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