20240919IPC to Staff 120-121.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 19, 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
Fifteenth 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.

Sincerely,

Lisa D. Nordstrom

LDN:sg
Attachments
' a1DA11> POWER .
RECEIVED
Thursday, September 19 2024
IDAHO PUBLIC
UTILITIES COMMISSION

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 attachments to Request Nos. 120 and 121 to Idaho Power
Company’s Response to the Fifteenth Production Request of the Commission Staff
dated September 19, 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, 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 19th day of September 2024.

Lisa D. Nordstrom
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 1
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]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS
ASSOCIATED WITH INCREMENTAL
CAPITAL INVESTMENTS AND
CERTAIN ONGOING OPERATIONS
AND MAINTENANCE EXPENSES.
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-24-07

IDAHO POWER COMPANY’S
RESPONSE TO THE FIFTEENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fifteenth Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated September 5, 2024, herewith submits the
following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 120: 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 July 2024”:
a. Transaction Date;
b. Transaction Number;
c. Transaction Amount; and
d. Transaction Purpose (Services performed and/or material purchased, etc.)
RESPONSE TO REQUEST FOR PRODUCTION NO. 120: Please see Response
to Staff Request No. 120 – Confidential Attachment. Idaho Power does not have a
Transaction Number for each transaction. Instead, Idaho Power has numbered each row.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 121: Please provide invoices for the sample
selected in the confidential attachment titled “June Capital Project Transaction Sample”.
For selections not linked to specific invoices, please explain the accounting method used
to determine the amount and provide calculations that determine the amount in Excel
format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 121: Please see Response
to Request for Production No. 121 - Confidential Attachments 1 through 12 providing
supporting documentation for the expenses selected in Staff’s sample, “June Capital
Project Transaction Sample”.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 4
DATED at Boise, Idaho, this 19th day of September 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 FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 19th day of September 2024, I served a true and
correct copy of Idaho Power Company’s Response to the Fifteenth 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
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
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FTP Site
X Email [e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

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X Email [e-mail]

Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 6
Idaho Conservation League
Brad Heusinkveld
710 N. 6th Street
Boise, Idaho 83702
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701

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IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 7
Steven Hubble
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Federal Executive Agencies
Peter Meier
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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Stacy Gust
Regulatory Administrative Assistant

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