20240909IPC to Staff 106-112.pdf

-UIQAW POWER,
MEGAN GOICOECHEA ALLEN
Corporate Council RECEIVED
Monday, September
mgoicoecheaallen(a� IDAHO PUBLIC
20UBLIidahopower.com p C
C
UTILITIES COMMISSION
September 9, 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
Thirteenth 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 confidential attachments, Idaho Power has
instead marked the entirety of the contents contained within Production Response Nos.
107 Confidential Attachment 1, 107 Confidential Attachment 2, 107 Confidential
Attachment 3, 107 Confidential Attachment 4, 107 Confidential Attachment 5, and 107
Confidential Attachment 7, confidential by designating the Attachment folder and
individual file name as "CONFIDENTIAL". When downloading the zip folder, please
save the zip file to your desktop to avoid any errors with the lengthy file names.

Commission Secretary
Idaho Public Utilities Commission
September 9, 2024
Page 2
If you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
i W" &
Megan Goicoechea Allen
MGA: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. 106,107, 108, 109, 110, 111 and
112 to Idaho Power Company's Response to the Thirteenth Production Request of the
Commission Staff dated September 9, 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 9th day of September 2024.
Megan Goicoechea Allen
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 THIRTEENTH
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 Thirteenth Production Request of the Commission Staff ("Commission"
or "Staff") to Idaho Power Company dated August 26, 2024, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 1

REQUEST FOR PRODUCTION NO. 106: Please provide a narrative explanation
of the need, scope of work, and other solutions considered for Budget ID "UNTY220002
- UNTY Install Satellite to Reduce Ongoing Expenses - Preliminary Scope". Please also
provide copies of the invoices for any charges incurred for this project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 106: The following provides
the need and scope of work for Budget ID UNTY220002, the installation of satellite at the
Unity substation.
Project Need: The need for this project was to improve the reliability of Unity
substation's communication service and, in turn, reduce monthly costs. The
communication service from Oregon utilities and Centuryl-ink was expensive and did not
perform reliably. Further, the service provider notified Idaho Power that service would
soon be discontinued.
Scope of Work: Substations require stable communication to support metering,
remote telemetry, and control operations. The scope of work included adding a satellite
dish and associated structural mount, conduits, satellite modem, and ancillary equipment
to enable connection to an existing communications multiplexer at Unity substation.
Alternative Solutions: The alternative solution considered was to install a radio
backhaul system. This radio backhaul option was eliminated because it would require a
new intermediate communications site, which includes the added cost of leasing an
existing site or building a new site. A new site alone, without Unity changes, would be
more costly than the satellite option and is supported by a more general programmatic
satellite implementation program, which is not appropriate at this time.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 2

Invoices: Design and construction costs were associated with internal labor so
there are no invoices for this work. Additional miscellaneous services such as equipment
rental and soil sampling were performed, and the invoices are included in Response to
Request for Production No. 106 — Confidential attachments 1-9.
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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 3

REQUEST FOR PRODUCTION NO. 107: Please provide a narrative explanation
of the need, scope of work, and competitive bids submitted for Budget ID "BOBN200005
— Station Perimeter Security Fence". Please also provide copies of the invoices for any
charges incurred for this project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 107: The following provides
the need and scope of work for Budget ID BOBN200005, the installation of the station
perimeter security fence.
Project Need: The need for this project was to meet identified enhanced security
prototype objectives and NERC CIP compliance regulations as more fully described
below.
Enhanced Security Prototype Objectives: Idaho Power conducted Threat and
Vulnerability Assessments ("TVA") of the Boise Bench substation in 2018 as part of its
enhanced security and Critical Infrastructure Protection ("CIP") compliance program
requirements. The goal was to identify critical assets at each location, measure the risks
associated with security threats against those assets, and develop security prototype
enhancement recommendations to appropriately mitigate risk.
The TVAs were conducted through an internal risk-based model that was created
to reflect the Company's risk tolerance for physical security events. Threats to assets
were measured in several categories:
• Consequence — What would the impact be to Idaho Power (Safety, Compliance,
Reputation, Property, Capability and Financially).
• Vulnerability— How vulnerable or susceptible are site assets to exploitation, hazard
or threat?
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 4

• Likelihood — How probable is the threat to occur?
• Threat — How capable and motivated are the threat actors involved?
• Security — How capable are the current security controls?
These measurements helped Idaho Power to derive risk scores for individual
threats against site assets. Intolerable risk was identified and enhanced security prototype
recommendations were developed to mitigate the identified risk to an acceptable level.
Collectively, the goal of the security prototype was to recommend enhanced security
controls that enable better: detection, deterrence, delay, communication, assessment,
monitoring, and response to identified threats.
NERC CIP Compliance Requirements: The Boise Bench substation is currently a North
American Electric Reliability Corporation ("NERC") CIP medium impact location. The
NERC CIP are a set of requirements designed to secure the assets required for operating
North America's bulk electric system. The Boise Bench substation is subject to NERC
CIP014 and CIP006.
CIP014 requires Idaho Power to identify and protect transmission stations and
transmission substations, and their associated primary control centers, that if rendered
inoperable or damaged as a result of a physical attack could result in instability,
uncontrolled separation, or cascading within an interconnection. CIP0141 requires Idaho
Power to implement the following at the Boise Bench substation:
• Conduct an evaluation of the potential threats and vulnerabilities of a physical
attack to each of their respective transmission station(s), transmission
substation(s), and primary control center(s). The evaluation should consider:
https://www.nerc.com/pa/Stand/Reliability%20Standards/CIP-014-1.pdf
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 5

o Unique characteristics of the identified and verified transmission station(s),
transmission substation(s), and primary control center(s).
o Prior history of attack on similar facilities taking into account the frequency,
geographic proximity, and severity of past physical security related events.
o Intelligence or threat warnings received from sources such as law
enforcement, the Electric Reliability Organization ("ERO"), the Electricity
Sector Information Sharing and Analysis Center ("ES-ISAC"), U.S. federal
and/or Canadian governmental agencies, or their successors.
• Develop and implement a documented physical security plan(s) that covers their
respective transmission station(s), transmission substation(s), and primary control
center(s). The physical security plan(s) shall include the following attributes:
o Resiliency or security measures designed collectively to deter, detect,
delay, assess, communicate, and respond to potential physical threats and
vulnerabilities identified during the evaluation.
o Provisions to evaluate evolving physical threats, and their corresponding
security measures, to the transmission station(s), transmission
substation(s), or primary control center(s).
CIP0062 requires Idaho Power to manage physical access to Bulk Electric System
Cyber Systems ("BES Cyber Systems") by specifying a physical security plan in support
of protecting BES Cyber Systems against compromise that could lead to mis-operation
or instability in the bulk electric system. This requires Idaho Power to collectively:
2 https://www.nerc.com/pa/Stand/Reliabilitv%20Standards/CIP-006-6.pdf
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 6

• Define operational or procedural controls to restrict physical access medium
impact BES Cyber Systems.
• Utilize two or more different physical access controls to collectively allow
unescorted physical access into physical security perimeters to only those
individuals who have authorized unescorted physical access.
• Monitor for unauthorized access through a physical access point into a physical
security perimeter.
• Issue an alarm or alert in response to detected unauthorized access through a
physical access point into a physical security perimeter.
• Monitor each physical access control system for unauthorized physical access to
a physical access control system.
• Issue an alarm or alert in response to detected unauthorized physical access to a
physical access control system.
• Log entry of each individual with authorized unescorted physical access into each
physical security perimeter, with information to identify the individual and date and
time of entry.
• Retain physical access logs of entry of individuals with authorized unescorted
physical access into each physical security perimeter for at least ninety calendar
days.
• Restrict physical access to cabling and other nonprogrammable communication
components used for connection between applicable cyber assets within the same
electronic security perimeter in those instances when such cabling and
components are located outside of a physical security perimeter.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 7

• Require continuous escorted access of visitors within each physical security
perimeter.
• Require manual or automated logging of visitor entry into and exit from the physical
security perimeter that includes date and time of the initial entry and last exit, the
visitor's name, and the name of an individual point of contact responsible for the
visitor.
The controls selected and implemented through this project ensure compliance with all
CIP014 and CIP006 requirements.
Scope of Work: To meet the identified enhanced security prototype objectives, as
well as the NERC CIP compliance regulations, several security controls were identified
and implemented through the scope of this project:
• Security Fencing and Gates— Previous to the project, the chain link fence
surrounding the locations offered negligible risk reduction against threats identified
in the TVA. The chain link fences were not anti-cut (threats can use common
snipping tools and defeat the fence in under a minute), anti-climb, provided no dig
protection, offered full opacity of sight lines to critical assets and were shorter than
Idaho Power's physical security standard fence height requirements. The fence's
enhanced security requirements were designed to better meet the collective
security requirements. The height of the fence, the anti-cut, anti-climb, and anti-
dig properties, along with 0 percent opacity enable a superior deterrence and delay
time. These attributes, in conjunction with other security controls implemented,
enabled an improved security posture and helped Idaho Power's security team
address risks identified by the TVA. Security objectives satisfied —deter and delay.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 8

• Security Camera and Analytics — enhanced security cameras brought better
picture, integrated infrared lighting, on-board Artificial Intelligence ("Al") analytics
features such as human and vehicle object detection. Visual gaps were filled by
adding additional cameras along the fence line to provide better detection
capabilities along site perimeters. Security objectives satisfied — detect, deter,
assess, and respond.
• Vehicle Crash Gates - the Boise Bench substation security fence line contains one
M30/P2 crash rated gate arm. The crash gate was installed at the west entry to the
facility and is rated to stop impact from a 15,000-pound vehicle moving at 30 miles
per hour. Security objectives satisfied — deter and delay.
• Annunciators and Horns — Boise Bench substation has networked annunciators,
strobes and horns deployed on site. These devices enable operators at a remote
monitoring center to respond to unauthorized access attempts through the
sounding of horns, audio playback, or live voice broadcasting. Security objectives
satisfied — deter, detect, assess, respond, and communicate.
Along with the physical security benefits, which enable Idaho Power to satisfy
NERC CIP requirements, the Company also gained operational benefits, such as the
ability to automate entry and exit into the facility and provide remote viewing of onsite
assets to operations employees located elsewhere. This project also provided enhanced
safety due to more secure fencing to keep members of the public out of the substation,
which reduces the probability of an electrical contact by a member of the public.
Competitive Bids: The Request for Proposal ("RFP") and bid submittals are
included in Response to Request for Production No. 107 — Confidential Attachments 1
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 9

through 6 and invoices are included in Response to Request for Production No. 107 —
Confidential Attachment 7.
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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 10

REQUEST FOR PRODUCTION NO. 108: Please provide a narrative explanation
of the need, other solutions considered, and competitive bids submitted for Budget ID
"B01000304 — Multifunction devices, plotters, printers". Please explain what was done
with the existing devices and provide copies of any invoices for charges incurred for this
project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 108: The following provides
the need for this project, which involved the maintenance and/or upgrading of the current
printer fleet with multifunction devices, plotters, and printers.
Project Need: The primary need was due to the age of the equipment. The average
life of the printers targeted for replacement over the last year is seven years old or greater.
Some of these printers are also in outlying areas that are difficult to get to if the current
printer experiences a failure.
Based on the experience of other like size/volume Fisher's customers in Boise, the
Company can estimate replacement years, usage, discontinued models, and budget
accordingly. In addition, the service provider indicated there are no known evolutionary
technology changes forecasted over the next 5 years that would change the Company's
printer fleet optimization model.
Alternative Solutions: Another consideration implemented was a "run to failure"
model in the Boise downtown area where there are a couple of pool printers in stock that
provided Idaho Power with the ability to replace printers when they fail instead of life-
cycling printers that are still operational. This has reduced the number of replacements
needed.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 11

Competitive Bids: In 2021 the Company launched a competitive RFP, and a new
purchase and services agreement was signed in 2022 that resulted in lower device prices.
The devices that are replaced have their hard drives removed and are sent to Investment
Recovery for proper disposal.
Please see the Response to Request for Production No. 108 — Confidential
Attachments 1 through 11 for invoices for charges incurred during this time period.
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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 12

REQUEST FOR PRODUCTION NO. 109: Please provide an Excel workbook
which identifies all software licenses addressed under Budget ID "PLZ1150014 — 2024
Microsoft Licensing True-Up". For each software, please provide the quantity of existing
and newly purchased licenses, individual purchase price, quantity assigned, and
explanation for any unassigned licenses and how this aligns with business needs since
January 1, 2024.
RESPONSE TO REQUEST FOR PRODUCTION NO. 109: Budget ID
PLZ1150014 is the capital purchase component of the Microsoft Windows Server Data
Center licenses and Microsoft SQL Enterprise licenses to accommodate for expansion of
the Company's computing and database processing requirements. These products are
sold in "2-core" packs with a minimum purchase of 8 pack blocks for Windows Server
Data Center and SQL Enterprise minimum of 1 pack (2-core). "Core" refers to the number
of physical cores on the host server running the software. Please see the Response to
Request for Production No. 109 — Confidential Attachment 1 for a table of licenses
addressed under Budget ID PLZ1150014.
Invoices reflect additional cloud-only services added to the Idaho Power M365
subscriptions and are charged to operations and maintenance expense ("O&M"). Invoice
1318041217 (provided as the Response to Request for Production No. 109 — Confidential
Attachment 2) reflects Windows Server Data Center license-only with no Software
Assurance. Software Assurance ("SA") is a variable benefit to licenses that can be added
to enable things such as mobility frequency across Virtualization Hosts and "free" (non-
licensed) failover systems. The Company does not need this service on all licenses and
this service is charged to O&M. For the 8 licenses for Windows Server Data Center in
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 13

Invoice 9882882146 (provided as the Response to Request for Production No. 109 —
Confidential Attachment 3) and the 2 licenses of SQL Enterprise on Invoice 9882881202
(provided as the Response to Request for Production No. 109 — Confidential Attachment
4), Software Assurance is included in the cost and capital and O&M components are
separated by Idaho Power. SA is paid annually as an O&M expense as part of the 5-year
Enterprise Agreement for all existing licenses, so the SA is provided, per product, as a
line item on the Consumer Pricing Sheet ("CPS") and thus the Company is able to
calculate the SA for these new licenses purchased. Licenses purchased during the annual
True-Up within the five-year agreement must pay the remaining years of SA. Because
this was year one of the 2023-2028 agreement, the SA for four years was charged to
O&M for each license.
All licenses purchased at True-Up are immediately in operation in the Idaho Power
environment by the time of purchase. No purchased licenses are not in production, as the
mechanism of True-Up is to license systems already in production. Purchased and in-
production quantities are:
• Windows Server Data Center: Cost is $733.02 per 2 cores. Total license
purchase in 2024 totals $43,891 plus tax. Each physical server requires either
16 or 20 cores.120 cores (60 2-core packs) were purchased in 2024, bringing
our grand total to 1,218 cores (609 2-core packs).
• SQL Enterprise: License cost is $19,361.96 per 2-core pack. Two 2-core packs
were purchased in 2024 (total of 4 cores) for $38,117 plus tax. Remaining
invoice cost is four years of SA on these two licenses. Total licenses owned
and in production are 67 (total of 134 cores).
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 14

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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 15

REQUEST FOR PRODUCTION NO. 110: Please provide a narrative explanation
of the need, scope of work, and other solutions considered for Budget ID "CHQB180060
— IEE License Expansion 2024". Please provide the invoices for this project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 110: Idaho Power was
required to expand the number of licenses for the meter data management system, Itron
Enterprise Edition ("IEE"), due to customer growth. Each endpoint in IEE requires one
license. As of March 2024, the Company was licensed for 640,000 endpoints plus a 5
percent buffer and had 635,000 active endpoints in the IEE system. Idaho Power
experiences an average endpoint increase of 1,200 a month and the Company was
expecting to reach 640,000 endpoints by July 2024. Licenses are available in blocks of
20,000. Idaho Power purchased 20,000 more endpoint licenses in May 2024.
This capital license purchase expanded the number of licensed IEE endpoints by
20,000 to meet current needs. Idaho Power changed its license purchase strategy from
purchasing large numbers of endpoints to more frequent smaller numbers that more
closely track actual growth. This approach minimizes ongoing costs that add no value by
paying for licenses when needed versus purchasing larger quantities of licenses, some
of which would not soon be leveraged.
Please see the Response to Request for Production No. 110 — Confidential
Attachment for the invoice for this project.
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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 16

REQUEST FOR PRODUCTION NO. 111: As a follow-up to Production Request
No. 53 for Budget ID "CHQB190012 Bathroom/Core Upgrade Each Floor At CHQ", please
provide the following:
a. Narrative explanation of the storm water damage;
b. Bids submitted;
c. All related invoices; and
d. Insurance coverage amount received by the Company and how it was applied to
the total project costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 111:
a. Due to heavy rains in the downtown Boise area, the city streets flooded causing
the check valve at the CHQ building's stormwater discharge to fail. This caused
the CHQ drainpipe to back up and the pressure caused the drain to detach at the
lowest 90-degree elbow, above the basement restrooms/locker rooms. This
occurred in the evening, when employees were not around. Thousands of gallons
of water from both the CHQ roof and the surrounding flooded streets poured into
the area prior to security being alerted by the fire alarm system.
The flooding spread throughout the basement, covering the entire floor with
1 — 2 inches of water. The water also got into all the floor mounted heating units in
the basement, shorting them out. Multiple areas needed new sheetrock,
baseboard, and electrical repairs due to the damage.
b. The bids received are included as Response to Request for Production No. 111 -
Confidential Attachments 1 through 3.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 17

c. All related invoices are included as Response to Request for Production No. 111
— Confidential Attachment 4.
d. Idaho Power did not received insurance proceeds as the damage was below the
per occurrence retention level provided by the policy.
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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 18

REQUEST FOR PRODUCTION NO. 112: In reference to the Company's
response to Staff Production Request No. 36, please provide normalized actual monthly
sales, revenues, and billing determinants from August 2023 through July 2024. Please
treat this as an ongoing request, supplementing it for subsequent months when actual
amounts for each month are known.
RESPONSE TO REQUEST FOR PRODUCTION NO. 112: Please see
Confidential Attachment 1 for normalized sales, revenue, billing determinants, and
associated workpapers for January—July 2024. Please note that this is an approximation,
and it is subject to change when the final weather models are developed. Please see
Confidential Attachment 2 for normalized sales, revenue, billing determinants, and
associated workpapers for August — December 2023.
- Green tabs contain the finalized requested data
- Red tabs contain the hard-coded 2024 actuals data.
- Blue tabs organize data from the red tabs.
The response to this Request is sponsored by Jessi Brady, Senior Regulatory
Analyst, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 19

DATED at Boise, Idaho, this 9t" day of September 2024.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 20

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 9t" day of September 2024, 1 served a true and
correct copy of Idaho Power Company's Response to the Thirteenth 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 THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 21

Idaho Conservation League Hand Delivered
Brad Heusinkveld U.S. Mail
710 N. 6t" Street Overnight Mail
Boise, Idaho 83702 FAX
FTP Site
X Email
bheusinkveld c(D,.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 17t" Street, Suite 3200 darueschhoff(a)hol land hart.com
Denver, CO 80202 tnelson(a)hol land hart.com
awjensen _hol land hart.corn
[e-mail]
aclee hollandhart.com
mamcmillen(o)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
Iswier(o)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 BoiseCityAttorneV(a-)_cityofboise.org
e newel I6a)cityofboise.org
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 22

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
sh u bbleCcDcityofboise.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(o-)hg.doe.gov
emily.medlyn(a-),hg.doe.gov
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE THIRTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER - 23