20241125FEA to IIPA 1.pdf

RECEIVED
Monday, November 25, 2024
IDAHO PUBLIC
Peter Meier UTILITIES COMMISSION
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
[e-mail]
Attorneys for the Federal Executive Agencies
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07
OF IDAHO POWER COMPANY TO )
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ) THE FEDERAL EXECUTIVE
ASSOCIATED WITH INCREMENTAL ) AGENCIES' RESPONSES TO
CAPITAL INVESTMENTS AND CERTAIN ) IDAHO IRRIGATION
ONGOING OPERATIONS AND ) PUMPERS ASSOCIATION,
MAINTENANCE EXPENSES ) INC.'S FIRST SET OF DATA
REQUESTS
The Federal Executive Agencies ("FEA") hereby provides its responses and objections to
Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") First Set of Data Requests to FEA.
FEA objects to the instructions and directions in IIPA's First Set of Data Requests insofar
as they seek: (A) to impose more burdensome requirements for discovery than the applicable
requirements of Rules 225 and 228 of the Rules of Procedure of the Idaho Public Utilities
Commission, or Commission precedent; or (B) require disclosure of privileged communications
and information pursuant to the attorney-client privilege or disclosure of communications and
information protected from discovery under the attorney work product doctrine. Subject to and
without waiving these general objections, FFA responds to IIPA's First Set of Data Requests,
FEDERAL EXECUTIVE AGENCIES' RESPONSES TO
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST SET 0F DATA REQUESTS 1

expressly reserving all evidentiary and other objections concerning FEA's responses and any
related documents that IIPA may seek to offer into evidence in this case. FEA's responses are
made in the spirit of cooperation without waiving FEA's right to contest the admissibility of any
of these matters at hearing.
IIPA 1-1: Please refer to the Direct Testimony of Larry Blank Table 2.
a. Please provide all workpapers used to generate this table.
b. Please identify all data sources used to generate this table.
C. Does this table reflect revenues prior to the 2023 GRC rate increases?
RESPONSES:
IIPA 1-La.: Please see attached Excel workbook"IIPA-FEA-I-I a WP LB-3 Tables DI Larry
Blank."
IIPA 1-I.b.: Please see Excel workbooks "Micron-FEA-1 WP LB-I AED-4CP CCOS' and
"Micron-FEA-I WP LB-2 AED-4CP"produced in response to Micron Request
No. 1.
IIPA 1-Le.: The revenues reflected in Table 2 are those as filed by IPC in its 2023 GRC
CCOS study.
This response is sponsored by Dr. Larry Blank.
Respectfully submitted, this 25th day of November 2024.
FEDERAL EXECUTIVE AGENCIES
BY THE U.S. DEPARTMENT OF ENERGY
e
Emily W. Medlyn
Attorney-Adviser
Peter Meier
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
Fax: [phone]
peter.meier(cr�,hq.doe.gov
[e-mail]
FEDERAL EXECUTIVE AGENCIES' RESPONSES TO
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST SET 0F DATA REQUESTS 2

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07
OF IDAHO POWER COMPANY TO )
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ) CERTIFICATE OF SERVICE
ASSOCIATED WITH INCREMENTAL )
CAPITAL INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES )
I CERTIFY that on this date I sent by email a true and correct copy of THE FEDERAL
EXECUTIVE AGENCIES' RESPONSES TO IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS on the parties of record to this
proceeding.
DATED November 25, 2024.
Emily W. Medlyn
Attorney-Adviser
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
FEDERAL EXECUTIVE AGENCIES' RESPONSES TO
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST SET 0F DATA REQUESTS 3