20241030IPC 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: [phone]
Facsimile: [phone]
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
[phone] or David Fewkes at [phone] 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 [e-mail]
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
[e-mail]
aclee hollandhart.com
mamcmillen(o)hol land hart.com
Jim Swier Hand Delivered
Micron Technology, Inc. U.S. Mail
8000 South Federal Way Overnight Mail
Boise, ID 83707 FAX
FTP Site
X Email
Iswier(o)micron.com
City of Boise Hand Delivered
Ed Jewell U.S. Mail
Deputy City Attorney Overnight Mail
Boise City Attorney's Office FAX
150 N. Capitol Blvd. FTP Site
P.O. Box 500 X Email
Boise, Idaho 83701 BoiseCityAttorneV(a-)_cityofboise.org
e newel I6a)cityofboise.org
IDAHO POWER COMPANY'S RESPONSE TO 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