20241125IPC to IIPA 1-8.pdf

0-10AM POWER.
LISA D. NORDSTROM
Lead Counsel RECEIVED
Inordstrorn(Widahopower.com Monday, November 25, 2024
IDAHO PUBLIC
November 25, 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 Third 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,
ot�
Lisa D. Nordstrom
LDN:sg
Enclosures
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

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 the attachments to Request Nos. 3-1, 3-3, 3-6 and 3-7 to Idaho Power
Company's Response to Idaho Irrigation Pumpers Association, Inc.'s Third Set of Data
Requests dated November 25, 2024, contain information that Idaho Power Company
and/or a third party claim is a trade secret or confidential public records exempt from
disclosure by state or federal law (material nonpublic information under U.S. Securities
and Exchange Commission Regulation FD), 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 25th day of November 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
mgoicoecheaallenCabidahopower.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 THIRD 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") Second Set of Data
Requests to Idaho Power Company dated November 14, 2024, herewith responds to the
following information:
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
THIRD SET OF DATA REQUESTS- 1

REQUEST FOR PRODUCTION NO. IIPA 3-1: Please refer to IPC's response to
IIPA DR 2-24 attachment C. Please provide the data in the sheet "Inputs" for January
2024 to October 2024. Please provide this data using:
a. Actual values
b. Weather normalized actual values based on IPC's standard normal weather
assumptions.
c. Weather normalized actual values based on 20-year average weather.
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-1:
a. Please see Confidential Attachment 2 provided with this request for the 2024 test
year sales forecast using actual kilowatt-hour ("kWh") sales through October.
November and December data is based on the Company's most recent sales
forecast produced in September 2024.
b. Please see Confidential Attachment 1 provided with this request for the 2024 test
year sales forecast using weather normal kWh sales through September. October
through December data is based on the Company's most recent sales forecast
produced in September 2024. The Company is not able to provide weather normal
sales for October 2024, as the calculation cannot be completed and validated
within the requested timeframe.
c. The Company is not able to calculate weather normalized sales based on 20-year
average weather, as this would require the development and validation of a new
model, which could not be completed within the requested timeframe.
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
THIRD SET OF DATA REQUESTS- 2

REQUEST FOR PRODUCTION NO. IIPA 3-2: Please refer to IPC's response to
IIPA DR 2-24 attachment C. Please provide the data in the sheet "Inputs" for October
2024 to December 2024. Please provide this data using:
a. IPC's most current forecast under IPC's standard normal weather assumptions.
b. IPC's most current forecast under 20-year average weather.
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-2:
a. Please see Confidential Attachment 1 provided in response to IIPA Request No.
3-1.
b. The Company is not able to calculate an updated sales forecast based on 20-year
average weather, as this would require the development and validation of a new
model, which could not be completed within the requested timeframe.
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
THIRD SET OF DATA REQUESTS- 3

REQUEST FOR PRODUCTION NO. IIPA 3-3: Please refer to IPC's response to
Staff Data Request No. 3 attachments 1, 2, 3, 12, and 13. Please provide these
workpapers revised to reflect actual plant additions from January 2024 to October 2024
and forecasted plant additions from November 2024 to December 2024.
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-3: Actual values from
January 2024 through October 2024 have already been provided to parties as noted in
the table below:
Staff DR 3 Contents' Attachment containing Actuals
Attach. # through October 2024
1 Accumulated Reserve CONFIDENTIAL Attachment— Third
Supplemental Response to Staff Request
No. 63
2 Depreciation /Amortization CONFIDENTIAL Attachment — Third
Expense Supplemental Response to Staff Request
No. 63
3, 12 Electric Plant In Service CONFIDENTIAL Attachment — Third
Supplemental Response to Staff Request
No. 62
Forecasted plant additions from November 2024 to December 2024 were included
in the Company's initial filing and provided to parties through the Company's Response
to Staff Request No. 3. Idaho Power has not re-forecast plant for these months based on
actual closings through month-end October 2024.
Attachment 13 — Response to Staff Request No. 3 reflects the incremental labor
determination, not plant. Please see Confidential Attachment- Response to IIPA Request
No. 3-3 for the updated incremental labor determination using actuals through October
2024.
All attachments reflect the incremental calculation to determine the filed revenue requirement in this
case.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
THIRD SET OF DATA REQUESTS-4

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
THIRD SET OF DATA REQUESTS- 5

REQUEST FOR PRODUCTION NO. IIPA 3-4: Please refer to the Direct
Testimony of Dr. Don Reading page 9 lines 21 to 23. Please also refer to "Attachment -
Response to ICIP Request No. 2.xlsx"
a. Is the referenced attachment identical to the CCOS used in IPC's 2023 GRC? If
no, please explain how the referenced attachment differs from the 2023 GRC.
b. Does the referenced attachment reflect rates approved in the 2023 GRC?
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-4: Please see the
responses below regarding the file labeled "Attachment— Response to ICIP Request No.
2."
a. No, the referenced attachment is not identical to the Class Cost-of-Service
("CCOS") study used in Idaho Power's 2023 General Rate Case ('2023 GRC").
The underlying methodology is generally the same. The primary differentiating
factor is that the CCOS study used in developing the revenue allocation in this rate
case only allocated the incremental revenue requirement, whereas the 2023 GRC
CCOS study allocated the total system revenue requirement. Therefore, the
composition of the incremental revenue requirement results in a different allocation
to each customer class relative to the 2023 GRC.
b. Idaho Power assumes this question is specific to the Retail Sales. In general, a
CCOS study does not reflect retail customer rates. However, Tatum Exhibit 4,
Column C, 2024 Retail Sales, does reflect rates approved in the 2023 GRC for
calculating the percentage increase by class.
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
THIRD SET OF DATA REQUESTS- 6

REQUEST FOR PRODUCTION NO. IIPA 3-5: Please refer to the Direct
Testimony of Dr. Don Reading page 11 lines 1 to 5.
a. Please provide Schedule 19's COS Index as expressed in Column P of Tatum
Exhibit 4 using the 2023 CCOS, before and after the 2023 GRC rate increase.
b. Please explain the significance of the COS Index.
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-5: Please see
responses below.
a. The 2023 GRC Settlement Stipulation did not explicitly include a "COS Index."
However, the Company has prepared the file labeled "Attachment — Response to
IIPA 3-5a," which contains the same metric for each customer class for the 2023
GRC Settlement Stipulation. The calculation compares each customer class's mill
rate (i.e., revenue requirement per kWh sales) as a result of the final revenue
allocation compared to the CCOS results. Therefore, a "before and after GRC" is
not a calculation that can be performed as the final results are inherently
embedded in the underlying calculation of the metric. As further described in
subpart (b) to this response, the COS Index in Tatum Exhibit 4 is overstated
towards 1.0 for each customer class due to the calculation being performed on
total revenue requirement rather than just the incremental revenue requirement at
issue in this limited issue rate case.
b. The "COS Index" is a customer class's final revenue allocation ratio relative to the
CCOS results. A customer class with a ratio greater than 1.0 or 100% is being
allocated revenue requirement above the results of the CCOS study, and a ratio
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
THIRD SET OF DATA REQUESTS- 7

less than 1.0 or 100% is being allocated revenue requirement below the results of
the CCOS study.
However, the CCOS study only includes the incremental revenue requirement in
this limited issue rate case. The COS Index illustrated in Tatum Exhibit 4 combines
existing base revenue with the CCOS results for the incremental revenue
requirement. Therefore, the index is muted because each customer class's base
revenue differs from the results of a CCOS study as if it had included all revenue
requirement— not just the incremental revenue requirement.
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
THIRD SET OF DATA REQUESTS- 8

REQUEST FOR PRODUCTION NO. IIPA NO. 3-6: Please refer to IIPA Request
1-2 attachment 1 for allocation factors D10, D13, and E10.
a. How is this data generated?
b. What time period do these data represent?
c. Does this data reflect actual or normal weather? If this data is not based on normal
weather, please provide this data under normal weather.
d. Cell R92 states "Net CEYW". Please explain what Net CEYW means and provide
the data not "Net CEYW".
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-6: Please see below
responses regarding the file labeled "Attachment 1 — Response to IIPA Request No. 2 —
D10 D13 E10."
a. This data reflects 2023 test year values from the Company's 2023 GRC. The data
for the twelve monthly coincident demands at generation level, used for the
monthly D10 factors, was generated by calculating a system coincident demand
factor ("SCD"), based on 2022 actual sales for each rate. System coincident
demand factors were calculated for each rate in each jurisdiction by dividing the
rate class demand value at the time of system peak, by the average demand for
each month. This SCD is then used to calculate a system coincident demand by
multiplying the average kilowatts ("kW") for the month 2023 GRC test year by the
SCD. The average kW for the month is calculated by dividing the test year energy
by the number of hours in the month. Finally, the system coincident demand is
grossed up for losses resulting in the monthly coincident demands at generation
level.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
THIRD SET OF DATA REQUESTS- 9

The data for the monthly energy requirements at generation level, used for the
monthly E10 factors, was calculated by multiplying the 2023 test year sales for
each month and rate class by the loss factor appropriate for each rate.
b. The data in this file is weather normalized for 2023.
c. It reflects weather normalized data.
d. "Net CEYW" means net of Clean Energy Your Way generation. Please see the file
labeled "Confidential Attachment— Response to IIPA 3-6(d)."
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, 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
THIRD SET OF DATA REQUESTS- 10

REQUEST FOR PRODUCTION NO. IIPA 3-7: Please refer to the IPC 2023 IRP
Technical Appendix C page 96, LOLE percentage by month.
a. What years do these data represent?
b. Please provide the data referenced in the footnote "January and February are
expected to be as high as November and December for the 2025-2026 winter
season due to forecasted industrial customer load ramps."
c. Please also refer to Response to IIPA Request No. 2-12 - Attachment 1.xlsx Tab
"Test Year 1", which indicates 35 percent of 2024 LOLP occurs in December.
Please explain the difference between test year 1 2024 results and the results in
Appendix C page 96.
d. Please also refer to Response to IIPA Request No. 2-12 attachments 1 and 2.
Please explain the difference between test years.
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-7:
a. The monthly Loss of Load Expectation ("LOLE") results represent a 2025 load and
resource year. The 2023 Integrated Resource Plan ("IRP") LOLE analysis utilized
six test years reflecting historical data from the years 2017 through 2022.
b. Please see "Response to Request for Production No. IIPA 3-7 Attachment" for the
70th percentile peak load forecast and referenced industrial customer load ramps.
c. In reviewing the referenced Loss of Load Probability ("LOLP") data for test year 1
of 2024, Idaho Power would clarify that 35 percent of LOLP values occur in
January, not December. Generally speaking, as noted in part (a) above, the table
on page 96 of the 2023 IRP reflects the results for a 2025 load and resource year
(not a 2024 load and resource year). Also as stated in part (a) above, the monthly
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
THIRD SET OF DATA REQUESTS- 11

LOLE analysis considers the results of all six test years (not one specific test year).
The analysis reflecting the results of six test years for a 2025 load & resource year
will be not match the results of a single test year for a 2024 load & resource year.
d. IIPA Request No. 2-12 requested that the Company provide LOLE or LOLP values
under two scenarios: 1) the 2023 IRP Preferred Portfolio, and 2) utilizing the
assumption that no resources are added. The differences in values between the
two attachments referenced in this request are due to the two scenarios requested
in IIPA Request No. 2-12. Aside from the differing resource assumptions, the
underlying test year data utilized in these analyses is the same.
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
THIRD SET OF DATA REQUESTS- 12

REQUEST FOR PRODUCTION NO. IIPA 3-8: Please provide IPC's actual hourly
load from January 1, 2022 to present.
RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 3-8: Please see the
attachment provided with this response.
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
THIRD SET OF DATA REQUESTS- 13

DATED at Boise, Idaho, this 25th day of November 2024.
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
THIRD SET OF DATA REQUESTS- 14

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of November 2024, 1 served a true and
correct copy of Idaho Power Company's Response to Idaho Irrigation Pumpers
Association, Inc.'s Third 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
THIRD SET OF DATA REQUESTS- 15

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(c�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(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 BoiseCityAttorneyCa�cityofboise.org
ejewell cityofboise.org
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
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
THIRD SET OF DATA REQUESTS- 16

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
peter.meielb-hg.doe.gov
emily.medlyn(a)hg.doe.gov
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
THIRD SET OF DATA REQUESTS- 17