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HomeMy WebLinkAbout20240924IPC to IIPA 1-22 (Redacted).pdf 0-10RHO POWER. LISA D. NORDSTROM Lead Counsel Inordstrom(cD-idahopower.com RECEIVED Tuesday, September 24, 2024 IDAHO PUBLIC September 24, 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. I PC-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 Idaho Irrigation Pumpers Association, Inc.'s First Set of Data Requests. 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:cd Enclosures 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(a)_idahopower.com dwalker idahopower.com mgoicoecheaallen(o)_idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE ) APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07 COMPANY TO INCREASE RATES FOR ) ELECTRIC SERVICE TO RECOVER ) IDAHO POWER COMPANY'S COSTS ASSOCIATED WITH ) RESPONSE TO IDAHO INCREMENTAL CAPITAL ) IRRIGATION PUMPERS INVESTMENTS AND CERTAIN ) ASSOCIATION, INC.'S FIRST SET ONGOING OPERATIONS AND ) OF DATA REQUESTS MAINTENANCE EXPENSES. ) COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") First Set of Data Requests to Idaho Power Company dated September 3, 2024, herewith responds to the following information: IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 1 REQUEST FOR PRODUCTION NO. IIPA 1-1: Please refer to "Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4" and "Attachment - Response to ICIP Request No. 2", which indicates that the response to Staff Request No. 3 does not include underlying workpapers. Please provide all workpapers underlying the attachments provided in response to Staff Request No. 3. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-1: The file labeled "Attachment 10 — Response to Staff Request No. 3 — Tatum Exhibit No. 4" contains the Excel file with formulas specific to the exhibit. The file labeled "Attachment — Response to ICIP Request No. 2" includes both Tatum Exhibit No. 4, as supplied in Response to Staff Request No. 3, and Idaho Power's Class Cost-of-Service ("CCOS") Study used in the development of Tatum Exhibit No. 4. See Response to Request for Production No. IIPA 1-2 for workpapers underlying the CCOS Study allocation factors. The response to this Request is sponsored by Timothy E. Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-2 REQUEST FOR PRODUCTION NO. IIPA 1-2: Please refer to "Attachment - Response to ICIP Request No. 2" tab "AIIocFactor Input". Please provide all workpapers used to calculate the values on this tab. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-2: Please see the following workpapers and corresponding support for the tab labeled "AIIocFactor_Input": Allocation Factor Supporting Workpaper Row 8-10, 15, 28-29 Attachment 1 — Response to IIPA Request No. 2 — D10 D13 E10 Row 19-23 Attachment 2 — Response to IIPA Request No. 2 — D20 D60 Row 24, 34 Attachment 3 — Response to IIPA Request No. 2 — DA360 DA362 Row 33 Attachment 4 — Response to IIPA Request No. 2 — DA350 DA359 Row 35 Attachment 5 — Response to IIPA Request No. 2 — DA364 DA367 Row 36 Attachment 6 — Response to IIPA Request No. 2 — DA368 Row 37-38 Attachment 7 — Response to IIPA Request No. 2 — DA371 DA373 Row 39 Attachment 8 — Response to IIPA Request No. 2 — CWINSTAL Row 40 Attachment 9 — Response to IIPA Request No. 2 — DA454 Row 42 Attachment 10 — Response to IIPA Request No. 2 — INTFUND Row 45 Confidential Attachment 10 — Response to Staff Request No. 35 Row 48,51-54, 94 Attachment 11 — Response to IIPA Request No. 2 — C10 Row 55 Attachment 12 — Response to IIPA Request No. 2 — CW369 Row 56 Attachment 13 — Response to IIPA Request No. 2 — CW370 Row 57 Attachment 14 — Response to IIPA Request No. 2 — CW902 Row 58 Attachment 15 — Response to IIPA Request No. 2 — CW903 Row 59 Attachment 16 — Response to IIPA Request No. 2 — CW904 Row 68-73 and 83 Attachment 17 — Response to IIPA Request No. 2 — D99U E99U D10U Row 74 and 76 Case No. IPC-E-23-11, Brady Exhibit No. 28 The response to this Request is sponsored by Timothy E. Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 3 REQUEST FOR PRODUCTION NO. IIPA 1-3: Please provide the following data for each new customer with demand greater than 1 MW that has been energized or is expected to be energized in 2024 or 2025: a. Rate Schedule b. Expected annual load c. Date service began or is expected to begin. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-3: Idaho Power does not forecast individual customers that are under 20 MW in size. Rather, the forecasts are developed by customer class (residential, commercial and industrial, and irrigation) and then categorized by rate schedule and jurisdiction. To date in 2024, there has been one new customer installation that has reached a load of greater than 1 MW. Rate Schedule 2024 Peak In-Service Date 119P 1,308 kW 1/31/2024 The response to this Request is sponsored by Jordan Prassinos, Load Forecast Manager and Principal Economist, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-4 REQUEST FOR PRODUCTION NO. IIPA 1-4: Please refer to "Response to Staff Request No. 35 -Attachment 1 - Load Forecasting Methodology.pdf" page 5 which states "Individual forecasts of customers with unique energy service agreements that exceed 20 megawatts ("MW") in size are provided to the Company from the customer." Please provide the 2023, 2024, and 2025 actual and forecasted load by month and delivery point, for each individually forecasted customer. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-4: Please see "Confidential Attachment - Response to IIPA Request No. 1-4.xlsx." The response to this Request is sponsored by Jordan Prassinos, Load Forecast Manager and Principal Economist, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 5 REQUEST FOR PRODUCTION NO. IIPA 1-5: Please refer to "Attachment - Response to ICIP Request No. 2" tab "AS—Table 9". Please explain what the 411.4 - Investment Tax Credit Adjustment represents and why it is appropriate to allocate this cost using the P111 P factor. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-5: The 411.4 — Investment Tax Credit Adjustment represents both federal and state investment tax credits related to property used in utility operations. The investment tax credits are only earned on investment in plant, excluding intangibles and real property. The P111 P allocation factor represents the total plant net of contributions in aid of construction ("CIACs") less intangibles and is therefore appropriate to allocate 411.4 Investment Tax Credit Adjustment. However, in preparation for this response, the Company discovered a modeling discrepancy in the derivation of the P111 P allocation factor. The calculation includes actual net distribution plant figures from the 2023 general rate case, while all other figures are a forecast limited and specific to the incremental rate base in the instant case. As a result, the P111 P allocation factor was overstated in the distribution substation weight and understated in the baseload demand weight. A reasonable modification would be to use the P101 P allocation factor instead to model the plant allocation. The response to this Request is sponsored by Timothy E. Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-6 REQUEST FOR PRODUCTION NO. IIPA NO.1-6: Please refer to "Attachment 14 - Response to Staff Request No. 3 - Larkin Exhibit No. 9 - Revenue Growth Offset.xlsx". a. How were the 2023 ID kWh Sales calculated? Does the value represent actual sales, normalized actual sales, 2023 GRC test period sales, or some other measure of sales? b. Please explain how the Mill Rate was calculated. c. Please explain how Incremental 2024 sales were calculated. d. Please provide supporting workpapers for the hardcoded values in this file. e. Please provide actual, and weather normalized sales by month and customer class from 2013 to present. f. Please provide the most recent load forecast currently in use by IPC's IRP team. g. Please provide the load forecast used in IPC's most recently completed IRP or IRP update. h. Please explain the difference between the 2024 sales on this sheet and normalized energy of 15,032,559,714 kwh in Attachment 9 - Response to Staff Request No. 3 - Application Attachment 3. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-6: a. The "2023 ID kWh Sales" is the forecast test year sales from the 2023 GRC. b. The calculation of the mill rate was provided in Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power Company dated July 5, 2024, labeled "Attachment 7— Response to Staff Request No. 3 — Larkin Workpaper 7 — Revenue Growth Offset." IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 7 c. Incremental 2024 sales were calculated by subtracting the 2023 GRC Idaho kWh sales from the 2024 GRC Idaho kWh sales. Please see part (h). d. Please see the responses below. • 2023 ID kWh Sales: Please see "Brady Workpaper 1 — Revenue Forecast Workbook" (tab: kWh Forecast Summary, cell: N75) provided in the Company's 2023 General Rate Case. • Mill Rate: Please see part (b). • Incremental 2024 ID kWh Sales: Please see "Response to Staff Request No. 35 - Confidential Attachment 10 - Revenue Forecast" for the 2024 test year ID kWh sales (tab: kWh Forecast Summary, cell: N78). The incremental 2024 ID kWh sales are calculated by subtracting the 2024 ID kWh sales from the 2023 ID kWh sales. Please see part (h). e. Please see "Confidential Attachment - Response to IIPA Request No. 1-6e" for historical sales and weather adjusted sales data. f. Please see "Confidential Attachment - Response to IIPA Request No. 1- 6f 2023_IRP_Forecast.xlsx" for the forecast used in the most recently acknowledged IPR (2023). The forecast for the current 2025 IRP is under assessment. g. Please see part (f). h. The 2024 ID kWh sales included in Attachment 9 - Response to Staff Request No. 3 - Application Attachment 3 matches the 2024 sales value included in Attachment 14 - Response to Staff Request No. 3 - Larkin Exhibit No. 9 - Revenue Growth Offset.xlsx". Please see the calculation below: IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 8 • 2023 ID kWh Sales: 14,907,835,244 • Incremental 2024 ID kWh Sales: 124,724,470 • 2024 ID kWh Sales: 14,907,835,244 + 124,724,470 = 15,032,559,714 The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 9 REQUEST FOR PRODUCTION NO. IIPA 1-7: Please refer to "Attachment 14 - Response to Staff Request No. 3 - Larkin Exhibit No. 9 - Revenue Growth Offset.xlsx". a. Please confirm that IPC's revenue forecast only accounts for incremental revenue attributable to rate base and labor. b. Please explain why IPC does not include all incremental revenue in the revenue growth offset. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-7: a. Correct, the revenue forecast only accounts for incremental revenue attributable to rate base and operations and maintenance ("O&M") labor expense. b. Because this current case was limited to only include incremental rate base and O&M labor expense, the Company gave appropriate revenue credit for the incremental revenue that would occur due to load growth since the 2023 GRC by only including rate base and O&M labor expense components. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 10 REQUEST FOR PRODUCTION NO. IIPA 1-8: Please refer to "Response to Request for Production No. 5 - Confidential Attachment- Capital Projects Completed Thru May 2024 list". a. Please explain why the amounts in rows 3616 to 3619 are negative. Is it IPC's intention to exclude incremental rate base associated with these types of assets? b. Please provide each load request indicated in the description for the following work orders i. 27599593 ii. 27610080 iii. 27620766 iv. 27620765 v. 27650842 vi. 27586408 vii. 27643697 viii. 27615513 ix. 27621630 RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-8: a. The amounts in rows 3616 to 3619 of Idaho Power's "Response to Request for Production No. 5 - Confidential Attachment - Capital Projects Completed Thru May 2024 list" are not negative. They are in fact positive amounts. A work order could be placed in service with a negative amount, as can be seen on row 3281, which would generally indicate a Contribution in Aid of Construction ("CIAC")was received that exceeded the work order costs at the time the work order was placed in service. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 11 It is not Idaho Power's intention to exclude these types of work orders from its incremental rate base. b. Work orders 27599593, 27610080, 27620766, and 27620765 were completed as a result of numerous individual customer load requests totaling approximately 20 MW. The total 20 MW load request was comprised of the following individual requests: ■. Work order 27650842 involved the replacement of the spare breaker at the Spring Valley Substation which was completed in response to an approximately _load request from_, with which the CIAC was reflected on a separate work order. Work order 27586408 is not the result of a customer load request but rather due to the transformer exceeding the planning capacity. Work order 27643697 is not the direct result of a customer load request. Rather, after a temporary satellite communication network was established at the Karcher Substation as a result of a = customer load request from ., a network modification to support a permanent reliable communication system based on best practices at substations was implemented. Work orders 27615513 and 27621630 are a result of a large load request for the load that is greater than 20 MW. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 12 REQUEST FOR PRODUCTION NO. IIPA 1-9: Please refer to Tatum Direct page 9 line 6 to 20. a. Please provide the final approved revenue requirement from the 2023 GRC by component. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-9: Please see Attachment — Response to IIPA Request No.1-9 for the requested information. The response to this Request is sponsored by Timothy E. Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 13 REQUEST FOR PRODUCTION NO. IIPA 1-10: Please provide actual 2023 expenses by FERC account and subaccount. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-10: Please see "Response to IIPA Request No. 1-10 — Attachment" for actual 2023 expenses by FERC account. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 14 REQUEST FOR PRODUCTION NO. IIPA 1-11: Please provide IPC's rate base by month from December 2022 to January 2024. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-11: Idaho Power does not calculate rate base on a monthly basis; therefore, the Company is providing the Idaho allocated rate base for year-end 2022 and 2023. Please note this information reflects actual year-end results consistent with the financial information utilized to prepare the annual FERC Form 1 filing. 2022 2023 Idaho Allocated Rate Base 3,789,804,059 4,195,270,090 The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 15 REQUEST FOR PRODUCTION NO. IIPA 1-12: Please provide IPC's results of operations by state for 2022 and 2023. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-12: The Company does not prepare a result of operations report in Idaho. The Idaho results of operations, as presented in this case, was prepared to demonstrate the need for the proposed rate increase. The Oregon results of operations report for 2022 and 2023 are publicly available and can be found at the following links: 2022 - https://edocs.puc.state.or.us/efdocs/HAQ/re48hag163535.pdf 2023 - https://edocs.puc.state.or.us/efdocs/HAQ/re48hag327868055.pdf The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 16 REQUEST FOR PRODUCTION NO. IIPA 1-13: Please provide IPC's 2023 and 2024 budget at the most granular level available. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-13: Please see Response to IIPA DR No. 1-13 — Confidential Attachment for the requested information. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 17 REQUEST FOR PRODUCTION NO. IIPA 1-14: Please refer to "Attachment 3 - Response to Staff Request No. 3 - Larkin Workpaper 3 - Incremental Plant Determination.xlsx." a. Please confirm that IPC's revenue requirement is based on forecasted 2024 end of year plant balance. If not confirmed please explain what period is represented in rate base. b. Please explain why IPC does not use the 13 month average reported in tab "Elec Plant In Service" column BT. c. Does IPC's revenue growth adjustment reflect annualization of December, 2024 load? If no, please explain how revenue growth is consistent with using end-of- year 2024 plant balances. d. Please provide the data in columns D and E for 2025. e. Please identify revenue requirement workpapers supporting the proposed base revenue of$1,458,265,770. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-14: a. Correct, as discussed in Mr. Larkin's testimony, the revenue requirement is based on the incremental difference between the plant balances approved in the 2023 Idaho GRC Settlement Stipulation and forecast 2024 end-of-year plant balances. b. The direct testimony of Tim Tatum thoroughly discusses regulatory lag and its impact on the Company. To mitigate the negative impacts of regulatory lag, the Company specifically chose to use year-end plant balances as opposed to a historical monthly average. This ensures that the rate base included in customer IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 18 rates reflects plant investments placed in service up to the time rates go into effect, thereby reducing, although not eliminating, regulatory lag. c. Idaho Power is unclear what is meant by "annualization" within the context of this question. However, the Company's revenue offset calculation included in this case reflects rates expected to be in effect as of December 31, 2024. d. The Company does not possess a forecast of plant balances for year-end 2025. e. The base revenue of $1,458,265,770 is comprised of the 2024 Retails sales forecast of $1,358,972,550 and is provided as "Response to Staff Request No. 35 - Confidential Attachment 10 - Revenue Forecast" (tab: Rev Forecast Summary, cell: N76) and the as-filed 2024 incremental revenue requirement of$99,293,220. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 19 REQUEST FOR PRODUCTION NO. IIPA 1-15: Please refer to Attachment 1 - Response to Staff Request No. 3 - Larkin Workpaper 1 - Accumulated Reserve. a. Please explain how IPC forecasts retirements. b. Please explain how IPC forecasts salvage. c. Please explain how IPC forecasts removal costs. d. Please provide actual retirements, salvage, and removal by FERC account and month for 2024. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-15: a. Idaho Power forecasted retirements by analyzing actual retirement activity for the previous five-year period 2019 through 2023. Retirement activity by FERC plant account was determined and compared to the final closings (plant additions) by FERC plant account for the same five-year period, yielding a historical percentage of retirements to plant additions. Retirements by FERC plant account for 2024 were then estimated by applying the historical percentage to the 2024 forecasted plant additions. The following FERC plant accounts have known retirement dates based on vintage layers and were not estimated: 1. Account 302— Franchises and consents 2. Account 303— Miscellaneous intangible plant 3. Account 391— Office furniture and equipment 4. Account 393—Stores equipment 5. Account 394— Tools, shop, and garage equipment 6. Account 395—Laboratory equipment 7. Account 397—Communication equipment 8. Account 398—Miscellaneous equipment IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-20 b. and c. To forecast salvage and removal cost, Idaho Power calculated average salvage, average removal costs, and average retirements by functional area (Steam Production, Hydraulic Production, Other Production, Transmission Plant, Distribution Plant and General Plant) for the previous five-year period (2019 through 2023). The salvage and removal averages as a percentage of the retirement average were used to estimate monthly salvage and removal costs, allocated to FERC plant accounts utilizing the respective ratio to estimated 2024 retirements. d. Please see Response to IIPA Request No. 1-15 — Confidential Attachment for actual 2024 retirements, salvage, and removal by FERC account and month through August 2024, the most recently completed accounting period. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-21 REQUEST FOR PRODUCTION NO. IIPA 1-16: Please provide IPC's actual and forecasted regulated capital structure by month from January 31, 2022 to December 31, 2025. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-16: Please see "Response to IIPA Request No. 1-16 - Confidential Attachment" for the requested information. The capital structure was provided quarter1ly for the requested periods to match the company's public filings. The response to this Request is sponsored by Tim E. Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-22 REQUEST FOR PRODUCTION NO. IIPA 1-17: Please refer to Attachment 6 - Response to Staff Request No. 3 - Larkin Workpaper 6 - Results of Operations Model.xlsx tab "JSS — PF". Please provide the source for the hard coded numbers in this sheet. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-17: The source for the hard coded numbers was provided in Idaho Power Company's Response to the First Production Request of ICIP to Idaho Power Company dated July 5, 2024, provided as Attachments 1 — 21 to the Company's response to ICIP Request No. 1 . The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-23 REQUEST FOR PRODUCTION NO. IIPA 1-18: Please provide workpapers reconciling the forecast estimates in Response to Staff Request No. 35 with the forecasted energy in "Attachment 9 - Response to Staff Request No. 3 - Application Attachment 3". RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-18: Please see "Confidential Attachment - Response to IIPA Request No. 1-18.xlsx." The "Comparison" tab contains the Idaho kWh forecast from both "Attachment 9 - Response to Staff Request No. 3 - Application Attachment 3" and "Response to Staff Request No. 35 — Confidential Attachment 10 — Revenue Forecast." Column N shows that these two forecasts reconcile to each other. The "Recon" tab shows a reconciliation of the kWh forecast to the various model tabs ("RES Model" tab, "COM Model" tab, "IND Model" tab, and "IRR Model' tab), which contain the predicted values from the model output results provided in the Response to Staff Request No. 35. The response to this Request is sponsored by Jordan Prassinos, Load Forecast Manager and Principal Economist, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-24 REQUEST FOR PRODUCTION NO. IIPA 1-19: Please refer to "Response to Staff Request No. 35 - Attachment 6 — Irrigation". a. Please provide all documentation available to IPC regarding the Palmer Z-Index. b. Please explain why the Palmer Z-Index is assumed to be zero in 2024. c. Please provide the Palmer Z-index by month from 2002 to present. d. Please provide the most current forecast of the Palmer Z-index available to IPC. e. Please provide the calculation of the Weighted Growing Degree Days Base 50 variable. f. Please explain how weights are calculated for the Weighted Growing Degree Days Base 50 variable. g. Please explain the rational for including the Residential Customers Added Per Year variable. Please include an explanation for why annual additions is preferred over total customers and provide explain why IPC finds it reasonable to forecast a negative relationship between residential customer additions and irrigation load. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-19: a. The historical Palmer Z-Index, obtained by Idaho Power from the National Oceanic and Atmospheric Administration ("NOAX), measures short-term drought on a monthly scale by accounting for precipitation, temperature, soil conditions, and evapotranspiration'. Negative values indicate drier than normal conditions; positive values indicate wetter than normal conditions. An average of the April through August Palmer Z-Indices for the Idaho "Central Plains" division for each Palmer, W.C., 1965: Meteorological drought. Research Paper No. 45. U.S. Weather Bureau. [NOAA Library and Information Services Division,Washington, D.C. 208521 IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-25 year of the estimation period (2002 to 2022)was used as a variable in the irrigation sales forecast model. b. The Palmer Z-Index is a historical index; therefore, when the irrigation sales forecast was completed in 2023, only the values for years 2002 through 2022 were utilized. c. Please see "Attachment - Response to IIPA Request No. 1-19c.xlsx." d. Idaho Power does not assume any long-term drought conditions in the forecast. e. The calculation of the Weighted Growing Degree Days Base 50 variable is done within an internal proprietary database. Because of this, Idaho Power does not possess a workpaper that shows the calculation. The calculation takes the daily average temperature for 5 weather stations (based on NOAA data) and sums up the number of degrees the daily average temperature is over 50, by month. Weighting is then applied based on the irrigation pumping horsepower for each area. f. Weights are calculated for the Weighted Growing Degree Days Base 50 variable by dividing the irrigation pumping horsepower in each weather station's area by the total irrigation pumping horsepower (all using the most recent calendar year). g. The correlation of new homes represented by annual residential customer additions is, while not exclusively, largely taking away from irrigated lands. Accordingly, the statistical finding of this negative relationship was deemed appropriate to use as a variable in the irrigation sales forecast model. The response to this Request is sponsored by Jordan Prassinos, Load Forecast Manager and Principal Economist, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-26 REQUEST FOR PRODUCTION NO. IIPA 1-20: Please refer to "Attachment 5 - Response to Staff Request No. 3 - Larkin Workpaper 5 - O&M Labor.xlsx" a. Please provide the data on tab "Labor Development" column I for 2024 to present. b. Please provide the data on tab "2023 Actual Payroll-SourcePg1" for 2021, 2022, and 2024 to present. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-20: a. Please see Response to IIPA Request No. 1-20a — Confidential Attachment. b. Please see Response to IIPA Request No. 1-20b — Confidential Attachment. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-27 REQUEST FOR PRODUCTION NO. IIPA 1-21: Please refer to Tatum Direct page 21 lines 3 to 7. a. Please confirm that IPC is requesting labor costs expected for 2025. b. Has IPC accounted for revenue growth expected for 2025? If yes, please identify the associated workpapers. If no, please explain how this is consistent with 2025 labor costs. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-21: a. Only the proposed general wage adjustment ("GWA") that will be in effect at year- end 2024 is included in the O&M labor forecast, reflective of when the proposed rates would become effective. However, this excludes other components of incremental 2025 labor such as headcount increases, merit salary increases, and benefit cost increases. b. There was no incremental revenue adjustment for 2025 because the Company did not include a full forecast of 2025 O&M labor in this case. Only the GWA, consistent with prior general rate cases, was included and represents the labor costs that will be in effect on January 1, 2025. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-28 REQUEST FOR PRODUCTION NO. IIPA 1-22: Please refer to the Response to Staff Request 35. Please provide the load forecast for 2025 by rate schedule. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-22: Idaho Power did not prepare a 2025 forecast by rate schedule for this filing. However, please see the attachments 1-7 for class model output data, as discussed in "Response to Staff Request No. 35 — Attachment 1 — Load Forecasting Methodology", through 2025. The response to this Request is sponsored by Jordan Prassinos, Load Forecast Manager and Principal Economist, Idaho Power Company. DATED at Boise, Idaho, this 24th day of September 2024. 67�Zc. eo 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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-29 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 24th day of September 2024, 1 served a true and correct copy of Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s First Set of Data Requests 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 PO Box 83720 Chris.Burdin(o)-puc.idaho.gov Boise, ID 83720-0074 Industrial Customers of Idaho Power Hand Delivered Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27t" Street FAX Boise, Idaho 83702 FTP Site X Email peter richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dreadingCc mindsprinq.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 Pocatello, Idaho 83205 elo echohawk.com Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance(a)_aegisinsight.com IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 30 Idaho Conservation League Hand Delivered Brad Huesinkveld U.S. Mail 710 N. 6th 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 17th Street, Suite 3200 darueschhoff(�Oollandhart.com Denver, CO 80202 tnelson(o)_hollandhart.com awjensen ,hollandhart.com karoach(o�hol land hart.com aclee 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 jswier(c)_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 BoiseCityAttorney(o)_cityofboise.org ejewell cityofboise.org IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 31 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(a_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(cDhq.doe.gov emily.medlyn(cD_hg.doe.gov Christy Davenport Legal Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 32