, and
other pertinent documents and the budget and schedule are updated in MS
Project related to forward action items that overwrite previous plans. Therefore,
the only WBS the Company can provide for the project reflects the most recent
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 8

budget and schedule. Please see the Response to Request for Production No.
31(d) — Attachment 1 for the hatchery renovation WBS.
iii. See part (d)(ii).
iv. Aside from the construction delay resulting from permitting delays, as
evidenced in Change Order—02 provided Response to Request for Production
No. 31(d) — Confidential Attachment 4 and discussed below, there were no
other delays in the construction schedule.
v. For status reports specific to construction see the Response to Request for
Production No. 31(d)—Attachment 2 and status reports specific to construction
inspection services see the Response to Request for Production No. 31(d) —
Attachment 3. There are no status reports associated with the engineering
design or construction support services.
vi. For the change orders specific to the engineering design see the Response to
Request for Production No. 31(d) — Confidential Attachment 4, change orders
specific to construction see the Response to Request for Production No. 31(d)
—Confidential Attachment 5, change orders specific to construction support see
the Response to Request for Production No. 31(d) — Confidential Attachment
6, and change orders specific to construction inspection services see the
Response to Request for Production No. 31(d) — Confidential Attachment 7.
e. i. Not applicable. See part (d)(ii).
ii. Not applicable. See part (d)(ii).
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 9

iii. Not applicable. However, see the variance notes included in the Budget Update
— Authorized to Spend included as Response to Request for Production No.
31(c) — Confidential Attachment 4.
iv. See part (d)(iv).
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 10

REQUEST FOR PRODUCTION NO. 32: Please provide the following
documentation for the single vendor platform project referenced by Colburn Direct at 28.
If any of the information requested below cannot be provided or is not available, please
explain why it is not available or cannot be provided.
a. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
b. Please provide the Baseline Construction Project Plan including the following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope, budget, and/or schedule deviated
from the Initial Project Plan, please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
v. Project status reports and action items; and
vi. Contractor change orders.
c. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 11

iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any deviations in schedule from the baseline construction
schedule.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32:
a. The single vendor platform project is a component of the grid modernization
initiative, which includes a set of multi-year projects designed to maintain and
improve reliability on the Company's electrical grid. This suite of projects replaces
and modernizes equipment nearing its end of life and updates the Company's
system with modern technology to enhance reliability while keeping costs low.
Idaho Power currently leverages three stand-alone grid control systems for
managing the bulk electric system, optimizing distribution assets, and responding
to customer outages. The systems are the (1) Energy Management System
("EMS")/Supervisory Control and Data Acquisition ("SCADA") system, (2) Outage
Management System ("OMS"), and Integrated Volt/Var Control, a Distribution
Management System ("DMS"). Because these systems are independent, they
require three sets of hardware, three network models, three support organizations,
and complex integrations between the systems. The single vendor platform
initiative replaces these numerous vendor solutions, consolidating the EMS, OMS,
and DMS into a single vendor platform. Please see the Response to Request for
Production No. 32(a) — Attachment 1 for the single vendor platform phase one
project plan.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 12

i. Please see the Response to Request for Production No. 32(a) — Confidential
Attachment 2 for the single vendor platform business case that outlines the
scope of the project.
ii. Please see the Response to Request for Production No. 32(a) — Attachment 3
for the single vendor platform variance notes that includes the initial project
budget amounts.
iii. The project was first identified in 2021 and during the 2021 through 2022 time
period the Company engaged in sourcing events to evaluate alternatives and
perform a financial analysis to determine if replacing the current system with a
new system is lower cost.
iv. See the Company's Response to Request for Production No. 17(a)(iv) for an
explanation of the capital project budget approval processes. The creation of
the BID BOBN220002 for the single vendor platform project and corresponding
budget amounts reflected in the Response to Request for Production No. 32(a)
— Attachment 3 is evidence of approval of the initial budget.
b. There were no changes to the project plan document since the business case was
created.
i. The project scope did not change following completion of the scope documents
provided in Response to Request for Production No. 32(a) —Attachment 1.
ii. See the Company's Response to Request for Production No. 17(b)(ii). The only
WBS the Company can provide for the project is reflective of the most recent
budget and schedule. Please see the Response to Request for Production No.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 13

32(b) — Attachment 1 for the first phase of the single vendor platform project
WBS.
iii. See part (b)(ii).
iv. See the Company's Response to Request for Production No. 17(a)(iv) and
(a)(ii). The budget updates reflected in the Response to Request for Production
No. 32(a) — Confidential Attachment 3 are evidence of approval of the updated
budget amounts associated with this project. See also the variance notes that
accompany budget update for an explanation of the change in the budget
amounts.
v. See the Company's Response to Request for Production No. 32(b) —
Confidential Attachment 2 for the status reports prepared jointly by Idaho Power
and Open Systems International ("OSI") as well as status reports prepared
internally by the Company's Project Management Office. Note, some of the
status reports include updates on phase two of the project, which has
commenced alongside the completion of phase one.
vi. See the Company's Response to Request for Production No. 32(b) —
Confidential Attachment 3 for the change orders associated with the OSI
contract. There have been no change orders associated with the Utilicast
contract.
c. i. Not applicable. See part (b)(ii).
ii. Not applicable. See part (b)(ii).
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 14

iii. Not applicable. However, see the variance notes provided in the Response to
Request for Production No. 32(a) — Confidential Attachment 3 for an
explanation of the variances driving the budget updates.
iv. While the schedule has evolved over the length of the project, with some
deadlines being moved up in the schedule and some extended to later in the
schedule, in general there have been no overall project schedule deviations
and implementation in October 2024 is still anticipated.
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 FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 15

REQUEST FOR PRODUCTION NO. 33: Please provide the following data in Excel
format for each individual expense for the projects listed in the Confidential attachment
labeled "Capital Project Data Request January Through May 2024".
a. Invoice date;
b. Invoice number;
c. Invoice amount; and
d. Invoice description (services performed and/or material purchased, etc.).
RESPONSE TO REQUEST FOR PRODUCTION NO. 33: Idaho Power interprets
Staff's request to mean all charges to each work order (i.e., labor, material issues, etc.)
not only invoice charges. Please see Confidential Attachment - Response to Staff
Request No. 33 for a listing of all charges to each work order in Staff's confidential
attachment.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.
DATED at Boise, Idaho, this 6th day of August 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 FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 16

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of August 2024, 1 served a true and correct
copy of Idaho Power Company's Response to the Fifth 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 [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 FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 17

Idaho Conservation League Hand Delivered
Matthew Nykiel U.S. Mail
710 N. 6t" 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. 6t" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email
bheusinkveld(cr,.idahoconservation.org
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Kristine A.K. Roach FTP Site
Holland & Hart LLP X Email
555 17' Street, Suite 3200 darueschhoff(a)hol land hart.com
Denver, CO 80202 tnelson _hollandhart.com
awiensen(o)-hol land hart.com
[e-mail]
aclee hollandhart.com
mamcmillen(a)hol land hart.com
Jim Swier Hand Delivered
Micron Technology, Inc. U.S. Mail
8000 South Federal Way Overnight Mail
Boise, ID 83707 FAX
FTP Site
X Email
jswier(cDmicron.com
City of Boise Hand Delivered
Ed Jewell U.S. Mail
Deputy City Attorney Overnight Mail
Boise City Attorney's Office FAX
150 N. Capitol Blvd. FTP Site
P.O. Box 500 X Email
Boise, Idaho 83701 BoiseCityAttorneV(a�_cityofboise.org
e newel I6c)cityofboise.org
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 18

Steven Hubble Hand Delivered
Boise City Dept. of Public Works U.S. Mail
150 N. Capitol Blvd. Overnight Mail
P.O. Box 500 FAX
Boise, Idaho 83701-0500 FTP Site
X Email
shubble cityofboise.org
Federal Executive Agencies Hand Delivered
Peter Meier U.S. Mail
Emily W. Medlyn Overnight Mail
U.S. Department of Energy FAX
1000 Independence Ave., S.W. FTP Site
Washington, DC 20585 X Email
Pete r.meier(a�hg.doe.gov
emily.medlyn(o)_hg.doe.gov
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 19