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HomeMy WebLinkAbout20241030IPC to IIPA 1-26 (2nd Set).pdf 0-10AM POWER. LISA D. NORDSTROM Lead Counsel RECEIVED InordstromCaDidahopower.com Wednesday, October 30, 2024 IDAHO PUBLIC October 30, 2024 UTILITIES COMMISSION VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s Second Set of Data Requests. Please note the information requested in IIPA Request Nos. 2-3 and 2-4 contains non-public material financial information related to third quarter financial results. However, Idaho Power will publicly issue its third quarter earnings release prior to markets opening on Thursday, October 31, at which point the financial information contained in these responses will no longer be confidential. To avoid designating this information as confidential and to lessen the administrative burden of parties utilizing the requested data in this case, Idaho Power will provide these attachments by 9 a.m., Thursday, October 31, rather than close of business Wednesday, October 30. Idaho Power has consulted with counsel for IIPA who has indicated they do not oppose this approach. 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. 1221 W. Idaho St(83702) P.O. Box 70 Boise, ID 83707 Commission Secretary Idaho Public Utilities Commission October 30, 2024 Page 2 If you have any questions about the attached filing, please do not hesitate to contact me. Sincerely, X. Lisa D. Nordstrom LDN: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. 2-5, 2-6, 2-11, 2-14, 2-15, 2-22, 2-23, 2-24, and 2-26 to Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s Second Set of Data Requests dated October 30, 2024, contain information that Idaho Power Company and/or a third party claim is a trade secret, business records of a private enterprise required by law to be submitted to or inspected by a public agency, confidential public records exempt from disclosure by state or federal law (material nonpublic information under U.S. Securities and Exchange Commission Regulation FD), and/or public records exempt from disclosure by federal law (Critical Energy/Electric Infrastructure Information under Federal Energy Regulatory Commission Order Nos. 630 and/or 662) 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 30th day of October 2024. Lisa D. Nordstrom Attorney for Idaho Power Company LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(aMdahopower.com dwalker idahopower.com mgoicoecheaallen(abidahopower.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 SECOND ONGOING OPERATIONS AND ) SET 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") Second 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 SECOND SET OF DATA REQUESTS- 1 REQUEST FOR PRODUCTION NO. IIPA 2-1: Please refer to Attachment 1 - Response to IIPA Request No. 1-2 — D10 D13 E10.xlsx. a. Please provide the source for the values in cells C71:C82. b. Please provide the source for the values in cells C114:C125. c. Please provide the date and time used for each monthly coincident peak demand. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-1: Please see responses below regarding the D10 D13 El Allocation Factor workpaper: a. The source for the values in cells C71:C82 is Exhibit 44 — Idaho 2023 Marginal Cost Study from Case No. IPC-E-23-11 (page 7, column 7). b. The source for the values in cells C114:C125 is Exhibit 44 — Idaho 2023 Marginal Cost Study from Case No. IPC-E-23-11 (page 3, row 10). c. Please see the file labeled "Response to IIPA Request No. 2-1 - Attachment" for the date and time for each monthly coincident peak demand. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 2 REQUEST FOR PRODUCTION NO. IIPA 2-2: Please provide the hourly real time energy prices for each market hub IPC participates in from 2022 to present. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-2: Please see the attached Excel file labeled "Response to IIPA Request No. 2-2 — Attachment" which includes the hourly Western Energy Imbalance Market ("EIM") Load Aggregation Point ("ELAP") prices for Idaho Power for January 2022—September 2024. The EIM is the real- time energy market that Idaho Power participates in and the ELAP price is reflective of the real-time value of energy on Idaho Power's system. 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 SECOND SET OF DATA REQUESTS- 3 REQUEST FOR PRODUCTION NO. IIPA 2-3: Please provide IPC's actual system and Idaho jurisdictional net power costs by month from 2020 to present. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-3: Please see the attached Excel file labeled "Response to I IPA Request No. 2-3—Attachment"to be posted by 9:00 a.m. on October 31, 2024. 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 SECOND SET OF DATA REQUESTS-4 REQUEST FOR PRODUCTION NO. IIPA 2-4: Please refer to Confidential Attachment — Response to IIPA Request No. 1-6e.xlsx. Please provide these data for retail sales by jurisdiction. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-4: Please see the attached file labeled "Response to IIPA Request No. 2-4 —Attachment 1" to be posted by 9:00 a.m. on October 31, 2024, for the retail sales by jurisdiction. 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 SECOND SET OF DATA REQUESTS- 5 REQUEST FOR PRODUCTION NO. IIPA 2-5: Please provide the day ahead high load hour and low load hour energy prices for each market hub IPC participates in from 2022 to present. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-5: Please see the confidential attachment labeled "Response to IIPA Request No. 2-5 — Confidential Attachment" which includes the day-ahead heavy-load ("HL") and light-load ("LL") energy prices for the Mid-Columbia, Palo Verde and Mead market hubs as published by the Intercontinental Exchange ("ICE"). 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 SECOND SET OF DATA REQUESTS- 6 REQUEST FOR PRODUCTION NO. IIPA NO. 2-6: Please provide the forecasted market prices at the most granular level available for 2025 for each market hub IPC participates in. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-6: Please see the confidential attachment "Response to IIPA Request No. 2-6 — Confidential Attachment" which includes the monthly forward HL and LL energy prices for 2025 for the Mid- Columbia, Palo Verde and Mead market hubs, as published by ICE. 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 SECOND SET OF DATA REQUESTS- 7 REQUEST FOR PRODUCTION NO. IIPA 2-7: Please provide all data, calculations, and workpapers used by IPC to support claims of liquidated damages associated with any recent BESS fires. Please explain how the Company intends to treat these amounts in rates. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-7: There are no liquidated damages associated with the recent BESS-related fire. Other damages related to the BESS fire are unknown at this time, and Idaho Power intends to recover any such damages from the supplier. As discussed in the Company's Responses to Staff's Requests for Production Nos. 79 through 84, any liquidated damages Idaho Power collects pursuant to the BESS project delays, including any associated with the project involved in the BESS fire, will be applied as a credit to net power supply expenses and therefore will flow back to customers through the Power Cost Adjustment ("PCA"). The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company, and Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 8 REQUEST FOR PRODUCTION NO. IIPA 2-8: Please identify the total MW and MWh of battery storage, by facility, included in net power cost underlying IPC's current rates. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-8: Please see the table below for the megawatt ("MW") and megawatt-hours ("MWh") of battery storage by facility included in Idaho Power's base power supply costs as established in the Company's 2023 General Rate Case: Facility MW MWh Black Mesa 40 160 Hemingway 80 320 Distribution-Connected BESS Sites 11 44 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 SECOND SET OF DATA REQUESTS- 9 REQUEST FOR PRODUCTION NO. IIPA 2-9: Please identify the total MW and MWh of battery storage, by facility, included in IPC's current filing. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-9: The following table presents the battery energy storage systems ("BESS") requested for recovery in the Company's current filing including their operating capacity and megawatt-hours supplied in alternating current ("AC"): BESS Contract Supplied Megawatt-hours Capacity Capacity Supplied Franklin 60 MW 65.93 MW 263.74 MWh Hemingway 36 MW 42.65 MW 170.61 MWh Black Mesa 40 MW 46.56 MW 186.22 MWh The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 10 REQUEST FOR PRODUCTION NO. IIPA 2-10: Please provide a copy of any special contract which IPC expects to serve energy under in 2025 or 2026. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-10: All executed special contracts are publicly available on the Commission's website. The Company expects to provide service to the following special contract customers in 2025 or 2026: Micron (Schedule 26), Simplot (Schedule 29), Department of Energy (Schedule 30), Simplot Caldwell (Schedule 32), Brisbie (Schedule 33), and Lamb Weston (Schedule 34). The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 11 REQUEST FOR PRODUCTION NO. IIPA 2-11: Please provide the following data for each customer over 10 MW: a. Name, capacity, and location of each substation electrically connected to the customer. b. Capacity and length of each circuit connecting the customer to substations. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-11: Please see the file labeled "Response to IIPA Request No. 2-11 — Confidential Attachment" for a list of the names, station transformer capacity, and location of substations serving customers having a demand over 10 MW. This list includes the capacity and length of circuits leaving the substation to each customer's point of delivery. The response to this Request is sponsored by Mitch Colburn, VP of Planning, Engineering & Construction, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 12 REQUEST FOR PRODUCTION NO. IIPA 2-12: Please refer to the 2023 IPC IRP. a. Please provide the loss of load expectation or loss of load probability by month and year under the 2023 IRP preferred portfolio. b. Please provide IPC's LOLE or LOLP by month from 2024 to 2027 if IPC does not acquire any additional capacity resources. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-12: a. Please see the file labeled "Response to IIPA Request No. 2-12 — Attachment 1" for the hourly Loss of Load Probability ("LOLP") values from Idaho Power's 2023 Integrated Resource Plan ("IRP") Preferred Portfolio for the 20-year planning horizon (2024-2043). Please note that the Company's Reliability & Capacity Assessment Tool ("RCAT") calculates LOLP values under various load and weather years; the six test years utilized in the 2023 IRP are provided in the separate sheets. b. Please see the file labeled "Response to IIPA Request No. 2-12 — Attachment 2" for the hourly LOLP values from Idaho Power's 2023 IRP assuming no identified resources from the Preferred Portfolio are included for 2024 through 2027. As stated in the response to part a, the Company's RCAT calculates LOLP values under various load and weather years; the six test years utilized in the 2023 IRP are provided in the separate sheets. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 13 REQUEST FOR PRODUCTION NO. IIPA 2-13: Please provide a diagram of IPC's transmission, generation, and load topology. Please identify the location of each BESS facility. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-13: Please see the file labeled "Response to IIPA Request No. 2-13 — Attachment — System Map" for a diagram demonstrating the topology of Idaho Power's transmission, generation, and BESS facilities. For a discussion of load topology please see the Company's Response to IIPA's Request No. 2-14. The response to this Request is sponsored by Mitch Colburn, VP of Planning, Engineering & Construction, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 14 REQUEST FOR PRODUCTION NO. IIPA 2-14: Please provide the most recent substation level long term load forecast provided by IPC's energy service division to IPC's transmission division. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-14: Idaho Power does not produce a single substation-level long-term load forecast. Transmission planning studies may use different hourly system loads as a starting point depending on what substation load scenario is being analyzed. For an example of a recent forecast by substation utilized by Idaho Power, please see the file labeled "Response to IIPA Request No. 2-14 — Confidential Attachment" for the substation loads used in the development of a 2025 heavy load summer planning model. The response to this Request is sponsored by Mitch Colburn, VP of Planning, Engineering & Construction, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 15 REQUEST FOR PRODUCTION NO. IIPA 2-15: Please provide the Black Mesa Power Purchase Agreement. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-15: Please see the file labeled "Response to IIPA Request No. 2-15 — Confidential Attachment." The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 16 REQUEST FOR PRODUCTION NO. IIPA 2-16: Please refer to Schedule 26. Please provide the Revised Exhibit 1 of Micron's Special Contract, dated March 9, 2022, as amended. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-16: The requested documents are available on the Commission's website. Please reference Case Nos. IPC- E-22-06, IPC-E-23-30, and IPC-E-24-23. See also Case No. IPC-E-24-18. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 17 REQUEST FOR PRODUCTION NO. IIPA 2-17: Was the Black Mesa PPA included in the final revenue requirement of the 2023 GRC? RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-17: No. Expenses associated with the Black Mesa PPA were not included in the 2023 General Rate Case ("GRC") revenue requirement. 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 SECOND SET OF DATA REQUESTS- 18 REQUEST FOR PRODUCTION NO. IIPA 2-18: Please refer to Exhibit No. 2 Case No. IPC-E-23-11 Settlement Stipulation Page 26. Does the billed kwh of 591,344,540 reflect the total forecasted load of Micron, or the load net of Black Mesa generation? RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-18: The billed kWh of 591,344,540 reflects Micron's forecasted load net of Black Mesa Solar generation. 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 SECOND SET OF DATA REQUESTS- 19 REQUEST FOR PRODUCTION NO. IIPA 2-19: Does the company currently have any schedule 20 customers? RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-19: No. 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 SECOND SET OF DATA REQUESTS- 20 REQUEST FOR PRODUCTION NO. IIPA 2-20: Does the company expect to have any schedule 20 customers in 2025? RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-20: The Company does not have any current indication that it will have any customers taking service under Schedule 20 in 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 SECOND SET OF DATA REQUESTS- 21 REQUEST FOR PRODUCTION NO. IIPA 2-21: Please refer to In the Supreme Court of The State of Idaho Docket No. 49126, Opinion Filed: May 17, 2023. a. Please provide the total dollar value of property tax at issue in this proceeding by year. b. Please provide the total Idaho property tax assessed by year from 2019 to present. Please indicate if these amounts include or exclude the contested amount identified in response to part a. c. Please provide the amount of Idaho property tax included in the 2023 GRC. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-21: a. This lawsuit has concluded regarding the issue of uniformity (State of Idaho Docket No. 49126 Opinion). However, the case was remanded back to the District Court (Fourth Judicial District of the state of Idaho CV01-21-14121) for further litigation to determine whether Idaho Power was unconstitutionally overtaxed. Until the final decision from the District Court, a financial impact cannot be determined. b. Idaho Property Tax Tax Idaho Irrigators Total 2023 2023 Total Year Property Property Property House Bill House Bill Property Tax Before Tax Tax before 292 292 Tax After House Bill Payments HB 292 Tax Additional School HB 292 Tax 292 Tax Idaho Relief Tax Relief District Relief Relief Code 63- 6020 2019 19,310,731 2,480,719 21,791,450 21,791,450 2020 18,846,093 2,131,850 20,977,943 20,977,943 2021 17,211,791 2,241,947 19,453,738 19,453,738 2022 14,581,590 1,866,235 16,447,825 16,447,825 2023 12,177,582 1,443,286 13,620,868 (121,730) (1,000,305) 12,498,833 The contested amounts are not determined. Years 2020, 2021 and 2022 are in dispute. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 22 c. The amount of Idaho property tax included in the 2023 GRC was $19,639,172 on a total system basis (reference P. Jeppsen, Exhibit No. 22, page 12) multiplied by an allocation factor of 95.67 percent for an Idaho allocated amount of$18,788,796 (reference K. Noe, Exhibit No. 35, page 19). 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 SECOND SET OF DATA REQUESTS- 23 REQUEST FOR PRODUCTION NO. IIPA 2-22: Please provide each IPC credit opinion available to IPC issued by Moody's or Standard and Poor's from 2020 to present. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-22: Please see confidential attachments 1-15 for the credit opinions issued by Moody's and Standard and Poor's from 2020 to present. The response to this Request is sponsored by Brian Buckham, Senior Vice President, Chief Financial Officer & Treasurer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 24 REQUEST FOR PRODUCTION NO. IIPA 2-23: Please provide all communications between IPC or IPC's parent and Moody's or Standard and Poor's in 2023 and 2024. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-23: Communications between Idaho Power and Moody's or Standard and Poor's from 2023 to 2024 that were not conducted telephonically consisted of the publication of credit opinions by Moody's and Standard and Poor's (provided in the Company's response to Request No. 2-22), and additional highly confidential presentations and reports provided by Idaho Power to Moody's and Standard and Poor's. The highly confidential information will be made available to IIPA at Idaho Power's corporate headquarters. Please contact Tami White at (208) 388-6938 or David Fewkes at (208) 388-2628 to arrange a time to review the requested material. For communications issued by Standard and Poor's and Moody's in 2023 and 2024 related to IdaCorp, please see confidential attachments 1-3. The response to this Request is sponsored by Brian Buckham, Senior Vice President, Chief Financial Officer & Treasurer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 25 REQUEST FOR PRODUCTION NO. IIPA 2-24: Please refer to Attachment - Response to IIPA Request No. 1-9.xlsx. a. Please confirm that the amount in Attachment - Response to IIPA Request No. 1- 9.xlsx line 45 of $1,287,899,827 reflects the Idaho firm jurisdictional sales approved in IPC's most recent general rate case. b. Please confirm that this revenue is based on the 14,907,835,244 kWh of sales identified in the incremental revenue tab of "Attachment 7 - Response to Staff Request No. 3 - Larkin Workpaper 7 - Revenue Growth Offset". c. Please provide the workpaper used to calculate a revenue of $1,287,899,827 based on the rates and load approved in IPC's last general rate case. d. Does IPC agree that the "Mill Rate", or revenue per kWh, approved in the prior rate case was $0.090061? If no, what was the revenue per kWh approved in the prior case? e. Does IPC agree that if the mill rate of $0.090061 is applied to the 124,724,470 incremental kWh included in "Attachment 7 - Response to Staff Request No. 3 - Larkin Workpaper 7 - Revenue Growth Offset", the total incremental revenue is $11,232,852.81? If no, what is the total incremental revenue? f. Please refer to Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx which indicates Idaho retail revenue of $1,358,973,000, which is $16.3 million more than the revenue reported in Attachment - Response to IIPA Request No. 1-9.xlsx line 45. Please explain why the incremental revenue reported in Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx differs from that calculated when the mill rate is applied to incremental sales. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 26 RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-24: a. Firm jurisdictional revenues of $1,287,899,827, consisting of 2023 normalized revenues, Base Revenue Transfer - PCA, and Base Revenue Transfer - Energy Efficiency ("EE") Rider, was the base revenue amount from which the percentage increase required was calculated. The amount of firm jurisdictional revenue approved in the 2023 General Rate Case was $1,342,619,613, which is comprised of the Firm Jurisdictional Sales of $1,287,899,827 plus the approved revenue requirement of $54,719,786. b. The 2023 normalized revenues which are included as part of the Firm Jurisdictional Revenues were based on the 14,907,835,244 kWh of sales. c. The workpaper showing the calculation of the 2023 normalized sales is provided as "Response to IIPA Request No. 2-24c — Confidential Attachment 1", the Base Revenue Transfer — PCA calculation is provided as "Response to IIPA Request No. 2-24c—Attachment 2", and the Base Revenue Transfer— EE Rider calculation is provided as "Response to IIPA Request No. 24c — Attachment 3." d. Yes, the system mill rate of $0.090061 is the result of dividing the approved revenue requirement in the 2023 ID GRC Settlement and corresponding 2023 normalized sales ($1,342,619,613 _ 14,907,835,244 kWh). e. No, the Company disagrees. Multiplying the system mill rate from the 2023 ID GRC Settlement by the 124,724,470 incremental kWh does not provide the total incremental revenue, as explained in subsection 'T' below. The total incremental revenue differs between the 2024 test year revenue forecast and the 2023 ID GRC Settlement ($1,358,972,550 - $1,342,619,613 = $16,352,937). IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 27 f. Please see the file labeled "Response to Staff Request No. 35 - Confidential Attachment 10 - Revenue Forecast" for the underlying support of the 2024 test year revenue forecast of $1,358,972,550. Specifically, please see tab "Rev Forecast Summary". The system mill rate in the 2023 ID GRC Settlement gives equal weighting to every kWh of sales. In contrast, the test year revenue forecast considers the specific composition of energy sales by customer class and the varying rates paid by customer class. Therefore, incremental revenue cannot be calculated using the system mill rate from the 2023 ID GRC Settlement without consideration for the incremental energy sales by customer class. 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 SECOND SET OF DATA REQUESTS- 28 REQUEST FOR PRODUCTION NO. IIPA 2-25: Please refer to Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx. Please also refer to Confidential Attachment - Response to IIPA Request No. 1-4.xlsx. a. Please indicate where the load associated with Simplot on Columns D and G appear in Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx and explain any differences between the 2024 amounts in IIPA 1-4 and Tatum Exhibit 4. b. Please indicate where the load associated with Lamb Weston on column D appears in Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx and explain any differences between the 2024 amounts in IIPA 1-4 and Tatum Exhibit 4. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-25: a. The load associated with Simplot (Column D) is located on Row 18 in Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx. There are no differences between the amount in IIPA 1-4 and Tatum Exhibit 4. The load associated with Simplot Caldwell (Column G) is included with Schedule 19 and located on Row 11 in Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx. There are no differences between the amount in IIPA 1-4 and Tatum Exhibit 4. b. The load associated with Lamb Weston (Column E) is included with Schedule 19 and located on Row 11 in Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx. There is a difference between the amount in IIPA 1-4 and Tatum Exhibit 4, and this amount is Lamb Weston's forecast Block 2 sales. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 29 Forecast Block 2 sales are included in IIPA 1-4 but not included in Tatum Exhibit 4, as Block 2 sales are not considered retail revenue as they are credited to customers in the PCA mechanism. 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 SECOND SET OF DATA REQUESTS- 30 REQUEST FOR PRODUCTION NO. IIPA 2-26: Confidential Attachment - Response to IIPA Request No. 1-4.xlsx. Please provide the large customer forecast used in IPC's last general rate case. Please provide in the format used in Confidential Attachment - Response to IIPA Request No. 1-4.xlsx. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 2-26: Please see the file labeled "Response to IIPA Request No. 26-2 — Confidential Attachment" for the large customer forecast used in Idaho Power's 2023 GRC. The response to this Request is sponsored by Matthew Larkin, Revenue Requirement Senior Manager, Idaho Power Company. DATED at Boise, Idaho, this 30th day of October 2024. 62�ZL 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 SECOND SET OF DATA REQUESTS- 31 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 30th day of October 2024, 1 served a true and correct copy of Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s Second 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(a)-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. 27' 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 dread ing�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@aegisinsight.com IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 32 Idaho Conservation League Hand Delivered Brad Huesinkveld 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 karoachC@hollandhart.com 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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 33 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 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(a�hg.doe.gov emily.medlyn(o)_hg.doe.gov Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND SET OF DATA REQUESTS- 34