20240828IPC to Staff 68.pdf

0-10AM POWER.
LISA D. NORDSTROM
Lead Counsel RECEIVED
InordstromCaDidahopower.com Wednesday, August 28, 2024
IDAHO PUBLIC
August 28, 2024 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
Ninth 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,
�4k, D �
Lisa D. Nordstrom
LDN:sg
Enclosures

CERTIFICATE OF ATTORNEY
RECEIVED
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIft Lft 4DAHO PUBLIC
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTIOYJTILITIES COMMISSION
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 to Idaho Power Company's Response to the Ninth
Production Request of the Commission Staff dated August 28, 2024, contains 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 28th 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) RECEIVED
Idaho Power Company Wednesday, August 28, 2024
1221 West Idaho Street (83702) IDAHO PUBLIC
P.O. BOX 70 UTILITIES COMMISSION
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 NINTH
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 Ninth Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated August 7, 2024, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 1

REQUEST FOR PRODUCTION NO. 68: Please provide the following data in Excel
format for each individual expense for the projects listed in the Confidential attachment RECEIVED
Wednesday, August 28, 2024
labeled "Capital Project Data Request June 2024". IDAHO PUBLIC
UTILITIES COMMISSION
a. Invoice Date;
b. Invoice Number;
c. Invoice Amount; and
d. Invoice Purpose (Services performed and/or material purchased, etc.).
RESPONSE TO REQUEST FOR PRODUCTION NO. 68: 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. 68 for a listing of all charges to each work order in Staff's confidential
attachment.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.
DATED at Boise, Idaho, this 28th 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 NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of August 2024, 1 served a true and RECEIVED
24
correct copy of Idaho Power Company's Response to the Ninth Productic r e e�s�l� t gust 28, 20I
the Commission Staff to Idaho Power upon the following named parties by th p� AHO PUBLIC
qT Ll'I` OMMISSION
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 NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 3

Idaho Conservation League Hand Delivered
Matthew A. Nykiel U.S. Mail
710 N. 6t" Street Overnight Mail REC EIVED
Boise, Idaho 83702 FAX Wednesday, August 28, 2024
FTP Site IDAHO PUBLIC
UTILITIES COMM SSION
X Email matthew.nykiel(o)_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(a)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(c�_hol land hart.com
Denver, CO 80202 tnelson(a)-hol land hart.com
awjensen _hol land hart.com
karoach(a)hollandhart.com
aclee(a)hollandhart.com
mamcmillen(a-),hollandhart.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
iswier(a)micron.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 BoiseCityAttorneyCa�cityofboise.org
ejewell cityofboise.org
IDAHO POWER COMPANY'S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER-4

Steven Hubble Hand Delivered
Boise City Dept. of Public Works U.S. Mail
150 N. Capitol Blvd. Overnight Mail EIVED
P.O. Box 500 FAX Wednesday, Augusstt 28, 2024
PUBLIC
Boise, Idaho 83701-0500 FTP Site IDAHO
UTILITIES COMM SSION
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
Peter.meier(�hg.doe.gov
emily.medlyn(q)_hg.doe.gov
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER-5